Instructions for Form 3115›(Rev. December 2022)
! becomes obsolete or is superseded, then a change can
1222 Inst 3115 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
CAUTION no longer be made under such DCN.
List of DCNs
| No. | Change |
|---|---|
| 1 | Commodity Credit Corporation loans (section 77)—for loans received from the Commodity Credit Corporation,from including the loan amount in gross income for the tax year in which the loan is receivedto treating the loan amount as a loan. See section 2.01 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 2 | Advances made by a lawyer on behalf of clients (section 162)—from treating advances of money to or on behalf of their clients for litigation or other client expenses as deductible expenses** to** treating those advances as a loan. See section 3.01 of Rev. Proc. 2022-14. |
| 3 | ISO 9000 costs (section 162)—to treating the costs as deductible, except to the extent they result in the creation or acquisition of an asset having a useful life substantially beyond the tax year. See section 3.02 of Rev. Proc. 2022-14. |
| 4 | Restaurant smallwares costs (section 162)—to the smallwares method described in Rev. Proc. 2002-12, 2002-1 C.B. 374 (that is, as materials and supplies that are not incidental under Regulations section 1.162-3). See section 3.03 of Rev. Proc. 2022-14. |
| 5 | Bad debts (section 166)—for an applicant other than a bank,from accounting for bad debts using a reserve or other improper methodto a specific charge-off method that complies with section 166. See section 4.01 of Rev. Proc. 2022-14. |
| 6 | Bad debt conformity for banks (section 166)—for banks other than new banks,to the method that conforms to Regulations section 1.166-2(d)(3) for the first time the bank makes this change, orto involuntarily revoke this method. This change does not fall under the procedures of Rev. Proc. 2022-14. Instead, see Regulations section 1.166-2(d)(3).Note. This change is implemented on a cut-off basis and generally with audit protection, but with some conditions or limitations. |
| 7 | Depreciation or amortization (impermissible to permissible) (sections 56, 167, 168, 197, 280F, or former sections 168, 1400I, 1400L, or 1400N)—from an impermissible methodto a permissible method for changes allowed under Regulations section 1.446-1(e)(2)(ii)(d), and for depreciable property owned at the beginning of the year of change. Complete Schedule E of Form 3115. An applicant changing its method of accounting for depreciation because of a change described in DCN 10 (sale or lease transactions) must file Form 3115 according to the DCN 10. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.01 of Rev. Proc. 2022-14. |
| 8 | Depreciation (permissible to permissible) (sections 56 and 167)—from a permissible methodto another permissible method listed in section 6.02 of Rev. Proc. 2022-14. Complete Schedule E of Form 3115. Change is implemented on a modified cut-off basis. An applicant making a change from a permissible to another permissible method of depreciating MACRS property must file Form 3115 according to DCN 200. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.02 of Rev. Proc. 2022-14. |
| 10 | Sale, lease, or financing transactions (sections 61, 162, 167, 168, and 1012)—from improperly treating property as sold, leased, or financedto a permissible method as described in section 6.03 of Rev. Proc. 2022-14. See section 6.03 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 11 | Obsolete. See DCN 7. |
| 12 | Obsolete.See DCN 7. |
| 13 | Obsolete. See DCN 7. |
| 14 | Obsolete.See DCN 7. |
| 15 | Obsolete.See DCN 210. |
| 16 | Amortizable bond premium (section 171)—from amortizing bond premiumto not amortizing the premium (revoking the section 171(c) election). See section 5.01 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis and is also generally made with audit protection, but with conditions or limitations. |
| 17 | Research and experimental expenditures (section 174)—from the capitalization methodto another permissible method, from the expense methodto another permissible method,from the deferred expense methodto another permissible method, from the current period of amortizationto a different period of amortization under the deferred expense method, orfrom treating research and experimental expenditures under any provision of the Internal Revenue Code other than section 174to treating such expenditures under section 174. See section 7.01 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis and does not receive audit protection.Note. This change does not apply to costs of developing computer software that are paid or incurred in tax years beginning after December 31, 2021. To make a change for such costs, see DCN 265. |
| 18 | Computer software expenditures (sections 162 and 167)—for costs of developed, acquired, leased, or licensed computer software,to deductible expenses or capital expenditures and amortization (for developed software),to capital expenditures and depreciation or amortization (for acquired computer software), orto deductible expenses under Regulations section 1.162-11 (for leased or licensed computer software). Complete Schedule E of Form 3115 for changes relating to acquired computer software or developed computer software if the change is to capital expenditures and amortization. See section 9.01 of Rev. Proc. 2022-14.Note.This change does not apply to costs of developing computer software that are paid or incurred in tax years beginning after December 31, 2021. To make a change for such costs, see DCN 265. |
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List of DCNs
| No. | Change |
|---|---|
| 19 | Package design costs (section 263)—to the capitalization method,to the design-by-design capitalization and 60-month amortization method, orto the pool-of-cost capitalization and 48-month amortization method. See section 11.01 of Rev. Proc. 2022-14. |
| 20 | Line pack gas or cushion gas costs (section 263)—to treating the costs as capital expenditures, the costs of recoverable amounts as not depreciable, and the costs of unrecoverable amounts as depreciable. A taxpayer that changes its method for the costs of unrecoverable amounts must also change to a permissible method of depreciation for those costs. Complete Schedule E of Form 3115 for changes relating to the costs of unrecoverable amounts. See section 11.02 of Rev. Proc. 2022-14. |
| 21 | Removal costs (section 263)—for certain costs incurred in the retirement and removal of depreciable assets,to a method that conforms with Rev. Rul. 2000-7, 2000-1 C.B. 712, or for removal costs in disposal of a depreciable asset, including a partial disposition, as described under Regulations section 1.263(a)-3(g)(2)(i). Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.03 of Rev. Proc. 2022-14. |
| 22 | Certain uniform capitalization methods used by resellers and reseller-producers (section 263A)—for qualifying applicants,to a qualifying method or methods. Complete Schedule D, Parts II and III, of Form 3115. See section 12.01 of Rev. Proc. 2022-14. |
| 23 | Certain uniform capitalization methods used by producers and reseller-producers (section 263A)—for qualifying applicants,to a qualifying method or methods. Complete Schedule D, Parts II and III, of Form 3115. See section 12.02 of Rev. Proc. 2022-14. |
| 24 | Obsolete.See DCN 17. |
| 25 | Impact fees (section 263A)—for impact fees incurred in connection with the new construction or expansion of a residential building,to treating the costs as capital expenditures allocable to the building. Complete Schedule E of Form 3115 if the building is depreciable. See section 12.03 of Rev. Proc. 2022-14. |
| 26 | Related party transactions (section 267)—for losses, expenses, and qualified stated interest incurred in transactions between related parties,to treating certain deductions attributable to such transactions in accordance with section 267, including the exception in section 1.267(a)-3(c)(4). See section 13.01 of Rev. Proc. 2022-14. |
| 27 | Obsolete. |
| 28 | Bonus or vacation pay deferred compensation (section 404)—for bonuses that are deferred compensation,from treating as deductible or capitalizable when accrued,to treating as deductible or capitalizable in the year in which includible in the employee’s income, and for vacation pay that is deferred compensation,from treating as deductible or capitalizable when accruedto treating as deductible or capitalizable in the year in which paid to the employee. See section 14.01 of Rev. Proc. 2022-14. |
| 29 | Grace period contributions (section 404)—for contributions made to a section 401(k) qualified cash or deferred arrangement or matching contributions under section 401(m),from treating contributions made after the end of the tax year but before the due date of the tax return as being on account of the tax year without regard to when the underlying compensation is earnedto treating such contributions as not being on account of the tax year if they are attributable to compensation earned after the end of that tax year. See section 14.02 of Rev. Proc. 2022-14. |
| 31 | Multi-year insurance policies for multi-year service warranty contracts (section 446)—for a manufacturer, wholesaler, or retailer of motor vehicles or other durable consumer goods accounting for multi-year insurance policies for multi-year service warranty contracts,to capitalizing and amortizing the costs. See section 15.02 of Rev. Proc. 2022-14. |
| 32 | Obsolete.See DCN 233. |
| 33 | Obsolete.See DCN 233. |
| 34 | First section 448 year (section 448)—for an applicant changingfrom the cash method for its first section 448 year that makes the change using the regulation provision in lieu of Rev. Proc. 2015-13. Complete Schedule A, Part I, of Form 3115. Also, complete Schedule D, Parts II and III, as applicable, of Form 3115. This change does not fall under the procedures of Rev. Proc. 2015-13. Instead, see Regulations section 1.448-1. (See DCN 123 for taxpayers making the change under Rev. Proc. 2015-13. For applicants subject to section 447, see DCN 258).Note. This change does not apply for any tax year beginning on or after January 5, 2021. See, however, DCN 257. |
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List of DCNs
| No. | Change |
|---|---|
