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, and, to clarify, this change also applies to a taxpayer that, by reason of the

exception in § 1. 267(a)-3(c)(4), wants to change its method of accounting with respect to the deduction of amounts owed to a controlled foreign corporation (as defined in § 957) (CFC) that does not have any United States shareholders (as defined in § 951(b)) owning stock of the CFC within the meaning of § 958(a). 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 § 1.1273-1(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. 201513, 2015-5 I. R. B. 419, do not apply to this change to comply with § 267(a)(3), including a change by reason of the exception in § 1. 267(a)-3(c)(4).

(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 Livia Piccolo at (202) 317-7007 (not a toll-free number). For further information regarding a change to comply with § 267(a)(3), contact Dylan Steiner at (202) 317-6934 (not a toll-free number).