(Archived Content)
JS-2142
The Treasury Department and IRS today issued a revenue procedure that sets forth the exclusive administrative procedures that taxpayers must use to obtain automatic consent to change their method of accounting for the second taxable year ending on or after December 31, 2003, under the final regulations on capitalizing costs incurred in acquiring or creating intangible assets.
The procedures issued today generally are consistent with Rev. Proc. 2004-23, which provided for automatic changes in method of accounting for a taxpayer's first taxable year ending on or after December 31, 2003. As required in Rev. Proc. 2004-23, taxpayers that changed to a method of accounting provided in the final regulations without the consent of the Commissioner are not eligible to use the procedures issued today unless they amend their prior federal income tax returns to correct their unauthorized change in method of accounting. However, although Rev. Proc. 2004-23 waived certain limitations that may prevent taxpayers from qualifying to automatically change a method of accounting, the procedures issued today do not contain such a waiver.
The Service intends to issue future guidance for changes in methods of accounting made for subsequent taxable years, including automatic consent procedures for some or all of the methods of accounting provided in the final regulations.
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