| 35 | Nonaccrual-experience method (section 448)—for an applicant changing:to a safe harbor method provided in Regulations section 1.448-3(f)(1) (the revenue-based moving average method), (f)(2) (the actual experience method), (f)(3) (the modified Black Motor method), (f)(4) (the modified moving average method), or (f)(5) (the alternative nonaccrual-experience method);to a periodic system;from an NAE method to a specific charge-off method;from a sub-method of its current NAE method provided in Regulations section 1.448-3 regarding applicable periods to another sub-method regarding applicable periods that is permitted under Regulations section 1.448-3, other than a change to exclude tax years from an applicable period under Regulations section 1.448-3(d)(6);from a sub-method of its current NAE method provided in Regulations section 1.448-3 regarding tracing of recoveriesto another sub-method regarding tracing of recoveries permitted under Regulations section 1.448-3(f)(2)(iii); orto the NAE book safe harbor method described in section 5.01 of Rev. Proc. 2011-46, 2011-42 I.R.B. 518. Note. An applicant using the NAE book safe harbor method that wants to make certain changes within the NAE book safe harbor method (as described in sections 5.02 and 5.03 of Rev. Proc. 2011-46) must attach a statement to its federal income tax return in lieu of filing a Form 3115. See Rev. Proc. 2011-46; section 15.03 of Rev. Proc. 2022-14; and Rev. Proc. 2006-56, 2006-2 C.B. 1169.Note. Certain changes are made on a cut-off basis. |
| 36 | Interest accrual on non-performing loans (section 451)—for an accrual method bank accounting for qualified stated interest on non-performing loans,to the method whereby interest is accrued until either the loan is worthless under section 166 and is charged off as a bad debt or the interest is determined to be uncollectible. See section 16.01 of Rev. Proc. 2022-14. |
| 37 | Advance rentals (section 451)—for advance rentals other than advance rentals subject to section 467,to inclusion in gross income in the tax year received. See section 16.02 of Rev. Proc. 2022-14. |
| 38 | State or local income or franchise tax refunds (section 451)—for an accrual method applicant with state or local income or franchise tax refunds,to accrue these items in the tax year the applicant receives payments or notice of approval of its refund claim (whichever is earlier), according to Rev. Rul. 2003-3, 2003-1 C.B. 252. See section 16.03 of Rev. Proc. 2022-14. |
| 39 | Capital cost reduction (CCR) payments (section 451)—for CCR payments (as defined in Rev. Proc. 2002-36, 2002-1 C.B. 993) made by vehicle lessees,to the method that excludes these payments from the applicant’s gross income and from the applicant’s bases in the purchased vehicles. See section 16.04 of Rev. Proc. 2022-14. |
| 41 | Obsolete. |
| 42 | Timing of incurring employee medical benefits liabilities (section 461)—for an applicant with an obligation to pay an employee’s medical expenses (including medical expenses for retirees and employees who filed claims under a workers’ compensation act) that is neither insured nor paid from a welfare benefit fund,to treatment as a liability incurred in the tax year in which the applicant’s employee files the claim with the applicant; or, if the applicant has a liability to pay a third party for medical services to its employees,to treatment as a liability as incurred in the tax year in which the services are provided. See section 20.01(1) of Rev. Proc. 2022-14. |
| 43 | Timing of incurring real property taxes, personal property taxes, state income taxes, and state franchise taxes (section 461)—for a qualifying applicant,to treating these taxes as incurred in the tax year in which the taxes are paid, orto account for these taxes under the recurring item exception to the economic performance rules, orto revoke the ratable accrual election under section 461(c). See section 20.02 of Rev. Proc. 2022-14. |
| 44 | Timing of incurring workers’ compensation act, tort, breach of contract, or violation of law liabilities (section 461)— for a qualifying applicant accounting for self-insured liabilities arising under any workers’ compensation act or out of any tort, breach of contract, or violation of law,to treating the liability as incurred in the tax year in which (a) all the events have occurred establishing the fact of the liability, (b) the amount of the liability can be determined with reasonable accuracy, and (c) payment is made to the person to which the liability is owed. See section 20.03 of Rev. Proc. 2022-14. |
| 45 | Timing of incurring certain payroll tax liabilities (section 461)—for FICA and FUTA taxes, state unemployment taxes, and railroad retirement taxes, to the method under which the applicant may deduct in Year 1 its otherwise deductible FICA and FUTA taxes, state unemployment taxes, and railroad retirement taxes imposed with respect to year-end wages properly accrued in Year 1, but paid in Year 2, if the requirements of the recurring item exception are met; or, for state unemployment taxes and railroad retirement taxes,to the method stated above where the applicant already uses that method of accounting for FICA and FUTA taxes. See section 20.04 of Rev. Proc. 2022-14. |
| 46 | Cooperative advertising (section 461)—to incurring a liability in the tax year in which these services are performed, provided the manufacturer is able to reasonably estimate this liability even though the retailer does not submit the required claim form until the following year. See section 20.05 of Rev. Proc. 2022-14. |
List of DCNs
| 47 | Distributor commissions (section 263)—from deducting distributor commissionsto capitalizing and amortizing distributor commissions using the distribution fee period method, the 5-year method, or the useful life method. This change is implemented on a cut-off basis and applies only to distributor commissions paid or incurred on or after the beginning of the year of change. See section 11.04 of Rev. Proc. 2022-14. Complete Schedule E of Form 3115. |
|---|
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List of DCNs
| No. | Change |
|---|---|
| 48 | Cash discounts (section 471)—for cash discounts granted for timely payment, when such discounts approximate a fair interest rate,from a method of consistently including the price of the goods before discount in the cost of the goods and including in gross income any discounts takento a method of reducing the cost of the goods by the cash discounts and deducting as an expense any discounts not taken, or vice versa. Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.01 of Rev. Proc. 2022-14. |
| 49 | Estimating inventory shrinkage (section 471)—from the present method of estimating inventory shrinkage in computing ending inventoryto the retail safe harbor method in section 4 of Rev. Proc. 98-29, 1998-1 C.B. 857, orto a method other than the retail safe harbor method, provided (a) the applicant’s present method of accounting does not estimate inventory shrinkage, and (b) the applicant’s new method of accounting (that estimates inventory shrinkage) clearly reflects income under section 446(b). Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.02 of Rev. Proc. 2022-14. |
| 50 | Obsolete. See DCN 235. |
| 51 | Obsolete. See DCN 235. |
| 53 | Qualifying volume-related trade discounts (section 471)—to treating qualifying volume-related trade discounts as a reduction in the cost of merchandise purchased at the time the discount is recognized in accordance with Regulations section 1.471-3(b). Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.03 of Rev. Proc. 2022-14. |
| 54 | Impermissible methods of identification and valuation of inventories (section 471)—for an applicant changingfrom an impermissible method of identifying or valuing inventoriesto a permissible method of identifying or valuing inventories. Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.04 of Rev. Proc. 2022-14. |
| 55 | Core alternative valuation method for remanufactured and rebuilt motor vehicle parts (section 471)—for remanufactures and rebuilders of motor vehicle parts and resellers of remanufactured and rebuilt motor vehicle parts that use the lower of cost or market method to value their inventory of cores,to the safe harbor method of accounting (the Core alternative valuation method) to value inventories of cores, as provided for in Rev. Proc. 2003-20, 2003-1 C.B. 445. Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.05 of Rev. Proc. 2022-14. |
| 56 | Change from LIFO inventory method (section 472)—for an applicant changing from the LIFO inventory method for its entire LIFO inventory, or for one or more dollar-value pools within its LIFO inventory,to the permitted method as described in section 23.01(1)(b) of Rev. Proc. 2022-14. Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 23.01 of Rev. Proc. 2022-14. |
| 57 | Determining current-year cost under the LIFO inventory method (section 472)—for an applicant changing its method of determining current-year costto(a) the actual cost of the goods most recently purchased or produced (most-recent acquisitions method); (b) the actual cost of the goods purchased or produced during the tax year in the order of acquisition (earliest-acquisitions method); (c) the average unit cost equal to the aggregate actual cost of all the goods purchased or produced throughout the tax year divided by the total number of units so purchased or produced; (d) the specific identification method; or (e) a rolling-average method if the applicant uses that rolling-average method in accordance with Rev. Proc. 2008-43, 2008-30 I.R.B. 186, as modified by Rev. Proc. 2008-52, 2008-2 C.B. 587. Complete Schedule C, Part I, of Form 3115. See section 23.02 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 58 | Alternative LIFO inventory method (section 472)—for a qualifying applicant that sells new automobiles or new light-duty trucks,to the Alternative LIFO Method described in Rev. Proc. 97-36, 1997-2 C.B. 450, as modified by Rev. Proc. 2008-23, 2008-1 C.B. 664. Complete Schedule C of Form 3115, as applicable. See section 23.03 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
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List of DCNs
| No. | Change |
|---|---|
