IRS MODIFIES RECENT REVENUE PROCEDURE FOR APPROVAL TO CHANGE CORPORATION'S ANNUAL ACCOUNTING PERIOD

July 9, 1992 TO: TAX MEMBERS NO. 44-92 ACCOUNTING/TREASURERS MEMBERS NO. 27-92 RE: IRS MODIFIES RECENT REVENUE PROCEDURE FOR APPROVAL TO CHANGE CORPORATION’S ANNUAL ACCOUNTING PERIOD __________________________________________________________ As we previously informed you, earlier this year the Internal Revenue Service ("IRS") issued Rev. Proc. 92-13, which revised the requirements by which a corporation may secure expedited approval for a change in its annual accounting period. (See Institute Memorandum to Tax Members No. 6-92 and Accounting/ Treasurers Members No. 3-92, dated January 17, 1992.) The attached IRS revenue procedure (No. 92-13A) modifies and amplifies certain sections of Rev. Proc. 92-13. Among the changes made by Rev. Proc. 92-13A is the clarification that the expedited approval procedure set forth in Rev. Proc. 92-13 may not be used by a corporation that is a direct or indirect shareholder of a passive foreign investment company ("PFIC") that is a qualified electing fund with respect to the shareholder. Corporations that are not shareholders in PFICs, as well as corporations holding shares of PFICs that are not qualified electing funds with respect to the shareholder, may use the expedited approval procedure if the other requirements set forth in Rev. Proc. 92-13 are met. We will keep you informed of developments. Keith D. Lawson Associate Counsel - Tax Attachment