The Service Issues New Administrative Authority Governing TPR Compliance

Pete Scalise

The Internal Revenue Service (hereinafter the “Service”) 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 Service.

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.

About the Author
Peter J. Scalise serves as the National Partner-in-Charge of the Federal Tax Credits and Incentives Practice at SAX CPAs LLP. Peter is a highly distinguished member of the Accounting Today Top 100 Influencers and has approximately thirty years of progressive Big 4 and Top 100 public accounting firm experience developing, managing, and leading large scale tax advisory practices on a regional, national, and global level.
Peter also serves as a passionate philanthropist and a member of several Boards of Directors and Boards of Advisors for local, regional, and national charities in connection with poverty and hunger alleviation; economic development; environmental conservation; health and social services; supporting veteran and military service personnel along with preserving arts and cultural programs.

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