| 59 | Used Vehicle Alternative LIFO Method (section 472)—for a qualifying applicant that sells used automobiles and used light-duty trucks,to the Used Vehicle Alternative LIFO Method, as described in Rev. Proc. 2001-23, 2001-1 C.B. 784, as modified by Announcement 2004-16, 2004-1 C.B. 668, and Rev. Proc. 2008-23, 2008-1 C.B. 664. Complete Schedule C, Part I, of Form 3115. See section 23.04 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 60 | Determining the cost of used vehicles purchased or taken as a trade-in (section 472)—for a qualifying applicant,to a method of (a) determining the cost of used vehicles acquired by trade-in using the average wholesale price listed by a consistently used official used car guide on the date of the trade-in; (b) using a different official used vehicle guide for determining the cost of used vehicles acquired by trade-in; (c) determining the cost of used vehicles purchased for cash using the actual purchase price of the vehicle; or (d) reconstructing the beginning-of-the-year cost of used vehicles purchased for cash using values computed by national auto auction companies based on vehicles purchased for cash, where the national auto auction company selected is consistently used. Complete Schedule C, Part I, of Form 3115. See section 23.05 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 61 | Change to IPIC inventory method (section 472)—for a qualifying applicant,from a non-inventory price index computation (IPIC) LIFO inventory methodto the IPIC method in accordance with all relevant provisions of Regulations section 1.472-8(e) (3); orfrom the IPIC method as described in T.D. 7814, 1982-1 C.B. 84 (the old IPIC method)to the IPIC method as described in T.D. 8976, 2002-1 C.B. 421 (the new IPIC method), which includes the following required changes (if applicable):from using 80% of the inventory price index (IPI)to using 100% of the IPI to determine the base-year cost and dollar-value of a LIFO pool(s);from using a weighted arithmetic meanto using a weighted harmonic mean to compute an IPI for a dollar-value pool(s); andfrom using a components-of-cost method to define inventory itemsto using a total-product-cost method to define inventory items. Complete Schedule C of Form 3115, as applicable. See section 23.06 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 62 | Changes within IPIC inventory method (section 472)—for one or more of the following changes within IPIC: (a)from the double-extension IPIC methodto the link-chain IPIC method, or vice versa; (b)to orfrom the 10% method; (c)to a pooling method described in Regulations section 1.472-8(b)(4) or Regulations section 1.472-8(c)(2), including a change to begin or discontinue applying one or both of the 5% pooling rules; (d) combine or separate pools as a result of the application of a 5% pooling rule described in Regulations section 1.472-8(b)(4) or Regulations section 1.472-8(c)(2); (e) change the selection of BLS tablesfrom Table 3 (Consumer Price Index for All Urban Consumers (CPI-U): U.S. city average, detailed expenditure categories) of the monthly CPI Detailed Reportto Table 9 (Producer price indexes and percent changes for commodity groupings and individual items, not seasonally adjusted) of the monthly PPI Detailed Report, or vice versa; (f) change the assignment of one or more inventory items to BLS categories under either Table 3 of the monthly CPI Detailed Report or Table 9 of the monthly PPI Detailed Report; (g) change the representative month when necessitated because of a change in tax year or a change in method of determining current-year cost made pursuant to section 23.02 of Rev. Proc. 2022-14; or (h) change from using preliminary BLS price indexes to using final BLS price indexes to compute an inventory price index, or vice versa. Complete Schedule C of Form 3115, as applicable. See section 23.07 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 63 | Replacement cost method for automobile dealers’ parts inventory (sections 471 and 472)—to the replacement cost method for automobile dealers’ parts inventory described in Rev. Proc. 2002-17, 2002-1 C.B. 676. Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.06 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 64 | Mark-to-market (section 475)—for accounting for securities or commodities by electing commodities dealers, securities traders, and commodities traders,to the mark-to-market method under section 475(e) or (f). An election statement must be filed earlier than the due date of Form 3115. See Rev. Proc. 99-17, 1999-1 C.B. 503, for rules relating to this statement. See section 24.01 of Rev. Proc. 2022-14. In general, for an electing dealer or trader, the election cannot be revoked within 5 tax years of the election year under the automatic method change described in section 24.02 of Rev. Proc. 2022-14 (DCN 218). Instead, the dealer or trader must use the non-automatic change procedures in Rev. Proc. 2015-13 to revoke the election and change to a realization method. |
| 65 | Dealer status changes (section 475)—for an applicant electing out of certain exemptions from securities dealer status,to the mark-to-market method. This change does not fall under the automatic change procedures of Rev. Proc. 2015-13. Instead, see Rev. Proc. 97-43, 1997-2 C.B. 494.Note. This change is implemented on a cut-off basis. |
List of DCNs
| 66 | Bank reserves for bad debts (section 585)—for a bank (as defined in section 581, including a bank for which a qualified subchapter S subsidiary (QSub) election is filed) to changefrom the section 585 reserve methodto the section 166 specific charge-off method. See section 25.01 of Rev. Proc. 2022-14. |
|---|---|
| 67 | Insurance company premium acquisition expenses (section 832)—for certain insurance companies,to a safe harbor method of accounting for premium acquisition expenses set forth in Rev. Proc. 2002-46, 2002-2 C.B. 105. See section 26.01 of Rev. Proc. 2022-14. |
| 68 | Discounted unpaid losses (section 846)—for insurance companies other than life insurance companies computing discounted unpaid losses,to the composite method orto alternative methods set forth in Notice 88-100, 1988-2 C.B. 439, and Rev. Proc. 2002-74, 2002-2 C.B. 980. See section 27.01 of Rev. Proc. 2022-14. |
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List of DCNs
| No. | Change |
|---|---|
| 70 | Functional currency (section 985)—to the use of another functional currency for the applicant or its qualified business unit (QBU), other than a QBU described in Regulations section 1.985-1(b)(1)(iii). See section 29.01 of Rev. Proc. 2022-14. |
| 71 | Rule of 78s (section 1272)—for stated interest on certain short-term consumer loans,from the Rule of 78s methodto the constant yield method. See section 15.04 of Rev. Proc. 2022-14. |
| 72 | Original issue discount (sections 1272 and 1273)—to the principal-reduction method for de minimis original issue discount (OID). See section 30.01 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis and does not receive audit protection. |
| 73 | Market discount bonds (section 1278)—from including market discount currently in income for the tax year to which the discount is attributableto including market discount in income for the tax year of disposition or partial principal payment (revoking the section 1278(b) election).Note. This change is implemented on a cut-off basis and is also generally made with audit protection, but with conditions or limitations. See section 31.01 of Rev. Proc. 2022-14. |
| 74 | Interest income on short-term obligations (section 1281)—to currently including accrued interest and discount in income (to comply with section 1281). See section 32.01 of Rev. Proc. 2022-14. |
| 75 | Stated interest on short-term loans (section 1281)—for a bank using the cash method of accounting,from accruing stated interest on short-term loans made in the ordinary course of businessto using the cash method to report such interest. See section 32.02 of Rev. Proc. 2022-14. |
| 76 | Sales of mortgage loans (section 1286)—for accounting for certain sales of mortgage loans in which the seller also enters into a contract to service the mortgages in consideration for amounts received from interest payments,from a method that is inconsistent with Rev. Rul. 91-46, 1991-2 C.B. 358,to a method that is consistent with Rev. Rul. 91-46. However, the change is only an automatic accounting method change for certain taxpayers who are under examination. This change does not fall under the automatic change procedures of Rev. Proc. 2015-13. Instead, see Rev. Proc. 91-51, 1991-2 C.B. 779. |
| 77 | Environmental remediation costs (section 263A)—for costs incurred to clean up land that a taxpayer contaminated with hazardous waste from the taxpayer’s manufacturing operations,to capitalizing such costs in inventory costs under section 263A. See section 12.04 of Rev. Proc. 2022-14. |
| 78 | Costs of intangibles and certain transactions (section 263(a))—for amounts paid or incurred to acquire or create intangibles, or to facilitate an acquisition of a trade or business, a change in the capital structure of a business entity, and certain other transactions,to a method of accounting provided in Regulations sections 1.263(a)-4, 1.263(a)-5, and 1.167(a)-3(b). Complete Schedule E of Form 3115 for changes to a method of accounting provided in Regulations section 1.167(a)-3(b). See section 11.05 of Rev. Proc. 2022-14. |
| 79 | REMIC inducement fees (sections 860A–860G)—for an inducement fee received in connection with becoming the holder of a noneconomic residual interest in a REMIC,to a safe harbor method provided under Regulations section 1.446-6(e)(1) or (e) (2). See Rev. Proc. 2004-30, 2004-1 C.B. 950, and section 28.01 of Rev. Proc. 2022-14. |
| 80 | All events test method for credit card annual fees (section 451)—to a method that satisfies the all events test in accordance with Rev. Rul. 2004-52, 2004-1 C.B. 973. See section 16.05 of Rev. Proc. 2022-14. |
| 81 | Ratable inclusion method for credit card annual fees (section 446)—to the ratable inclusion method for credit card annual fees. See section 16.05 of Rev. Proc. 2022-14. |
| 82 | Obsolete. |
| 83 | Full inclusion method for certain advance payments (section 451)—to the full inclusion method, as described in section 5.01 of Rev. Proc. 2004-34, 2004-1 C.B. 991. The applicant must be using, or changing to, an overall accrual method of accounting. See section 16.06 of Rev. Proc. 2022-14.Note. This change may not be made for a year of change beginning on or after January 1, 2021. See, however, DCN 254. |
| 84 | Deferral method for certain advance payments (section 451)—to the deferral method as described in section 5.02 of Rev. Proc. 2004-34, 2004-1 C.B. 991 (except as provided in section 8.03 and 8.04(2) of Rev. Proc. 2004-34). The applicant must be using, or changing to, an overall accrual method of accounting. See section 16.06 of Rev. Proc. 2022-14.Note. This change may not be made for a year of change beginning on or after January 1, 2021. See, however, DCN 254. |
| 85 | Film producer’s treatment of certain creative property costs (section 446)—to account for creative property costs under the safe harbor method provided in Rev. Proc. 2004-36, 2004-1 C.B. 1063. See section 15.05 of Rev. Proc. 2022-14. |
| 86 | Timber fertilization costs (section 162)—for costs incurred by a timber grower for the post-establishment fertilization of an established timber stand,to treat such costs as ordinary and necessary business expenses deductible under section 162. See section 3.04 of Rev. Proc. 2022-14. |
