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CONSOLIDATED RETURNS
In Rev. Proc. 2007-64, the Service has modified the scope provision set forth in Rev. Proc. 2006-45 for corporations that exit a consolidated group and request consent to change their annual accounting periods. Rev. Proc. 2007-64 also modifies the terms and conditions relating to recordkeeping and book conformity for controlled foreign corporations (CFCs) that have a majority U.S. shareholder year (as defined in Sec. 898(c)(3)) and change to a one-month deferral year under Sec. 898(c)(2) or a 52- or 53-week tax year that references a one-month deferral year.
Corporation Exiting a Consolidated Group
Rev. Proc. 2007-64 modifies the scope of Rev. Proc. 2006-45 to clarify that any corporation leaving a consolidated group is excluded from the automatic change procedures under Rev. Proc. 2006-45 during the consolidated group's tax year (without regard to a change in the consolidated...