RP-2017-47: Safe Harbor for Inadvertent Normalization Violations

Internal Revenue Service (IRS) sent this bulletin at 09/07/2017 03:47 PM EDT

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September 7, 2017

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Revenue Procedure 2017-47 provides a safe harbor concerning inadvertent or unintentional uses of a practice or procedure that is inconsistent with §§ 50(d)(2) and 168(i)(9), which require the use of the Normalization Rules. If the safe harbor provided in this revenue procedure applies, the Internal Revenue Service will not assert that a taxpayer’s inadvertent or unintentional use of a practice or procedure that is inconsistent with §§ 50(d)(2) and 168(i)(9) constitutes a violation of the Normalization Rules. Revenue Procedure 2017-47 does not limit or change the process by which a taxpayer may request a letter ruling or a referral for a technical advice memorandum that the taxpayer’s proposed practice or procedure is consistent or inconsistent with the Normalization Rules.

Revenue Procedure 2017-47 will be in IRB 2017-38, dated 9/18/17.

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