Rev. Proc. 66-33

SECTION 1. SCOPE.

This Revenue Procedure extends certain provisions of Revenue Procedure 64-54, C.B. 1964-2, 1008, to apply to taxable years beginning prior to January 1, 1965, and announcess the effective date of the proposed Income Tax Regulations under section 482 of the Internal Revenue Code of 1954.

SEC. 2. REVENUE PROCEDURE 64-54.

.01 Revenue Procedure 64-54 prescribes the Service's policy and procedure for the treatment of United States controlling taxpayers subject to `economic double taxation or other undue hardship for taxable years beginning prior to January 1, 1963, arising from the application of section 482 of the Internal Revenue Code of 1954 (section 45 of Internal Revenue Code of 1939) to the United States controlling taxpayers and one or more of their controlled foreign entities

.02 It has been ascertained that the circumstances causing the hardships which Revenue Procedure 64-54 was designed to mitigate continued beyond January 1, 1963. Accordingly, all of the provisions of Revenue Procedure 64-54, with the exception of section 4.02 thereof, are extended to cover taxable years of United States controlling taxpayers beginning prior to January 1, 1965. Section 4.02 applies only to the cases of United States controlling taxpayers for taxable years beginning prior to January 1, 1963.

SEC. 3. EFFECTIVE DATE OF PROPOSED SECTION 482 REGULATIONS.

It is contemplated that when proposed regulations sections 1.482-1(d) and 1.482-2 are finally adopted, they will apply to all taxable years covered by the Internal Revenue Code of 1954, except as provided otherwise in section 1.482-2(d)(4)(ii)(a) of the regulations. However, the Internal Revenue Service will not pursue section 482 allocations where section 4.01 of Revenue Procedure 64-54, as amended, and as clarified by Revenue Ruling 65-109, C.B. 1965-1, 222, so provides.

¹ Also Released as Technical Information Release 836, dated August 2, 1966.