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List of DCNs
| No. | Change |
|---|---|
| 87 | Change in general asset account treatment due to a change in the use of MACRS property (section 168)—to the method of accounting provided in Regulations sections 1.168(i)-1(c)(2)(ii)(E) and 1.168(i)-1(h)(2) (as in effect before January 1, 2012) orto the method of accounting provided in Regulations section 1.168(i)-1(h)(2) to comply with the 2020 change in law to retroactively provide a 30-year recovery period under the alternative depreciation system in section 168(g) for certain residential rental property placed in service before 2018 and held by an electing real property trade or business. Complete Schedule E of Form 3115. Change is implemented on a modified cut-off basis. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See Regulations section 1.168(i)-1(l)(2)(ii) and section 6.04 of Rev. Proc. 2022-14. |
| 88 | Change in method of accounting for depreciation due to a change in the use of MACRS property (section 168)—to the method of accounting provided in Regulations section 1.168(i)-4 or to revoke the election provided in Regulations section 1.168(i)-4(d)(3)(ii) to disregard a change in use of MACRS property. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See Regulations section 1.168(i)-4(g)(2) and section 6.05 of Rev. Proc. 2022-14.Note. The applicant is required to calculate a section 481(a) adjustment as of the first day of the year of change as if the proposed method of accounting had always been used by the taxpayer beginning with the tax year in which the change in the use of the MACRS property occurred by the applicant. |
| 89 | Depreciation of qualified non-personal-use vans and light trucks (section 280F)—for certain vehicles placed in service before July 7, 2003,to a method of accounting in accordance with Regulations section 1.280F-6(f)(2)(iv). Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See Regulations section 1.280F-6(f)(2)(iv) and section 6.06 of Rev. Proc. 2022-14. |
| 90 | Insurance companies’ incentive payments to health care providers (section 446)—for deducting provider incentive payments,to the method of including those payments in discounted unpaid losses without regard to section 404. See section 15.06 of Rev. Proc. 2022-14. |
| 91 | Up-front network upgrade payments received by utilities (section 61)—to a safe harbor method provided in Rev. Proc. 2005-35, 2005-2 C.B. 76. See section 1.01 of Rev. Proc. 2022-14. |
| 92 | Allocation of environmental remediation costs to production (section 263A)—to a method that allocates under section 263A environmental remediation costs to the inventory produced during the tax year such costs are incurred. See Rev. Rul. 2005-42, 2005-2 C.B. 67, and section 12.05 of Rev. Proc. 2022-14. |
| 94 | Obsolete. |
| 96 | Replacement cost method for heavy equipment dealers’ parts inventory (sections 471 and 472)—to the replacement cost method for heavy equipment dealers’ parts inventory described in Rev. Proc. 2006-14, 2006-1 C.B. 350. Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.07 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 106 | Timing of incurring certain liabilities for services or insurance (section 461)—for an applicant that is currently treating the mere execution of a contract for services or insurance as establishing the fact of the liability under section 461 and wants to changefrom that method for liabilities for services or insurance to comply with Rev. Rul. 2007-3, 2007-1 C.B. 350. See section 20.06 of Rev. Proc. 2022-14. |
| 107 | Impermissible to permissible method of accounting for depreciation or amortization for disposed depreciable or amortizable property (sections 167, 168, or 197; or former sections 168, 1400I, 1400L(b), 1400L(c), or 1400N(d))—for an item of certain depreciable or amortizable property that has been disposed of by the applicant and for which the applicant did not take into account any depreciation allowance or did take into account some depreciation but less than the depreciation allowable,from using an impermissible method of accounting for depreciationto using a permissible method of accounting for depreciation. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.07 of Rev. Proc. 2022-14. |
| 108 | Change by bank for uncollected interest (section 446)—for a bank (as defined in Regulations section 1.166-2(d)(4)(i)) that uses an accrual method of accounting; is subject to supervision by federal authorities, or by state authorities maintaining substantially equivalent standards; and has 6 or more years of collection experience to changeto the safe harbor method of accounting for uncollected interest (other than interest described in Regulations section 1.446-2(a)(2)) set forth in section 4 of Rev. Proc. 2007-33, 2007-1 C.B. 1289. See section 15.07 of Rev. Proc. 2022-14. |
| 109 | Rotable spare parts (section 263(a))—for an applicant that maintains a pool or pools of rotable spare parts that are primarily used to repair customer-owned (or customer-leased) equipment under warranty or maintenance agreementsto the safe harbor method provided in Rev. Proc. 2007-48, 2007-2 C.B. 110. Complete Schedule E of Form 3115. See section 11.06 of Rev. Proc. 2022-14. |
List of DCNs
| 110 | Rotable spare parts (section 471)—from the safe harbor method (or a similar method) of treating rotable spare parts as depreciable assets, in accordance with Rev. Proc. 2007-48, 2007-2 C.B. 110,to treating rotable spare parts as inventoriable items. See section 22.08 of Rev. Proc. 2022-14. |
|---|
-21-
List of DCNs
| No. | Change |
|---|---|
| 111 | Advance Trade Discount Method (section 471)—for an accrual method applicant required to use an inventory method of accounting and maintaining inventories, as provided in section 471, that receives advance trade discountsto the Advance Trade Discount Method described in Rev. Proc. 2007-53, 2007-2 C.B. 233. See section 22.09 of Rev. Proc. 2022-14. |
| 112 | Changes to the Vehicle-Pool Method (section 472)—for a retail dealer or wholesaler distributor (reseller) of cars and light-duty trucks to the Vehicle-Pool Method as described in Rev. Proc. 2008-23, 2008-1 C.B. 664. See section 23.08 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 113 | Payroll tax liabilities (section 461)—for an accrual method applicant that wants to change its method for FICA and FUTA taxesto the safe harbor method provided in Rev. Proc. 2008-25, 2008-1 C.B. 686, which provides that, solely for the purposes of the recurring item exception, an applicant will be treated as satisfying the requirement in Regulations section 1.461-5(b)(1)(i) for its payroll tax liability in the same tax year in which all events have occurred that establish the fact of the related compensation liability and the amount of the related compensation liability can be determined with reasonable accuracy. See section 20.04 of Rev. Proc. 2022-14. |
| 114 | Rolling-average method of accounting for inventories (sections 471 and 472)—for an applicant required to account for inventories under section 471 and that uses a rolling-average method to value inventories for financial accounting purposesto the same rolling-average method to value inventories for federal income tax purposes, in accordance with Rev. Proc. 2008-43, 2008-30 I.R.B.186. See section 22.13 of Rev. Proc. 2022-14.Note. This change must be implemented on a cut-off basis unless the applicant’s books and records contain sufficient information to compute a section 481(a) adjustment, in which case the applicant may choose to implement the change with a section 481(a) adjustment. |
| 116 | Obsolete. See DCN 7. |
| 117 | Obsolete. See DCN 205 or 206, as applicable. |
| 119 | Obsolete. See DCN 7. |
| 121 | Repairable and reusable spare parts (section 263(a))—to treat certain repairable and reusable spare parts as depreciable property in accordance with the holding in Rev. Rul. 69-200, 1969-1 C.B. 60, or Rev. Rul. 69-201, 1969-1 C.B. 60. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.07 of Rev. Proc. 2022-14. |
| 122 | Overall accrual method change that is made other than (1) for the applicant’s first section 448 year, (2) mandatory section 448 year, or (3) because taxpayer is subject to section 447 (section 446)—for a qualifying applicant that makes a change for a year of change other than in its first section 448 year, mandatory section 448 year, or that is not subject to section 447,from the overall cash methodto an overall accrual method. Complete Schedule A, Part I, of Form 3115. Also complete Schedule D, Parts II and III, as applicable. See section 15.01 of Rev. Proc. 2022-14.Note. See DCN 123 for a change in the first section 448 year, DCN 257 for a change made in mandatory section 448 year, or DCN 258 for change made as a result of applicant being subject to section 447. |
| 123 | Change in overall method from the cash method to an accrual method for the first section 448 year (section 446)— for an applicant that is required by section 448 to changefrom the overall cash methodto an overall accrual method and the applicant qualifies to make the change under the automatic consent procedures of Regulations sections 1.448-1(g) and (h)(2) as well as Rev. Proc. 2015-13 for a year of change that is the applicant’s first section 448 year. See Regulations sections 1.448-1(g) and (h)(2), and section 15.01 of Rev. Proc. 2022-14.Note: This change does not apply to tax years beginning on or after January 5, 2021. |
| 124 | Change from the cash method to an accrual method for specific items (section 446)—for a qualifying applicant using an overall accrual method and accounting for one or more identified specific items of income and expense on the cash methodto an accrual method of accounting for the identified specific item or items. See section 15.08 of Rev. Proc. 2022-14. |
| 125 | Multi-year service warranty contracts (section 446)—for an eligible accrual method manufacturer, wholesaler, or retailer of motor vehicles or other durable consumer goods that wants to changeto the service warranty income method described in section 5 of Rev. Proc. 97-38, 1997-2 C.B. 479. See Rev. Proc. 97-38 and section 15.09 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis and also has a reduced Form 3115 filing requirement. |
| 126 | Overall cash method for specified transportation industry taxpayers (section 446)—for “specified transportation industry taxpayers,” as defined in section 15.10(2) of Rev. Proc. 2022-14, with average annual gross receipts of more than $10 million and not in excess of $50 millionto the overall cash method. See section 15.10 of Rev. Proc. 2022-14. |
| 127 | Change to overall cash/ 15.11(2)(a) of Rev. Proc. 2022-14,to an overall cash/ See section 15.11 of Rev. Proc. 2022-14. |
