SECTION 3. SCOPE

.01 Section 163(j)(7)(B) and (C) and § 1.163(j)-1(b)(15)(iii) elections . Section 4 of this revenue procedure applies to a taxpayer that made an election under § 163(j)(7)(B) and § 1.163(j)-9 to be an electing real property trade or business, under § 163(j)(7)(C) and § 1.163(j)-9 to be an electing farming business, or under § 1.163(j)-1(b)(15)(iii) to be an excepted regulated utility trade or business, on its timely filed (including extensions) original Federal income tax return or Form 1065 for a taxable year beginning in 2022 (2022 taxable year), 2023 (2023 taxable year), or 2024 (2024 taxable year) and now wants to withdraw the election. The elections described in the preceding sentence are referred to in this revenue procedure as “§ 163(j)(7) elections” collectively or as a “§ 163(j)(7) election” individually. If a taxpayer withdraws an election pursuant to this revenue procedure, the taxpayer will be treated as if the election had never been made. The fact that a taxpayer satisfies the scope requirement of this section 3 is not a determination that the taxpayer is a real property trade or business for purposes of §§ 162, 212, or 469, a farming business for purposes of §§ 162, 199A, or 263A, or a regulated utility trade or business for purposes of §§ 162, 168, or 501.

.02 Section 168(k)(7) election . Section 5 of this revenue procedure applies to a taxpayer that (a) is withdrawing a § 163(j)(7) election under section 4 of this revenue procedure, (b) during the taxable year of its prior § 163(j)(7) election or a subsequent taxable year, placed into service depreciable property, (c) timely filed its Federal income tax return or Form 1065 for the placedin-service year of such depreciable property on or before March 18, 2026, and (d) has not yet made, but wants to make, a late § 168(k)(7) election with respect to a class of depreciable property that includes property affected by the withdrawal of the § 163(j)(7) election.

.03 CFC group election . Section 6 of this revenue procedure applies to a taxpayer that has made or revoked a CFC

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group election for a specified period of a specified group beginning on or before December 31, 2024, and wants to revoke this election or make a new election, respectively, for the first specified period of the specified group beginning after December 31, 2024, but the 60-month limitation described in § 1.163(j)-7(e)(5) (ii) is not satisfied.

.04 Amended BBA partnership returns . The filing and furnishing option provided by section 7 of this revenue procedure applies to BBA partnerships described in section 7.03 of this revenue procedure for the taxable years described in section 7.04 of this revenue procedure. This revenue procedure exercises § 6031(b) authority to allow a BBA partnership to file an amended partnership return and issue amended Schedules K-1 under the circumstances described in section 7 of this revenue procedure. A non-BBA partnership that is required or previously chose to file Form 1065 must file an amended Form 1065 and issue amended Schedules K-1 to each of its partners.