NO EXPEDITIOUS ACCOUNTING PERIOD CHANGES FOR CORPORATIONS MAKING SECTION 936 ELECTION.

Rev. Proc. 94-12

SECTION 1. PURPOSE

This revenue procedure modifies section 4 (SCOPE) of Rev. Proc. 92-13, 1992-1 C.B. 665, by adding a new condition which must be satisfied in order to obtain expeditious approval under the revenue procedure. The new section 4.01(14) prohibits the use of the revenue procedure by corporations which have an election in effect under section 936 of the Internal Revenue Code.

SEC. 2. BACKGROUND

.01 Rev. Proc. 92-13 permits certain corporations to obtain expeditious approval of a change in their annual accounting period.

.02 Section 4.01 of Rev. Proc. 92-13 identifies the corporations that are eligible under the revenue procedure to obtain expeditious approval of a change in their annual accounting period.

.03 Section 4.03 of Rev. Proc. 92-13 provides that corporations which are unable to use the automatic provisions of the revenue procedure or section 1.442-1(c) of the Income Tax Regulations must secure prior approval from the Commissioner for a change in annual accounting period pursuant to section 1.442-1(b)(1).

SEC. 3. APPLICATION

A new subsection (14) is added to section 4.01 of Rev. Proc. 92- 13 to read as follows:

.01 This revenue procedure applies to a corporation that:

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(14) is not a corporation which has in effect an election under section 936 of the Code.

SECTION 4. EFFECTIVE DATE

This revenue procedure is effective for applications for change in annual accounting period filed on or after August 10, 1993.

SECTION 5. EFFECT ON OTHER DOCUMENTS

Rev. Proc. 92-13 is modified.

DRAFTING INFORMATION

The principal author of this revenue procedure is TaJuana Nelson Hyde of the Office of Assistant Chief Counsel (Income Tax and Accounting). For further information regarding this revenue procedure, contact Ms. Nelson Hyde on (202) 622-4990 (not a toll-free number).