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Introduction

SECTION 12. LOSSES, EXPENSES

Internal Revenue Bulletin 2015-5 · 2026-10-03 edition · updated 2026-10-04 · United States

AND INTEREST WITH RESPECT TO TRANSACTIONS BETWEEN RELATED TAXPAYERS (§ 267)

.01 Change to comply with § 267 .

(1) Description of change . This change applies to a taxpayer that wants to change its method or methods of accounting to comply with the requirements of § 267, which disallows or defers certain deductions attributable to transactions between related taxpayers. However, this change does not apply to a change for original issue discount (OID), including stated interest that is OID because it is not qualified stated interest (as defined in § 1.1273–1(c)). See section 5.02 of this revenue procedure for a change to comply with § 163(e)(3) for OID on an obligation held by a related foreign person.

(2) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 12.01 is “26.” (3) Contact information . For further information regarding a change under this section, contact Steven Gee at (202) 3177007 (not a toll-free number). For further information regarding a change to comply with § 267(a)(3), contact Joseph Vetting at (202) 317-4960 (not a toll-free number).

.02 Reserved .

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▸Contents — Internal Revenue Bulletin 2015-5
Internal Revenue Bulletin 2015-5

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