SECTION 1. PURPOSE

.01 Withdrawal of a § 163(j) election . This revenue procedure provides guidance under § 163(j) ¹ regarding the withdrawal of an election under § 163(j)(7)(B) and § 1.163(j)-9 to be an electing real property trade or business, an election under § 163(j)(7)(C) and § 1.163(j)-9 to be an electing farming business, and an election under § 1.163(j)-1(b)(15)(iii) to be an excepted regulated utility trade or business, for purposes of the business interest deduction limitation under § 163(j). This revenue procedure allows certain taxpayers to withdraw such an election for the taxable year in which the election was made. This revenue procedure also allows a taxpayer that withdraws one of these elections to make a late election not to deduct the additional first-year depreciation for certain property.

.02 Revoking or making a CFC group election . In addition, this revenue procedure provides guidance under § 1.163(j)-7(e) allowing a taxpayer to revoke or make a controlled foreign corporation (CFC) group election without

regard to the 60-month limitation under § 1.163(j)-7(e)(5)(ii) for the first specified period of a specified group beginning after December 31, 2024.

.03 Amended partnership returns . This revenue procedure allows eligible partnerships to file amended partnership returns for taxable years beginning in 2022, 2023, and 2024 using a Form 1065, U.S. Return of Partnership Income (Form 1065), with the “Amended Return” box checked, and to issue an amended Schedule K-1, Partner’s Share of Income, Deductions, Credits, etc. (Schedule K-1), to each of its partners. Eligible partnerships subject to the rules of subchapter C of chapter 63 of the Code (BBA partnerships) may file an administrative adjustment request under § 6227 (AAR). BBA partnerships satisfying the requirements of section 7 of this revenue procedure may opt to file an amended Form 1065 and furnish amended Schedules K-1 instead of filing an AAR.