SECTION 1. PURPOSE

As a result of travel restrictions and disruptions resulting from the global outbreak of the virus that causes COVID-19 (the “COVID-19 Emergency”), individuals may temporarily conduct activities in a country other than the United States or in a territory of the United States (any such country or territory, a “foreign country”) that would not otherwise have been conducted there. Absent guidance such as this revenue procedure, there may be uncertainty regarding whether these activities give rise to a foreign branch separate unit for purposes of the dual consolidated loss rules under section 1503(d) or an obligation to file Form 8858 (“Information Return of U.S. Persons With Respect to Foreign Disregarded Entities (FDEs) and Foreign Branches (FBs)”). This revenue procedure provides that certain activities are not taken into account for either of these purposes.