List of DCNs
| 128 | Change to overall cash method for farmers (section 446)—for a qualifying applicant engaged in the trade or business of farming to the overall cash method. See section 15.12 of Rev. Proc. 2022-14.Note. For applicants changing from the crop method, that portion of the change is implemented using a cut-off basis. For applicants that wish to change to the cash method for all items of income and expense and an accrual method for purchases and sales of inventories, see DCN 259. |
|---|
-22-
List of DCNs
| No. | Change |
|---|---|
| 129 | Nonshareholder contributions to capital under section 118 (section 446)—from excluding from gross income under section 61 certain payments or the fair market value of property received (including customer connection fees received by a regulated public utility described in former section 118(c)), by characterizing the payments or the fair market value of property as nontaxable contributions to capital under section 118(c),to including the payments or the fair market value of property in gross income under section 61. This change also applies to a regulated public utility described in former section 118(c) that changesfrom including in gross income under section 61 payments or the fair market value of property received that are contributions in aid of construction under former section 118(c) and Regulations section 1.118-2 and that meet the requirements of former sections 118(c)(1)(B) and 118(c)(1)(C)to excluding from income the payments or the fair market value of the property as nontaxable contributions to capital under section 118(a). See section 15.13 of Rev. Proc. 2022-14.Note. The change described in section 15.13(1)(a)(ii) of Rev. Proc. 2022-14 does not apply to contributions made after December 22, 2017. |
| 130 | Retainages not received under long-term contracts (section 451)—for an accrual method applicant’s retainages under section 451to a method consistent with the holding in Rev. Rul. 69-314, 1969-1 C.B. 139. This change does not apply to retainages under long-term contracts as defined in section 460(f). An applicant changing its method of accounting under this section must treat all retainages (receivables and payables) in the same manner. See section 16.07 of Rev. Proc. 2022-14. |
| 131 | Series E, EE, or I U.S. savings bonds (section 454)—for a cash method taxpayer changing the taxpayer’s method of accounting for interest income on series E, EE, or I U.S. savings bondsfrom reporting as interest income the increase in redemption price on a bond occurring in a tax yearto reporting this income in the tax year in which the bond is redeemed, disposed of, or finally matures, whichever is earliest. A statement in lieu of a Form 3115 is authorized for this change. See section 17.01 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 132 | Prepaid subscription income (section 455)—for an accrual method applicant changing its method of accounting for prepaid subscription incometo the method described in section 455 and the related regulations, including an eligible applicant that wants to make the “within 12 months” election under Regulations section 1.455-2. A statement in lieu of a Form 3115 is authorized for this change. See section 18.01 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 133 | Timing of incurring liabilities for bonuses (section 461)—to treat bonuses as incurred in the tax year in which all events have occurred that establish the fact of the liability to pay a bonus and the amount of the liability can be determined with reasonable accuracy. See section 20.01(2) of Rev. Proc. 2022-14. |
| 134 | Timing of incurring liabilities for vacation pay, sick pay, and severance pay (section 461)—to treat vacation pay, sick pay, and severance pay as incurred in the tax year in which all events have occurred that establish the fact of the liability to pay vacation pay, sick pay, and severance pay, and the amount of the liability can be determined with reasonable accuracy. The applicant may make this change if the vacation pay, sick pay, and severance pay vests in that tax year and the vacation pay, sick pay, and severance pay is received by the employee by the 15th day of the 3rd calendar month after the end of that tax year. See section 20.01(3) of Rev. Proc. 2022-14. |
| 135 | Rebates and allowances (section 461)—for an accrual method applicant’s liability for rebates and allowancesto the recurring item exception method under section 461(h)(3) and Regulations section 1.461-5. See section 20.07 of Rev. Proc. 2022-14. |
| 136 | Change from an improper method of inclusion of rental income or expense to inclusion in accordance with the rent allocation (section 467)—for an applicant that is a party to a section 467 rental agreement and is changing its method for its fixed rentto the rent allocation method provided in Regulations section 1.467-1(d)(2)(iii). See section 21.01 of Rev. Proc. 2022-14.Note. This change only receives limited audit protection. |
| 137 | Permissible methods of identification and valuation of inventories (section 471)—for an applicant changing from one permissible method of identifying and valuing inventoriesto another permissible method of identifying and valuing inventories. Complete Schedule D, Parts II and III, of Form 3115, as applicable. See section 22.10 of Rev. Proc. 2022-14. |
| 138 | Change in the official used vehicle guide utilized in valuing used vehicles (section 471)—for a used vehicle dealer from not using an official used vehicle guide for valuing used vehiclesto using an official used vehicle guide for valuing used vehicles; orfrom using an official used vehicle guide for valuing used vehiclesto using a different official used vehicle guide for valuing used vehicles. See section 22.11 of Rev. Proc. 2022-14. |
List of DCNs
| 139 | Invoiced advertising association costs for new vehicle retail dealerships (section 471)—for an applicant engaged in the trade or business of retail sales of new automobiles or new light-duty trucks (dealership)from capitalizing certain advertising costs as acquisition costs under Regulations section 1.471-3(b)to deducting the advertising costs under section 162 as the advertising services are provided to the dealership. See Regulations section 1.461-4(d)(2)(i), and section 22.12 of Rev. Proc. 2022-14. |
|---|
-23-
List of DCNs
| No. | Change |
|---|---|
| 140 | Changes within the Used Vehicle Alternative LIFO Method (section 472)—for a taxpayer using the Used Vehicle Alternative LIFO Method, as described in Rev. Proc. 2001-23, 2001-1 C.B. 784, as modified by Announcement 2004-16, 2004-1 C.B. 668, and Rev. Proc. 2008-23, 2008-1 C.B. 664,to use a different “official used vehicle guide” in conjunction with the Used Vehicle Alternative LIFO Method, orto a different precise manner of using an official used vehicle guide (for example, a change in the specific guide category that an applicant uses to represent vehicles of average condition for purposes of section 4.02(5)(a) of Rev. Proc. 2001-23). See section 23.09 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 141 | Changes to dollar-value pools of manufacturers (section 472)—for a manufacturer that purchases goods for resale (resale goods) and thus must reassign resale goods from the pool(s) it maintains for the goods it manufactures to one or more resale pools, and the manufacturer wants to changefrom using multiple pools described in Regulations section 1.472-8(b)(3) to using natural business unit (NBU) pools described in Regulations section1.472-8(b)(1), or vice versa; or wants to reassign items in NBU pools described in Regulations section 1.472-8(b)(1) into the same number or a greater number of NBU pools. See section 23.10 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 145 | Tenant construction allowances (section 168)—for an applicant changing from improperly treating the applicant as having a depreciable interest in the property subject to the tenant construction allowances for federal income tax purposesto properly treating the applicant as not having a depreciable interest in such property for federal income tax purposes; orfrom improperly treating the applicant as not having a depreciable interest in the property subject to the tenant construction allowances for federal income tax purposesto properly treating the applicant as having a depreciable interest in such property for federal income tax purposes. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.08 of Rev. Proc. 2022-14. |
| 146 | Obsolete. See DCN 205. |
| 147 | Obsolete. See DCN 206. |
| 148 | Debt issuance costs (section 446)—for an applicant changing its method of accountingto comply with Regulations section 1.446-5, which provides rules for allocating the costs over the term of the debt. See section 15.14 of Rev. Proc. 2022-14. |
| 149 | Ratable accrual of real property taxes (section 461)—for an accrual method applicant for real property taxes that relate to a definite period of timeto the method described in section 461(c) and section 1.461-1(c)(1) (ratable accrual election) for a tax year other than the applicant’s first tax year in which real property taxes are incurred. See section 20.08 of Rev. Proc. 2022-14. Note. This change has a reduced Form 3115 filing requirement. |
| 150 | Retail sales facility safe harbor for a motor vehicle dealership (section 263A)—for a motor vehicle dealershipto treat its sales facility as a retail sales facility as described in section 5.01 of Rev. Proc. 2010-44, 2010-49 I.R.B. 811. See section 12.06 of Rev. Proc. 2022-14. |
| 151 | Reseller without production activities safe harbor for a motor vehicle dealership (section 263A)—for a motor vehicle dealershipto be treated as a reseller without production activities as described in section 5.02 of Rev. Proc. 2010-44, 2010-49 I.R.B. 811. See section 12.06 of Rev. Proc. 2022-14. |
| 152 | Deduction for energy efficient commercial buildings (section 179D)—for an applicant to change its method of accounting to deduct under section 179D amounts paid or incurred for the installation of energy efficient commercial building property, subject to the limits of section 179D(b), in the year the property is placed in service. See Rev. Proc. 2012-39, 2012-2 C.B. 470, and section 8.01 of Rev. Proc. 2022-14.Note. This change does not receive audit protection. |
