SECTION 3. SCOPE

.01 Applicability . The procedures in section 4 of this revenue procedure apply only to in-scope applicable entities described in section 3.02 of this revenue procedure.

.02 In-scope applicable entity . An in-scope applicable entity is an applicable entity described in section 3.02(1) of this revenue procedure that is also described in section 3.02(2) of this revenue procedure.

(1) An applicable entity is described in this section 3.02(1) if it is one of the following—

(a) An organization exempt from the tax imposed by subtitle A of the Code because it is the government of any U.S. territory or a political subdivision thereof. See § 1.6417-1(c)(1)(ii).

(b) Any State, the District of Columbia, or political subdivision thereof. See § 1.6417-1(c)(2).

(c) A Tribal entity that is— (i) An Indian Tribal government or a subdivision thereof ( See § 1.6417-1(c) (3)),

(ii) A Tribe incorporated under § 17 of the Indian Reorganization Act of 1934, as amended, or incorporated under § 3 of the Oklahoma Indian Welfare Act, as amended, that seeks to make an elective

1 Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

2 For this purpose, filing Form 990-T, Exempt Organization Business Income Tax Return (and proxy tax under section 6033(e)), solely to make an elective payment election under § 6417 is not considered a requirement to file a federal income tax return under § 6011.

Bulletin No. 2025–6 713 February 3, 2025

payment election with respect to any applicable section 6417 credit, ³ or

(iii) A wholly owned entity organized or incorporated under the laws of the Indian Tribal government(s) that owns it and that seeks to make an elective payment election with respect to any applicable § 6417 credit. ⁴

(d) An agency of any applicable entity described in section 3.02(1)(a), (b), or (c) of this revenue procedure.

(2) An applicable entity is described in this section 3.02(2) if it—

(a) Is not required to file either a federal income tax return under § 6011 or an annual information return under § 6033(a),

(b) Has adopted a taxable year by filing a Form 990-T for the sole purpose of making an elective payment election under § 6417, and (c) Desires to change its taxable year to match the accounting period used in keeping its books and records.

.03 Inapplicability . The procedures in section 4 of this revenue procedure do not apply to entities that are not in-scope applicable entities described in section 3.02 of this revenue procedure, including entities that have either filed a federal income tax return under § 6011 or filed an annual information return under § 6033(a) with the Internal Revenue Service Center and were required to use their established taxable year when making an elective payment election under § 6417. Entities described in the preceding sentence may request a change in annual accounting period under Rev. Proc. 2006-45, 2006-45 I.R.B. 851 (relating to corporations and certain other entities), Rev. Proc. 2006-46, 2006-45 I.R.B. 859 (relating to partnerships, S corporations, electing S corporations (as described therein), and personal service corporations), Rev. Proc. 85-58, 1985-2 C.B. 740 (relating to organizations exempt from federal income tax under § 501(a)), or Rev. Proc. 2002-39, 2002-22 I.R.B. 1046 (relating to entities not eligi

ble under the automatic approval procedures), as applicable.