SECTION 7. REQUEST FOR

COMMENTS

Section 461(h)(2)(A) and § 1.461– 4(d)(2)(i) do not define the phrase “as services are provided” for purposes of determining when economic performance occurs for liabilities arising from services to be provided to the taxpayer by another person. The Treasury Department and the Internal Revenue Service invite comments regarding when economic performance occurs for liabilities arising from services to be provided to

the taxpayer by another person under contracts for: (1) deliverable-type services that are not completed on a periodic basis, (2) multiple services that are not separately priced, and (3) Ratable Service Contracts that are longer than one year.

Comments may be submitted in writing on or before November 15, 2015. Comments should be submitted to Internal Revenue Service, CC:PA:LPD:PR (Rev. Proc. 2015–39), Room 5203, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044, or electronically to Notice. comments@irscounsel.treas.gov . Please include Rev. Proc. 2015–39 in the subject line of any electronic communication.

Alternatively, comments may be hand delivered Monday through Friday between the hours of 8 a.m. and 4 p.m. to CC:PA:LPD:PR (Rev. Proc. 2015–39), Courier’s Desk, Internal Revenue Service, 1111 Constitution Avenue, N.W., Washington, DC.

All comments will be available for public inspection and copying.