While there are multiple elections available throughout the code that provide for various strategies and planning opportunity, the elections of §884 allow a taxpayer enough opportunities in which planning can provide some substantial benefits and make the requirements simpler and easier on the taxpayer.
The election presented in §1.884-4(c)(1) allows a taxpayer to use the accrual method when determining if interest was paid or not during a tax year. This can provide some deferral benefits for a taxpayer, as well as making the tracking and administration of the system easier for an accrual taxpayer. No longer does a taxpayer have to keep track of how interest is paid and how it is accrued.
The election presented in §1.884-1(e)(3) provides a planning opportunity for a taxpayer that has additional assets that are not connected to the trade or business of its branch. However, one has to have assets that are not connected for this election to be effective. Otherwise, the same the taxpayer will find itself in the same place as Taiyo, and have made the election with no effect. In that case the results are the same regardless of the election.
With proper planning and application, the elections presented can prove to be useful and convenient. However, as with most elections, without the proper planning and guidance, the pitfalls of the requirements can make the election useless at best, or malignant in the worst.