SECTION 1. PURPOSE

This document provides procedures for making certain elections required by the amendments to § 936 of the Internal Revenue Code by the Omnibus Budget Reconciliation Act of 1993 (OBRA), § 13227, 1993–3 C.B. 3, 77. Specifically, this revenue procedure provides rules for electing the § 936(a)(4)(B) percentage limitation in post-1993 tax years and describes how certain affiliated possessions corporations may elect to compute the § 936(a)(4)(A) economic activity limitation on a consolidated basis in post-1993 tax years pursuant to § 936(i)(5). The revenue procedure also provides rules for revoking a possessions corpora

tion’s § 936(a) election and changing a § 936(h) intangible property income allocation method in post-1993 tax years.