SECTION 9. REQUESTS FOR

CONSENT TO CHANGE FROM SEPARATE ENTITY REPORTING TO SINGLE ENTITY REPORTING IN CASES WHERE A VALID CONSENT FROM THE SERVICE TO REPORT INTERCOMPANY TRANSACTIONS ON A SEPARATE ENTITY BASIS WAS NOT PREVIOUSLY OBTAINED

Requests for consent to change from separate entity reporting to single entity reporting, where a valid consent from the Service to report intercompany transactions on a separate entity basis was not previously obtained, must be separately requested as a change in method of accounting under Rev. Proc. 97–27, or its successor. Any such changes in methods of accounting are effected on a cut-off basis (that is, no § 481(a) adjustment will be made).