SECTION 10. STARTUP EXPENDITURES AND

ORGANIZATIONAL FEES (§§ 195, 248, AND 709).

01 Start-up expenditures (1) Description of change and scope (a) Applicability . This change applies to a taxpayer that wants to change its method of accounting under § 195 to change:

(i) the characterization of an item as a start-up expenditure;

(ii) the determination of the taxable year in which the taxpayer begins the active trade or business to which the start-up expenditures relate; or

(iii) the amortization period of a startup expenditure to 180 months.

(b) Inapplicability . This change does not apply to:

(i) start-up expenditures paid or incurred before October 23, 2004; or

(ii) start-up expenditures paid or incurred after October 22, 2004, and before August 17, 2011, if the period of limitations on assessment of tax for the taxable

year the election under § 1. 195-1(b) is deemed made has expired.

(2) No rulings (a) Characterization of item . The consent granted under section 9 of Rev. Proc. 2015-13 for a change specified in section 10. 01(1)(a)(i) of this revenue procedure is not a determination by the Commissioner that the taxpayer has properly characterized an item as a start-up expenditure and does not create any presumption that the proposed characterization of an item as a start-up expenditure is permissible under § 195(c)(1). The director will ascertain whether the taxpayer’s characterization of an item as a start-up expenditure is permissible.

(b) When active trade or business be- gins . The consent granted under section 9 of Rev. Proc. 2015-13 for a change specified in section 10.01(1)(a)(ii) of this revenue procedure is not a determination by the Commissioner that the taxpayer has properly determined the taxable year in which the taxpayer begins the active trade or business to which the start-up expenditures relate and does not create any presumption that the proposed taxable year in which the taxpayer begins the active trade or business to which the start-up expenditures relate is permissible under § 195(c)(2). The director will ascertain whether the taxpayer’s determination of the taxable year in which the taxpayer begins the active trade or business to which the start-up expenditures relate is permissible.

(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change to a method of accounting under this section 10. 01 is “223. ”

(4) Contact information . For further information regarding a change under this section, contact Elizabeth Binder at (202) 317-7005 (not a toll-free number).. 02 Organizational expenditures under § 248

(1) Description of change and scope (a) Applicability . This change applies to a corporation that wants to change its method of accounting under § 248 to change:

(i) the characterization of an item as an organizational expenditure;

(ii) the determination of the taxable year in which the corporation begins busi

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(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 10. 03 is “229. ” (4) Contact information . For further information regarding a change under this section, contact Meghan Howard at (202) 317-5055 (not a toll-free number).