SECTION 9. GRANT OF CONSENT

FOR AN AUTOMATIC CHANGE

Pursuant to § 1.446–1(e)(2)(i), the consent of the Commissioner is hereby granted to any taxpayer that is eligible to make an automatic change. This consent is granted only for the change(s) in method of accounting and the affected item(s) that are clearly and expressly identified in the taxpayer’s Form 3115. See SECTION 6.02(2). Further, such consent is granted only if the taxpayer complies with all the applicable provisions and implements the change in method of accounting on its federal income tax return for the requested year of change to which the original Form 3115 is attached pursuant to SECTION 6.03. In the case of an entity that is not required to file a federal income tax return (for example, a CFC or 10/50 corporation), consent is granted only if the entity complies with all the applicable provisions and the change in

method of accounting is reflected on the timely filed (including any extension) federal income tax return(s) on which the entity’s affected item(s) is included for the year with or within which ends the entity’s requested year of change.