SECTION 4. MODIFICATIONS

.01 Inapplicability of Rev. Proc. 2006– 45 . Section 4.02 of Rev. Proc. 2006–45 is modified to add a new paragraph (15) to read as follows:

“(15) Certain specified foreign corpo- rations. Notwithstanding any other provision in this section 4, a specified foreign corporation (as defined in section 965(e)) if each of the following conditions is satisfied:

(a) The specified foreign corporation’s taxable year (determined without regard to the requested change) ends on December 31;

(b) If the requested change were permitted, the first effective year of the corporation would begin on January 1, 2017, and would end on a date before December 31, 2017; and (c) The specified foreign corporation has one or more United States shareholders that must include an amount in gross income under section 951(a)(1) by reason

of section 965 with respect to the specified foreign corporation or any other specified foreign corporation (with such amount determined without regard to the requested change).”

.02 Inapplicability of Rev. Proc. 2002– 39. Section 3 of Rev. Proc. 2002–39 is modified to add a new subsection 3.03 to read as follows:

“.03 Inapplicability for certain speci- fied foreign corporations . Notwithstanding any other provision of this revenue procedure, a request to change the annual accounting period of a specified foreign corporation (as defined in section 965(e)) pursuant to this revenue procedure will not be approved if:

(a) The specified foreign corporation’s taxable year (determined without regard to the requested change) ends on December 31;

(b) If the requested change were permitted, the first effective year of the corporation would begin on January 1, 2017, and would end on a date before December 31, 2017; and (c) The specified foreign corporation has one or more United States shareholders that must include an amount in gross

income under section 951(a)(1) by reason of section 965 with respect to the specified foreign corporation or any other specified foreign corporation (with such amount determined without regard to the requested change).”