The IRS recently issued IRS Notice 2017-6 in connection to Tangible Property Regulations Compliance (hereinafter “TPR Compliance” or “Regulations”) that extended a specific eligibility provision for taxpayers making an automatic change of accounting method providing an opportunity to continue to take advantage of the Regulations on their 2016 tax returns.

As it should be duly recalled before IRS Notice 2017-6 was issued, the requirements set forth under Rev. Proc. 2015-13 prevented taxpayers from making an automatic change in accounting method for the same item more than once within a five year period. Under IRS Notice 2017-6, the five year rule will not apply to changes made for the tax years beginning before January 1, 2017 thereby allowing taxpayers who are still making modifications to still be in compliance with the Regulations without requiring consent from the IRS.

For the complete scope and application of IRS Notice 2017-6, please consult https://www.irs.gov/pub/irs-drop/n-17-06.pdf

For the complete scope and application of Rev. Proc. 2015-13, please consult https://www.irs.gov/pub/irs-drop/rp-15-13.pdf


Peter J. Scalise serves as the Federal Tax Credits & Incentives Practice Leader for the Americas at Prager Metis CPAs, LLC a member of The Prager Metis International Group. Peter is a highly distinguished BIG 4 Alumni Tax Practice Leader and has over twenty years of progressive CPA Firm experience developing, managing and leading multi-million dollar tax advisory practices on a regional, national, and global level. Peter serves on both the Board of Directors and Board of Editors for The American Society of Tax Professionals (ASTP). Peter is the Founding President and Chairman of both The Northeastern Region Tax Roundtable and The Washington National Tax Roundtable, operating divisions of ASTP.

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