SECTION 5. APPLICABILITY

DATE

This revenue procedure is applicable to adjustments under § 481(a)(2) that result from an eligible terminated S corporation’s change to an overall accrual method of accounting in the C corporation’s first taxable year after the revocation of its election under § 1362(a), when such revocation occurs during the two-year period beginning on December 22, 2017.

DRAFTING INFORMATION

The principal author of this revenue procedure is Natasha Mulleneaux of the Office of Associate Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Ms. Mulleneaux at (202) 317-7007 (not a toll-free number).

26 CFR 601.105: Examination of returns and claims for refund, credit, or abatement; determination of correct tax liability (Also: 842(b))

Rev. Proc. 2018–45