IRS Provides List of Accounting Method Changes to Which Automatic Change Procedures Apply (article)

IRS Provides List of Accounting Method Changes to Which Automatic Change Procedures Apply (article)

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The IRS has released guidance listing the specific changes in accounting method to which the automatic change procedures set forth in Rev. Proc. 2015-13, I.R.B. 2015-5, 419, apply. The latest guidance updates and supersedes the current list of automatic changes found in Rev. Proc. 2016-29, I.R.B. 2016-21, 880.

Significant changes to the list of automatic changes in Rev. Proc. 2016-29 include:

  1. Removing expired waivers to the eligibility rules (formerly referred to as "scope limitations" ) for various types of automatic method changes;
  2. Removing automatic accounting method changes (or portions thereof) that are now obsolete;
  3. Section 10.01, relating to start-up expenditures under Code Sec. 195, is modified to allow an automatic change to an amortization period of 180 months;
  4. New Section 10.02 is added to allow a corporation to change under Code Sec. 248 (a) the characterization of an item as an organizational expenditure; (b) the determination of the taxable year in which the corporation begins business to which the organizational expenditures relate; or (c) the amortization period of an organizational expenditure to 180 months;
  5. New Section 10.03 allows a partnership to make the similar changes under Code Sec. 709;
  6. Section 11.08 is modified to provide that a taxpayer may not make a change to comply with the tangible property (repair regulations) using the automatic procedure if the taxpayer is changing from capitalizing to deducting repair and maintenance costs and the taxpayer also received a section 1603 grant for energy property in lieu of tax credits in connection with the costs.
  7. Section 12.14, relating to capitalization of interest under the Code Sec. 263A uniform capitalization rules is modified include changes from an improper method of capitalizing interest to a property method;
  8. Section 20.02(1)(b)(ii), relating to a change by a party to a Code Sec. 467 rental agreement from an improper method of inclusion of rent income or expense, is clarified to provide that the automatic change does not apply to a rental agreement that provides a specific allocation of fixed rent that allocates rent to periods other than when the rents are payable;
  9. Section 21.05, relating to impermissible methods of identification and valuation of inventory, is modified to clarify various situations in which the taxpayer may or may not use the automatic change procedure;
  10. Section 21.11, relating to changes from one permissible method of identification and valuation of inventory to another permissible method, is clarified to provide that this automatic change does not apply to allocate costs to inventory under Code Sec. 471 or Code Sec. 263A;
  11. Section 23.01, relating to certain taxpayers that elected to use the mark-to-market method of accounting under Code Sec. 475 for securities or commodities, is modified to waive certain eligibility rules;
  12. Section 23.02, relating to changes made from the mark-to-market method to a realization method, is modified to clarify that this automatic change is not limited to a change required by Code Sec. 475;
  13. Section 25.03, relating to change in qualification as a life/nonlife insurance company, is modified to clarify that the automatic change applies to an insurance company that changed from being treated as a life insurance company under part I of subchapter L to being treated as a nonlife insurance company under Part II of subchapter L, or vice versa;
  14. Section 30,01, relating to the revocation of a Code Sec. 1278(b) election, is modified to include an additional situation in which a taxpayer is treated as having made a deemed election;
  15. New Section 21.18 allows a taxpayer currently deducting inventories to change to a permissible method of identifying and valuing inventories. For example, a taxpayer currently deducting inventories may change to using the first-in, first-out (FIFO) method as its inventory-identification method and cost or market, whichever is lower (LCM), as its inventory-valuation method.

Subject to a transition rule, this revenue procedure is effective for a Form 3115 filed on or after April 19, 2017, for a year of change ending on or after Aug. 31, 2016, that is filed under the automatic change procedures.

Rev. Proc. 2017-30 amplifies and modifies Rev. Proc. 2016-29, I.R.B. 2016-21, 880, as modified by Notice 2016-36, I.R.B. 2016-25, 1029, Rev. Proc. 2016-39, I.R.B. 2016-30, 164, and Notice 2017-6, I.R.B. 2017-3, 422. Rev. Proc. 2016-29, as amplified and modified is superseded in part. Rev. Proc. 2017-30 also modifies Rev. Proc. 2011-46, I.R.B. 2011-42, 518; Rev. Rul. 2004-62, 2004-1 CB 1072; Rev. Rul. 2000-7, 2000-9 CB 712; Rev. Rul. 2000-4, 2000-1 CB 331; and Rev. Proc. 2007-48, 2007-2 CB 110.


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IRS Provides List of Accounting Method Changes to Which Automatic Change Procedures Apply (article)When adopting new accounting standards, entities will often need to file for a change in accounting method. The IRS recently clarified upcoming changes for which the automatic change procedures will apply....2017-04-24T18:43:00-05:00When adopting new accounting standards, entities will often need to file for a change in accounting method. The IRS recently clarified upcoming changes for which the automatic change procedures will apply.