Coddington wrote:The big firms appear to be taking the approach that everyone needs to file a Form 3115 to identify their Units of Property, even if it leads to no changes. That's not an unreasonable approach when a taxpayer may have hundreds or thousands of locations. But if a taxpayer has never had a chance to define its UoP due to the lack of repair/improvement activities in the past, it is theoretically possible to adopt the new regulations prospectively without filing a Form 3115.
Coming from the tax accounting methods industry, the Service's apparent embrace of preventative method change applications to announce conformity seems encouraging and would permit what you suggest. However, I'm going to refrain from commenting further until I've read all of the new rev procs.
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