Rev. Proc. 2016-29: Automatic change procedures update

Rev. Proc. 2016-29: Automatic change procedures update

The IRS today released an advance version of Rev. Proc. 2016-29 that aggregates and adds to the prior list of automatic changes to which the automatic exchange procedures of Rev. Proc. 2015-13—as clarified and modified by Rev. Proc. 2015-33 and modified by Rev. Proc. 2016-1—apply.

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Rev. Proc. 2016-29 [PDF 1 MB] provides 343 pages of automatic changes and includes a section of “significant changes” to the list of automatic changes in Rev. Proc. 2015-14. 

“Significant changes”

The “significant changes” section of Rev. Proc. 2016-29 lists, among other items, changes:

  • Relating to impermissible to permissible methods of depreciation or amortization (modified to provide that a taxpayer cannot make a change under this section for any property for which the taxpayer has claimed a federal income tax credit)  
  • Relating to late partial disposition elections under section 168, and relating to partial dispositions of tangible depreciable assets to which the IRS’s adjustment pertains (modified to remove all references to Prop. Reg. section 1.168(i)-8 because it is obsolete) 
  • Relating to the revocation of a partial disposition election under the remodel-refresh safe harbor described in Rev. Proc. 2015-56 (modified to provide that such revocation must be made, and the eligibility rules in Rev. Proc. 2015-13 do not apply, for any tax year beginning after December 31, 2013, and ending before December 31, 2016)
  • Relating to changes for tangible property (modified to provide that this section does not apply to amounts paid or incurred for repair and maintenance costs that the taxpayer is changing from capitalizing to deducting and for which the taxpayer has claimed a federal income tax credit or elected to apply section 168(k)(4))
  • Relating to the remodel-refresh safe harbor described in Rev. Proc. 2015-56 (modified to provide that the eligibility rules of Rev. Proc. 2015-13 do not apply for any tax year beginning after December 31, 2013, and ending before December 31, 2016)
  • Relating to changes to comply with the requirements of section 267 (modified to provide that the eligibility rules in Rev. Proc. 2015-13 do not apply to changes to comply with section 267(a)(3)) 
  • Relating to changes for long-term contracts to the percentage-of-completion method described in Reg. section 1.460-4(b) (removed from the revenue procedure in its entirety) 
  • Relating to impermissible methods of identification and valuation of inventory (amplified and modified to provide that a taxpayer can make a change under this section if the taxpayer is changing from an impermissible method of accounting under section 471) 

 

The following sections are added to the list of automatic changes in this revenue procedure to provide additional changes in method of accounting to be made under the automatic change procedures: 

  • Relating to changes for start-up expenditures under section 195 
  • Relating to changes for interest capitalization under section 263A 
  • Relating to certain changes within the retail inventory method under section 471

 

Also, the waiver of the eligibility rule in Rev. Proc. 2015-13 is extended one year to any tax year beginning before January 1, 2016, for the following items:

  • Relating to depreciation of leasehold improvements under Reg. section 1.167(a)-4 
  • Relating to a change from a permissible to another permissible method of accounting for depreciation of MACRS property under Reg. sections 1.168(i)-1, 1.168(i)-7, and 1.168(i)-8 
  • Relating to dispositions of a building or structural component under Reg. section 1.168(i)-8 
  • Relating to dispositions of tangible depreciable assets (other than a building or its structural components) under Reg. section 1.168(i)-8 
  • Relating to dispositions of tangible depreciable assets in a general asset account under Reg. section 1.168(i)-1 
  • Relating to changes for tangible property under the final tangible property regulations

Today’s revenue procedures substantially supersedes Rev. Proc. 2015-14.

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