SECTION 13. LOSSES, EXPENSES

AND INTEREST WITH RESPECT TO TRANSACTIONS BETWEEN RELATED TAXPAYERS (§ 267).

01 Change to comply with § 267 (1) Description of change . This change applies to a taxpayer that wants to change its method or methods of accounting to comply with the requirements of § 267, which disallows or defers certain deductions attributable to transactions between related taxpayers. However, this change does not apply to a change for original issue discount (OID), including stated interest that is OID because it is not qualified stated interest (as defined in § 1.12731(c)). See section 5. 02 of this revenue procedure for a change to comply with § 163(e)(3) for OID on an obligation held by a related foreign person.

(2) Certain eligibility rules inappli- cable . The eligibility rules in sections 5. 01(1)(e) and (f) of Rev. Proc. 2015-13, 2015-5 I. R. B. 419, do not apply to this change to comply with § 267(a)(3).

(3) Designated automatic accounting method change number . The designated automatic accounting method change number for a change under this section 13. 01 is “26. ” (4) Contact information . For further information regarding a change under this section, contact Steven Gee at (202) 3177007 (not a toll-free number). For further information regarding a change to comply with § 267(a)(3), contact Michael Kaercher at (202) 317-6934 (not a toll-free number).

November 25, 2019 1162 Bulletin No. 2019–48