| 153 | Certain revenue recognition methods of accounting—change in applicable financial statements (AFS) (section 451) — for an applicant with an AFS (1) using the deferral method for including advance payments in gross income in accordance with its AFS to change its methodto recognize advance payments in gross income consistent with a changed manner for recognizing advance payments for its AFS;or (2) that includes amounts in income in accordance with Regulations section 1.451-3 that has a change in the manner in which the item, or portion of it, is taken into account as AFS revenue or has a change in transaction price allocation to performance allocationsto use the new AFS method for purposes of Regulations section 1.451-3(b)(1) or (d), as applicable. The requirement in section 6.03(3)(a) of Rev. Proc. 2015-13 to provide an additional copy of the application to the examining agent(s), appeals officer(s), and counsel to the government, if applicable, applies to this application. A statement in lieu of a Form 3115 is authorized for this change. See section 16.08 of Rev. Proc. 2022-14. Note. This change is implemented on a cut-off basis or with a section 481(a) adjustment depending on the change being made and does not receive audit protection. This change does not apply to method changes relating to Rev. Proc. 2004-34, section 451(b), Proposed Regulations section 1.451-3, and Proposed Regulations section 1.451-8 for tax years beginning on or after January 1, 2021. |
List of DCNs
| 154 | California franchise taxes (Rev. Rul. 2003-90)—for an accrual method applicant changingto recognizing its California franchise tax liability in the tax year following the tax year in which the tax is incurred under the Cal. Rev. & Tax Code. See section 20.09 of Rev. Proc. 2022-14. |
|---|---|
| 155 | Unearned premiums (section 833)—for a Blue Cross or Blue Shield organization within the meaning of section 833(c)(2) or an organization described in section 833(c)(3) required to change its method of accounting for unearned premiums because it fails to meet or meets anew the MLR requirements of section 833(c)(5). See section 26.02 of Rev. Proc. 2022-14. |
-24-
List of DCNs
| No. | Change |
|---|---|
| 156 | Gift cards issued as a refund (Rev. Proc. 2011-17)—for an accrual method applicant who issues gift cards as a refund for returned goods changingto treat the transaction as the payment of a cash refund and sale of a gift card in the amount of the gift card, as provided in Rev. Proc. 2011-17, 2011-5 I.R.B. 441. See section 20.10 of Rev. Proc. 2022-14. |
| 157 | Classification of wireless telecommunications assets used by wireless telecommunications carriers (sections 167 and 168)—for applicants that have a depreciable interest in wireless telecommunications assets (as defined in Rev. Proc. 2011-22, 2011-8 I.R.B. 737) used primarily to provide wireless telecommunications or broadband services by mobile phones that are changingto the method described in Rev. Proc. 2011-22 to determine the recovery periods for depreciation of certain tangible assets used by wireless telecommunications carriers. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See Rev. Proc. 2011-22 and section 6.09 of Rev. Proc. 2022-14. |
| 158 | Wireline network property (section 263(a))—for certain applicants that have a depreciable interest in wireline network assets (as described in section 4 of Rev. Proc. 2011-27, 2011-8 I.R.B. 740) used primarily to provide wireline telecommunications or broadband services that are changingto (a) the wireline network assets maintenance allowance method described in section 5 of Rev. Proc. 2011-27; or (b) the adoption of all, or some, of the units of property described in section 6 of Rev. Proc. 2011-27, to determine whether expenditures to maintain, replace, or improve wireline network assets must be capitalized under section 263(a). See section 3.07 of Rev. Proc. 2022-14. |
| 159 | Wireless network property (section 263(a))—for certain applicants that have a depreciable interest in wireless network assets (as described in section 4 of Rev. Proc. 2011-28, 2011-8 I.R.B. 743) used primarily to provide wireless telecommunications or broadband services by mobile phones that are changingto (a) the wireless network asset maintenance allowance method described in section 5 of Rev. Proc. 2011-28, or (b) the adoption of all, or some, of the units of property described in section 6 of Rev. Proc. 2011-28, to determine whether expenditures to maintain, replace, or improve wireless network assets must be capitalized under section 263(a). See section 3.08 of Rev. Proc. 2022-14. |
| 160 | Electric transmission and distribution property (section 263(a))—for certain applicants that have a depreciable interest in electric transmission or distribution property (as described in section 4 of Rev. Proc. 2011-43, 2011-37 I.R.B. 326) used primarily to transport, deliver, or sell electricity that are changingto the method described in Rev. Proc. 2011-43, to determine whether expenditures incurred to maintain, replace, or improve transmission and distribution property are deductible repairs under section 162 or capitalizable improvements under section 263(a). See section 3.09 of Rev. Proc. 2022-14. |
| 161 | Timing of incurring liabilities under the recurring item exception to the economic performance rules (section 461(h) (3))—for an applicant changingto a method of accounting to conform to any of the holdings in Rev. Rul. 2012-1, 2012-2 I.R.B. 255, which addresses the “not material” and “better matching” requirements of the recurring item exception and distinguishes contracts for the provision of services from insurance and warranty contracts. See section 20.11 of Rev. Proc. 2022-14. |
| 175 | Obsolete. See DCN 199. |
| 176 | Obsolete. See DCN 200. |
| 177 | Obsolete. See DCN 205. |
| 178 | Obsolete. See DCN 206. |
| 179 | Obsolete. See DCN 207. |
| 181 | Plants removed from the list of plants that have a preproductive period in excess of 2 years (section 263A)—for an applicant that is not a corporation, partnership, or tax shelter required to use an accrual method of accounting and either is changingto not applying section 263A to the production of a plant or plants that have been removed from the list of plants with a nationwide weighted average preproductive period in excess of 2 years,or is revoking its section 263A(d)(3) electionto not apply section 263A to the production of a plant or plants that have been removed from the list of plants with a nationwide weighted average preproductive period in excess of 2 years. See Rev. Proc. 2013-20 and section 12.07 of Rev. Proc. 2022-14. |
| 182 | Steam or electric power generation property (section 263(a))—for an applicant changing its method of accounting for its treatment of expenditures on generation property (as defined in section 4.01 of Rev. Proc. 2013-24, 2013-22 I.R.B. 1142)to use all or some of the unit of property definitions and the corresponding major component definitions described in Appendix A of Rev. Proc. 2013-24, to determine whether expenditures to maintain, replace, or improve generation property must be capitalized under section 263(a). See section 3.10 of Rev. Proc. 2022-14. |
| 183 | Change to proportional method of accounting for OID on a pool of credit card receivables (section 1272(a)(6))—for an eligible taxpayer that wants to change to the proportional method of accounting for original issue discount (OID) on a pool of credit card receivables, as described in Rev. Proc. 2013-26, 2013-22 I.R.B. 1160, as modified by Rev. Proc. 2021-35, 2021-35 I.R.B. 355. See section 30.02 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
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List of DCNs
| No. | Change |
|---|---|
| 184 | Deducting repair and maintenance costs or capitalizing improvement costs (sections 162 and 263(a))—for an applicant changingto deducting amounts paid or incurred for repair and maintenance costs under section 162 and Regulations section 1.162-4 or changingto capitalizing amounts paid or incurred for improvements to tangible property and, if depreciable, to depreciating such property under section 167 or 168. Includes a change by an applicant in the method of identifying units of property under Regulations section 1.263(a)-3(e) for purposes of determining whether amounts paid or incurred improve a unit of property under Regulations section 1.263(a)-3. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 185 | Change to the regulatory accounting method (section 162)—for a regulated applicant changing its method of accounting for amounts paid or incurred to repair or maintain tangible property to follow its method of accounting for regulatory accounting purposes to determine whether an amount paid or incurred improves property under Regulations section 1.263(a)-3, consistent with Regulations section 1.263(a)-3(m). Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 186 | Deducting non-incidental materials and supplies when used or consumed (section 162)—for an applicant changing its method of accounting for non-incidental materials and suppliesto the method of deducting such amounts in the tax year in which they are actually used or consumed, consistent with Regulations section 1.162-3. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 187 | Deducting incidental materials and supplies when paid or incurred (section 162)—for an applicant that wants to change its method of accounting for incidental materials and suppliesto the method of deducting such amounts in the tax year in which they are paid or incurred, consistent with Regulations section 1.162-3. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 188 | Deducting non-incidental rotable and temporary spare parts when disposed (section 162)—for an applicant changing its method of accounting for costs to acquire or produce non-incidental rotable and temporary spare partsto the method of deducting such costs in the tax year in which the taxpayer disposes of the parts, consistent with Regulations section 1.162-3. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 189 | Change to the optional method for rotable and temporary spare parts (section 162)—for an applicant changing its method of accounting for rotable and temporary spare partsto the optional method of accounting for rotable and temporary spare parts (described in Regulations section 1.162-3(e)), consistent with Regulations section 1.162-3. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 190 | Deducting dealer expenses that facilitate the sale of property (section 162)—for an applicant that is a dealer in property changing its method of accounting for commissions and other costs paid or incurred to facilitate the sale of tangible propertyto the method of treating such costs as ordinary and necessary business expenses, consistent with Regulations section 1.263(a)-1(e)(2). Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 191 | Non-dealer expense to facilitate the sale of property (section 263(a))—for an applicant that is not a dealer in property changing its method of accounting for commissions and other costs paid or incurred to facilitate the sale of propertyto the method of capitalizing such costs, consistent with Regulations section 1.263(a)-1(e)(1). Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 192 | Capitalizing acquisition or production costs (section 263(a))—for an applicant changing its method of accountingto capitalizing amounts paid or incurred to acquire or produce property under Regulations section 1.263(a)-2 and, if depreciable, to depreciating such property under section 167 or 168. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
