The preamble to the proposed procedure states that the IRS intends to publish guidance permitting the IRS and taxpayers to resolve accounting method
issues for taxable years beyond the years under examination, before Appeals, or before a federal court.
The Company indicated that a change in inventory accounting method
would require a restatement of prior periods and would be expected to have a material impact on its historical financial statements, but no impact on cash flows.
shareholders who own directly or indirectly, in the aggregate, more than 50% of the total combined voting power of all classes of CFC stock who are entitled to vote and undertake to act on its behalf--may make an election, or adopt or change an accounting method
, on behalf of the CFC (without regard to any other different methods or elections previously used to prepare its books and financial statements).
Other taxpayers--otherwise eligible to use the cash method--may have elected to use the accrual method in a previous period and may want to change their overall accounting methods
to the cash method.
Moreover, the new procedure adopts a novel and, to our mind's eye, unwarranted expansion of the definition of what constitutes a change in accounting method
2008-52 also allows taxpayers to file an automatic accounting method
change request as early as the first day of the year of change.
The new procedure is generally effective for Forms 3115, Application for Change in Accounting Method
, filed on or after May 15, 1997.
381(c)(5)) and adjustments for accounting method
changes (under Sec.
Concededly, where an accounting method
falls within one of the enumerated categories of "A," "B," "Designated A," "Designated B," or LIFO methods, the procedure provides clear guidelines for securing consent of the Commissioner.
First quarter fiscal year 1994 net income and earnings per share, before the cumulative effect of change in accounting method
associated with the adoption of Financial Accounting Standard 109 (SFAS 109 "Accounting for Income Taxes"), was $690,000 and 14 cents per share respectively, compared to a net loss of $433,000 and loss per share of 9 cents for the first quarter of fiscal year 1993.
The Company will be revising its accounting method
to use variable accounting for the expensing of stock options.
With the passing of April 15, many practitioners will shift their attention to taxpayers under extension, some of which may have advance consent accounting method
Third, section 481 and the applicable revenue procedures generally allow a taxpayer several years to take into the income the effect of an unfavorable change in accounting method
Although this change in accounting method
will defer recognition of distributor and reseller revenues compared to the previous accounting method
, management believes the sell-through method will more conservatively reflect Riverstone's revenues on an ongoing basis.
The IRS has ruled in technical advice (TAM 200738014) that a service provider's request for a change in accounting method
for mixed service costs does not qualify for audit protection because the service provider received written notification, citing the treatment of mixed service costs as an issue under consideration.