The IRS today released an advance version of Notice 2017-06 that extends the waiver of the eligibility rule for making certain automatic changes in accounting methods.
According to Notice 2017-06 [PDF 81 KB], the IRS and Treasury Department are aware that taxpayers continue to request consent to change their methods of accounting to use the final tangible property regulations and final depreciation and disposition regulations. Today’s notice is being issued:
“…to ease taxpayers’ transition to these final regulations and to reduce the administrative burden that would result from requiring taxpayers to apply for non-automatic changes of accounting method for each of the changes…this notice modifies the applicable sections of Rev. Proc. 2016-29 to extend the waiver of the eligibility rule …of Rev. Proc. 2015-13 for one year to any taxable year beginning before January 1, 2017.”
The IRS notice lists the applicable sections of Rev. Proc. 2016-29.
Notice 2017-06 provides a transition rule. Under this rule, if before December 20, 2016, a taxpayer properly filed a Form 3115 under the non-automatic change procedures in Rev. Proc. 2015-13 requesting the Commissioner’s consent for a change in method of accounting (described in this notice), and the Form 3115 is pending with the national office on December 20, 2016, the taxpayer may choose to make the change of accounting method under the automatic change procedures in Rev. Proc. 2015-13 by following certain requirements and procedures of Rev. Proc. 2016-29 with the following modifications:
© 2017 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved.
The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.