| 193 | Deducting certain costs for investigating or pursuing the acquisition of property (section 162)—for an applicant changing its method of accountingfrom capitalizingto deducting amounts paid or incurred in the process of investigating or otherwise pursuing (a) the acquisition of real property if the amounts meet the requirements of Regulations section 1.263(a)-2(f) (2)(iii); or (b) the acquisition of real or personal property if the amounts are for employee compensation or overhead costs under Regulations section 1.263(a)-2(f)(2)(iv), consistent with Regulations section 1.263(a)-2. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.08 of Rev. Proc. 2022-14. |
List of DCNs
| 194 | Change to a reasonable allocation method for self-constructed assets (section 263A)—for a producer or a reseller-producerto a reasonable allocation method under Regulations section 1.263A-1(f)(4) for self-constructed assets or from not capitalizing a cost subject to section 263Ato capitalizing that cost under a reasonable allocation method under Regulations section 1.263A-1(f)(4) that the producer or reseller-producer is already using for self-constructed assets. See section 12.08 of Rev. Proc. 2022-14. |
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List of DCNs
| No. | Change |
|---|---|
| 195 | Real property acquired through foreclosure (section 263A)—for an applicant that capitalizes costs under section 263A(b) (2) and Regulations section 1.263A-3(a)(1) to real property acquired through foreclosure, or similar transaction,to an otherwise permissible method of accounting under which the acquisition and holding costs for real property acquired through foreclosure, or similar transaction, are not capitalized under section 263A(b)(2) and Regulations section 1.263A-3(a)(1). See section 12.09 of Rev. Proc. 2022-14. |
| 196 | Obsolete. |
| 197 | Obsolete. |
| 198 | Partial dispositions of tangible depreciable asset to which the IRS’s adjustment pertains (section 168)—for MACRS property for which the applicant is making a partial disposition election under Regulations section 1.168(i)-8(d)(2)(iii) to the disposition of a portion of the asset to which the IRS’s adjustment pertains (as described in Regulations section 1.168(i)-8(d)(2) (iii)). Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.10 of Rev. Proc. 2022-14. |
| 199 | Depreciation of leasehold improvements (sections 167, 168, and 197)—for leasehold improvements in which the applicant has a depreciable interest at the beginning of the year of change,from improperly depreciating or amortizing these leasehold improvements over the term of the lease (including renewals, if applicable)to properly depreciating or amortizing these leasehold improvements under section 167(f)(1), 168, or 197, as applicable. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.11 of Rev. Proc. 2022-14. |
| 200 | Depreciation of MACRS property (permissible to permissible) (section 168)—for MACRS property,from a permissible methodto another permissible method listed in section 6.12(3) of Rev. Proc. 2022-14. Certain changes are made on a modified cut-off basis or a cut-off basis. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.12 of Rev. Proc. 2022-14. |
| 201 | Sales-based royalties (section 263A)—for sales-based royalties (as described in Regulations section 1.263A-1(e)(3)(ii)(U) (2)) properly allocable to inventory property for which the applicant is making a change listed in section 12.10(1) of Rev. Proc. 2022-14. See Rev. Proc. 2014-33 and section 12.10 of Rev. Proc. 2022-14. |
| 202 | Sales-based vendor chargebacks under a simplified method (section 263A)—for an applicant changing its method of accounting to no longer include cost adjustments for sales-based vendor chargebacks (as described in Regulations section 1.471-3(e)(1)) in the formulas used to allocate additional section 263A costs to ending inventory under a simplified method. See Rev. Proc. 2014-33 and section 12.11 of Rev. Proc. 2022-14. |
| 203 | Sales-based vendor chargebacks (section 471)—for an applicant changing its method of accounting to treat sales-based vendor chargebacks as a reduction in cost of goods sold in accordance with Regulations section 1.471-3(e)(1). See Rev. Proc. 2014-33 and section 22.14 of Rev. Proc. 2022-14. |
| 204 | Retail inventory method (section 471)—for an applicant using the retail inventory method, a changeto (a) not adjusting the numerator of the cost complement for an allowance, discount, or price rebate required by Regulations section 1.471-3(e) to reduce only cost of goods sold; (b) not adjusting the denominator of the cost complement for temporary markups and markdowns; (c) computing the cost complement using a method described in Regulations section 1.471-8(b)(3) (including changes from a method described in section 1.471-8(b)(3) to another method described in that section) for a retail LCM applicant; or (d) adjusting the denominator of the cost complement for permanent markups and markdowns for a retail cost applicant. See section 22.15 of Rev. Proc. 2022-14.Note. A taxpayer making any of these changes for its first or second tax year after December 31, 2014, may use either a section 481(a) adjustment or a cut-off basis to implement the change. |
| 205 | Dispositions of a building or structural component (section 168)—for MACRS property for which the applicant is making a change listed in section 6.13(3) of Rev. Proc. 2022-14 for disposing of a building or a structural component or disposing of a portion of a building (including its structural components) to which the partial disposition rule in Regulations section 1.168(i)-8(d) (1) applies. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.13 of Rev. Proc. 2022-14. |
| 206 | Dispositions of tangible depreciable assets (other than a building or its structural components) (section 168)—for MACRS property for which the applicant is making a change listed in section 6.14(3) of Rev. Proc. 2022-14 for disposing of section 1245 property or a depreciable land improvementor disposing of a portion of section 1245 property or a depreciable land improvement to which the partial disposition rule in Regulations section 1.168(i)-8(d)(1) applies. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.14 of Rev. Proc. 2022-14. |
List of DCNs
| 207 | Dispositions of tangible depreciable assets in a general asset account (section 168)—for MACRS property for which the applicant is making a change listed in section 6.15(3) of Rev. Proc. 2022-14 for disposing of an asset subject to a general asset account election. Complete Schedule E of Form 3115. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 6.15 of Rev. Proc. 2022-14. |
|---|
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List of DCNs
| No. | Change |
|---|---|
| 208 | Cable network asset maintenance allowance or unit of property method of accounting (section 263(a))—for certain applicants that operate and have a depreciable interest in cable network assets used in a cable system that provides video, high speed internet, and VOIP phone services that are changing to (a) the network maintenance allowance method for cable network assets described in section 5 of Rev. Proc. 2015-12, 2015-2 I.R.B. 265; or (b) the adoption of all, or some, of the units of property described in section 6 of Rev. Proc. 2015-12, to determine whether expenditures to maintain, replace, or improve cable network assets must be capitalized under section 263(a). See section 3.11 of Rev. Proc. 2022-14. |
| 209 | Cable network customer drops and labor costs associated with installing customer premise equipment (section 263(a))—for certain applicants that operate cable systems and (a) are changing to the specific identification method described in section 7.01(1) of Rev. Proc. 2015-12, or the safe harbor allocation method described in section 7.01(2) of Rev. Proc. 2015-12 for determining whether customer drop costs (including installations) may be deducted under section 162 or must be capitalized under section 263(a), or (b) are changing to deducting labor costs associated with installing customer premise equipment under section 7.02 of Rev. Proc. 2015-12. See section 3.11 of Rev. Proc. 2022-14. |
| 210 | Depreciation of fiber optic transfer node and fiber optic cable used by a cable system operator (section 168)—for a cable system operator within the scope of Rev. Proc. 2015-12 that is changing to the safe harbor method of accounting in section 8.03 of Rev. Proc. 2015-12 for determining depreciation of a fiber optic transfer node and trunk line consisting of fiber optic cable used in a cable distribution network providing one-way and two-way communication services. See Rev. Proc. 2015-12 and section 6.17 of Rev. Proc. 2022-14. |
| 211 | Bad debt conformity election by bank after previous election automatically revoked (section 166)—for an eligible bank changing its method of accounting for bad debts by making the conformity election under Regulations section 1.166-2(d)(3)(iii) (C)(3). See section 4.02 of Rev. Proc. 2022-14. |
| 212 | Change to comply with section 163(e)(3)—for a taxpayer changing its method or methods of accounting to comply with the requirements of section 163(e)(3), which defers certain deductions attributable to OID debt instruments held by related foreign persons. Any portion of the OID will not be allowable as a deduction to the U.S. person issuer until paid. See section 5.02 of Rev. Proc. 2022-14. |
| 213 | Railroad track structure expenditures (section 263(a))—for a taxpayer changing its method of accounting for track structuresto (a) the safe harbor method provided in Rev. Proc. 2002-65, 2002-2 C.B. 700; or (b) the safe harbor method provided in Rev. Proc. 2001-46, 2001-2 C.B. 263. See section 11.09 of Rev. Proc. 2022-14. |
| 214 | U.S. ratio method (section 263A)—for a foreign person (as defined in Notice 88-104, as modified by Notice 89-67) required to capitalize costs under section 263A that is changing its method of accounting to the U.S. ratio method (as described in Notice 88-104) or that currently uses the U.S. ratio method and is changing to the U.S. ratio method of a different applicable U.S. trade or business for applying the U.S. ratio method. See section 12.12 of Rev. Proc. 2022-14. |
