Tax Alert – Technical Guidance Issued Regarding the Final Tangible Property Regs

Technical Guidance Issued Regarding the Final Tangible Property Regulations

TD 9659 This document contains final regulations relating to property transferred in connection with the performance of services under section 83 of the Internal Revenue Code (Code). These final regulations affect certain taxpayers who receive property transferred in connection with the performance of services.

Revenue Procedure 2014-17 modifies the procedures in Rev. Proc. 2012-20, 2012-14 I.R.B. 700, and Rev. Proc. 2011-14, 2011-4 I.R.B. 330, regarding certain changes in method of accounting for dispositions of tangible depreciable property.

This revenue procedure supersedes Rev. Proc. 2012-20 and provides the procedures by which a taxpayer may obtain the automatic consent of the Commissioner of Internal Revenue to change to the methods of accounting provided in §§ 1.167(a)-4 and 1.168(i)-7 of the Income Tax Regulations, §§ 1.167(a)-4T, 1.168(i)-1T, 1.168(i)-7T, and 1.168(i)-8T of the temporary regulations, and §§ 1.168(i)-1, 1.168(i)-7, and 1.168(i)-8 of the proposed regulations.

This revenue procedure also modifies Rev. Proc. 2011-14 and allows a late partial disposition election under Prop. Reg. § 1.168(i)-8 or a revocation of a general asset account election under § 1.168(i)-1T or Prop. Reg. § 1.168(i)-1 to be treated as a change in method of accounting for a limited period of time. Finally, this revenue procedure modifies section 6.01 of the APPENDIX of Rev. Proc. 2011-14 to waive a scope limitation in certain circumstances.

Revenue Procedure 2014-21 provides the depreciation deduction limitations for owners of passenger automobiles (including trucks and vans) first placed in service during calendar year 2014 and the amount to be included in income by lessees of passenger automobiles first leased during calendar year 2014. These depreciation deduction limitations and income inclusion amounts are updated annually pursuant to section 280F to reflect the automobile price inflation adjustments.

Revenue Procedure 2014-23 provides guidance with respect to the United States and area median gross income figures that are to be used by issuers of qualified mortgage bonds, as defined in § 143(a) of the Internal Revenue Code, and issuers of mortgage credit certificates, as defined in § 25(c), in computing the housing cost/income ratio described in § 143(f)(5).

Notice 2014-15 extends the time period announced in Notice 2012-18 through December 31, 2014.Notice 2012-18, published in the Internal Revenue Bulletin on March 5, 2012, provided State housing finance agencies that participated in the Physical Inspections Pilot Program a temporary alternative method to satisfy the physical inspection and certification review requirements of § 1.42-5(c)(2) of the Income Tax Regulations. The availability of this alternative method ended on December 31, 2012.

[hr] **The purpose of this news alert is for informational and discussion purposes only and is not intended to be used as tax advice.

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