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TREAS/IRS RIN: 1545-AQ55 Publication ID: Fall 2008 
Title: Use of General Accepted Accounting Priniciple (GAAP) Earnings as Earnings and Profits (E&P) of Foreign Corporations 
Abstract: The regulations are part of Treasury's ongoing simplification efforts. The regulations would modify the computation of earnings and profits (E&P) of foreign corporations by allowing taxpayers to account for inventory costs, using capitalization methods used for financial accounting purposes rather than the uniform capitalization rules required by section 263A. The regulations would also permit reliance on financial accounting conventions in computing depreciation for foreign corporations deriving less than 20 percent of gross income from U.S. sources and maintaining assets with tax bases not materially different from financial book bases. Use of these simplified rules may result in an accounting method change, which would ordinarily require the filing of Form 3115 (Application for Change in Accounting Method). However, the regulations waive this filing requirement if its conditions are met. 
Agency: Department of the Treasury(TREAS)  Priority: Substantive, Nonsignificant 
RIN Status: Previously published in the Unified Agenda Agenda Stage of Rulemaking: Long-Term Actions 
Major: No  Unfunded Mandates: No 
CFR Citation: 26 CFR 1   
Legal Authority: 26 USC 7805    26 USC 964    26 USC 952   
Legal Deadline:  None
Timetable:
Action Date FR Cite
NPRM  07/01/1992  57 FR 29246   
Next Action Undetermined  To Be Determined    
Additional Information: REG-209545-92 (INTL-0018-92) Drafting attorney: Jeffrey L. Parry (202) 622-3850 Reviewing attorney: Barbara A. Felker (202) 622-3850 CC: INTL
Regulatory Flexibility Analysis Required: No  Government Levels Affected: None 
Small Entities Affected: No  Federalism: No 
Included in the Regulatory Plan: No 
RIN Data Printed in the FR: No 
Agency Contact:
Jeffrey L. Parry
Senior Counsel
Department of the Treasury
Internal Revenue Service
1111 Constitution Avenue NW., Room 4555,
Washington, DC 20224
Phone:202 317-6936
Fax:202 317-4922
Email: jeffrey.l.parry@irscounsel.treas.gov