The IRS issued Revenue Procedure 2014-54 yesterday, which addresses certain changes in method of accounting for dispositions of tangible property. The guidance provides the procedures by which a taxpayer may obtain the automatic consent of the IRS to change to the methods of accounting provided in Treas. Reg. §§1.168(i)-1, which provides rules for general asset accounts; 1.168(i)-7, which provides rules for depreciation of MACRS property; and 1.168(i)-8, which provides rules for dispositions of MACRS property. Additionally, the revenue procedure allows a late partial disposition election under Treas. Reg. §1.168(i)-8 to be treated as a change in method of accounting for a limited period of time.
Revenue Procedure 2014-54 will be published in IRB 2014-41 on October 6. The revenue procedure complies with the final rules issued in T.D. 9689 on Aug. 14.