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Rev. Proc. 2025-6

SECTION 4. PROCEDURE

Internal Revenue Bulletin 2025-6 · 2026-10-03 edition · updated 2026-10-04 · United States

.01 In-scope applicable entities chang- ing their annual accounting period . An in-scope applicable entity that desires to change its taxable year may effectuate the change by timely filing the Form 990-T for the first effective year with the appropriate Internal Revenue Service Center. The Form 990-T must be filed by the fifteenth day of the fifth month following the close of the short period (absent filing a Form 8868, Application for Extension of Time to File an Exempt Organization Return or Excise Taxes Related to Employee Bene- fit Plans, requesting an extension to file a Form 990‑T). The Form 990-T should indicate that a change of annual accounting period is being made and include a statement describing the present annual accounting period and the proposed annual accounting period. The in-scope applicable entity is not required to file Form 1128 with the Form 990-T.

.02 Automatic approval . An in-scope applicable entity that complies with all the applicable provisions of this revenue procedure will have obtained the approval of the Commissioner for a change in annual accounting period, beginning with the first effective year.

.03 Examples . (1) Example (1) . XYZ is an applicable entity described in section 3.02(1) of this revenue procedure. XYZ is not required to file either a federal income tax return under § 6011 or an annual information return under § 6033(a) and has never filed a return or adopted a taxable year. XYZ keeps its books and records on the basis of a fiscal year that ends on September 30. In February 2023, XYZ places into service an applicable credit property, as defined in § 1.6417-1(e), that meets the requirements to generate an applicable credit under § 6417. XYZ desires to make an elective payment election under § 6417. Applying § 1.6417-2(b)(3)(i), XYZ adopts a calendar year taxable year ending on December 31, 2023, for the sole purpose of making an elec

tive payment election under § 6417, by timely filing Form 990-T on the basis of a calendar year and by declaring on Form 990-T that XYZ has adopted as its taxable year a calendar year ending December 31, 2023. XYZ maintains adequate books and records, including a reconciliation of any differences between its regular books and records year and those of its chosen taxable year, to support making an elective payment election based on its chosen taxable year. XYZ has adopted a calendar tax year. If XYZ desires to change its taxable year to an accounting period that matches its books and records, it will be an “in-scope applicable entity” within the meaning of section 3.02 of this revenue procedure.

(2) Example (2). Same facts as Example (1), except that XYZ now wishes to conform its taxable year to its accounting period used in keeping its books and records and, accordingly, wants to change to a taxable year ending September 30 effective for the taxable year beginning January 1, 2024, and ending September 30, 2024 (that is, the first effective year). Pursuant to section 4.01 of this revenue procedure, XYZ files a Form 990-T for the short period beginning January 1, 2024, and ending September 30, 2024, by the fifteenth day of the fifth month after the end of XYZ’s short taxable year (or Tuesday, February 18, 2025, accounting for February 15 falling on a Saturday and Monday, February 17 being a Federal holiday) and attaches a statement to the Form 990-T indicating that a change of taxable year from a calendar year taxable year to a taxable year ending September 30 is being made. XYZ has changed its taxable year to a taxable year ending September 30 and has obtained the approval of the Commissioner for the requested change.

(3) Example (3). Same facts as Example (2), except that XYZ, instead of timely filing its Form 990-T on or before February 18, 2025, timely files the Form 8868 on or before February 18, 2025 . XYZ is now entitled to a 6-month automatic extension to file its Form 990-T. Thus, XYZ has until August 15, 2025, to timely file the Form 990-T on which it makes the desired change in its taxable year to a taxable year ending September 30 and to obtain the approval of the Commissioner for the requested change.

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