The IRS today posted a Large Business & International (LB&I) directive as guidance for IRS examiners to follow concerning examinations of taxpayers using the safe harbor methods of accounting for cable network assets, as described in Rev. Proc. 2015-12. LB&I-04-0415-003 (April 16, 2015)
Read the LB&I directive.
There are two alternative safe harbor approaches provided by Rev. Proc. 2015-12 for purposes of determining:
The LB&I directive instructs IRS examiners to discontinue examining tax years ending before January 1, 2014, that involve the following issues:
For tax years ending after December 31, 2013, the LB&I directive instructs examiners to permit taxpayers to change their method of accounting for the first year ending after December 31, 2013. If a taxpayer has not changed its method of accounting to comply with either the safe harbor or the final tangible property regulations, the directive instructs examiners to perform a risk assessment.
Lastly, the LB&I directive provides instruction to examiners regarding the placed-in-service date of a node and fiber optic cable for depreciation purposes and whether cable distribution network assets are primarily used for providing one way or two way communication services for depreciation purposes.
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