| 215 | Depletion (section 263A)—for an applicant changing its method of accounting for depletion to treat these amounts as an indirect cost that is only properly allocable to property that has been sold under Regulations section 1.263A-1(e)(3)(ii)(J). See section 12.13 of Rev. Proc. 2022-14. |
| 216 | Obsolete. |
| 217 | Retainages received under long-term contracts (section 451)—for an accrual method applicant’s retainages under section 451to a method consistent with the holding in Rev. Rul. 69-314, 1969-1 C.B. 139. This change only applies to retainages under long-term contracts as defined in section 460(f) that are exempt construction contracts (as defined in Regulations section 1.460-3(b)(1)). An applicant changing its method of accounting under this section must treat all retainages (receivables and payables) in the same manner. See section 16.07 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis. |
| 218 | Change from the mark-to-market method of accounting to a realization method (section 475)—for a taxpayer changing its method of accounting for securities or commoditiesfrom the mark-to-market method described in section 475to a realization method of accounting (for example, by revoking an election under section 475(e), section 475(f)(1), or section 475(f) (2)). A notification statement must be filed earlier than the due date of the Form 3115. See section 24.02 of Rev. Proc. 2022-14. Note. This change is generally made with audit protection, but has conditions or limitations. This change is also implemented on a cut-off basis. |
| 219 | Change in qualification as life/ section 816(a) to movefrom a life insurance company taxable under Part I of subchapter Lto a non-life insurance company taxable under Part II of subchapter L, or vice versa. See section 26.03 of Rev. Proc. 2022-14.Note. This change does not receive audit protection. |
List of DCNs
| 220 | Economic performance safe harbor for Ratable Service Contracts (section 461)—for an accrual method taxpayer that wants to change its treatment of Ratable Service Contracts to conformto the safe harbor method provided by Rev. Proc. 2015-39, 2015-33 I.R.B. 197. See section 20.12 of Rev. Proc. 2022-14. |
|---|---|
| 221 | Obsolete. |
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List of DCNs
| No. | Change |
|---|---|
| 222 | Remodel-refresh safe harbor method (section 263)—for a qualified taxpayer changingto the remodel-refresh safe harbor method of accounting provided in section 5.02 of Rev. Proc. 2015-56 for its qualified costs, including the making of a late general asset account election as provided under section 5.02(6)(d) of Rev. Proc. 2015-56. Additionally, a qualified small taxpayer qualifies for a reduced Form 3115 filing requirement. See section 11.10 of Rev. Proc. 2022-14.Note. This change is generally made with audit protection, but has conditions or limitations. Certain changes are also implemented on a cut-off basis. |
| 223 | Start-up expenditures (section 195)— for an applicant changing its method of accounting under section 195to change the characterization of an item as a start-up expenditure, the determination of the tax year in which the taxpayer begins the active trade or business to which the start-up expenditures relate, or the amortization period of a start-up expenditure to 180 months. See section 10.01 of Rev. Proc. 2022-14. |
| 224 | Interest capitalization (section 263A)—for an applicant changing its method of accounting for interestfrom not capitalizing any interest, capitalizing interest in accordance with its method of accounting for financial reporting purposes, or applying an improper method of capitalizing interest under Regulations sections 1.263A-8 through -14, with respect to the production of designated property,to capitalizing interest with respect to the production of designated property in accordance with Regulations sections 1.263A-8 through -14. See section 12.14 of Rev. Proc. 2022-14. |
| 225 | Certain changes within the retail inventory method (section 471)—for an applicant using the retail inventory method that wants to changefrom includingto not including temporary markups and markdowns in determining the retail selling prices of goods on hand at the end of the tax year. See section 22.16 of Rev. Proc. 2022-14. |
| 226 | Transfer of interties under the safe harbor described in Notice 2016-36 (section 118)—for a utility changingto the safe harbor method of accounting provided in section III.C of Notice 2016-36 for the treatment under section 118 of a transfer of an intertie, including a dual-use intertie, by a generator to a utility, or for a utility using the safe harbor method of accounting provided in section III.C of Notice 2016-36 and is required to terminate that safe harbor method of accounting. See section 15.15 of Rev. Proc. 2022-14.Note. The change from using the safe harbor method of accounting provided in section III.C of Notice 2016-36 to terminating that safe harbor method of accounting is implemented on a cut-off basis. |
| 227 | Change to or from the net asset value (NAV) method (section 446)—for an applicant that holds shares in a money market fund (MMF) and that wants to change its method of accounting for gain or loss on the shares from a realization method to the NAV method described in Regulations section 1.446-7 or from the NAV method to a realization method. See section 15.16 of Rev. Proc. 2022-14.Note. This change is implemented on a cut-off basis and also has a reduced Form 3115 filing requirement. |
| 228 | Organizational expenditures under section 248 (section 248)—for a corporation changing its method of accounting under section 248to change the characterization of an item as an organizational expenditure, the determination of the tax year in which the corporation begins business to which the organizational expenditures relate, or the amortization period of an organizational expenditure to 180 months. See section 10.02 of Rev. Proc. 2022-14. |
| 229 | Organization fees under section 709 (section 709)—for a partnership changing its method of accounting under section 709 to change the characterization of an item as an organizational expense, the determination of the tax year in which the partnership begins business to which the organizational expenses relate, or the amortization period of an organizational expense to 180 months. See section 10.03 of Rev. Proc. 2022-14. |
| 230 | Change from currently deducting inventories to permissible methods of identification and valuation of inventories (section 471)—for an applicant changingfrom currently deducting inventoriesto a permissible method of identifying and valuing inventories. See section 22.17 of Rev. Proc. 2022-14. |
| 231 | Changes in the timing of recognition of income due to the New Standards (section 451)—for an applicant that wants to change its method of accounting for the recognition of incometo a method under the new financial accounting standards jointly announced by the Financial Accounting Standards Board and the International Accounting Standards Board for (i) identifying performance obligations, (ii) allocating transaction price to performance obligations, and/ obligations satisfied. See section 16.09 of Rev. Proc. 2022-14.Note. A taxpayer making this change may implement the change with either a section 481(a) adjustment or on a cut-off basis. This change applies to a tax year beginning on or before May 10, 2022. An applicant that makes a New Standards change that also wants to comply with section 451(b) and Regulations section 1.451-3, and/ Rev. Proc. 2022-14, as applicable. |
List of DCNs
| 232 | Change to not apply section 263A to replanting costs for lost or damaged citrus plants pursuant to section 263A(d) (2)(C)—for certain applicants that currently capitalize costs of replanting citrus plants under section 263A(d)(2),to not applying section 263A to those costs under section 263A(d)(2)(C). Costs must be paid or incurred after December 22, 2017, and on or before December 22, 2027. See Rev. Proc. 2018-35, 2018-28 I.R.B. 204, and section 12.15 of Rev. Proc. 2022-14.Note. The section 481(a) adjustment is calculated by taking into account only amounts paid or incurred after December 22, 2017, and on or before December 22, 2027. |
|---|---|
| 233 | Overall cash method for a small business taxpayer (section 446)—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) changingto the overall cash method. Complete certain lines of Schedule A, Part I, of Form 3115. See section 15.17 of Rev. Proc. 2022-14. |
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List of DCNs
| No. | Change |
|---|---|
| 234 | Uniform capitalization exception for a small business taxpayer (section 263A)—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) changingfrom capitalizing costs under section 263Ato no longer capitalizing costs under section 263A, including for self-constructed assets. See Rev. Proc. 2018-40 and section 12.16 of Rev. Proc. 2022-14. |
| 235 | Inventory exception for a small business taxpayer (section 471)—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) changing its accounting method for inventory items under section 471to one of the following methods: (a) treating inventory as non-incidental materials and supplies (NIMS) under section 471(c)(1)(B) (i); (b) treating inventory as NIMS under Proposed Regulations section 1.471-1(b)(4); (c) a method that conforms to section 471(c)(1)(B)(ii) by using the taxpayer’s method of accounting reflected in its AFS, as defined in section 451(b)(3), with respect to the tax year, or if the taxpayer does not have an AFS for the tax year, the books and records of the taxpayer prepared in accordance with the taxpayer’s accounting procedures; or (d) the AFS section 471(c) method in Proposed Regulations section 1.471-1(b)(5), or if the taxpayer does not have an AFS for the tax year, the non-AFS section 471(c) method described in Proposed Regulations section 1.471-1(b)(6). See section 22.18 of Rev. Proc. 2022-14.Note. This change does not apply to tax years beginning on or after January 5, 2021. See, however, DCN 260 or 261 for tax years beginning on or after January 5, 2021. |
| 236 | Long-term contract exception for small business taxpayer (section 460)—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) (a) changingfrom the percentage-of-completion accounting method described in Regulations section 1.460-4(b) for exempt long-term construction contracts described in section 460(e)(1)(B)to an exempt contract accounting method described in section 1.460-4(c), or (b) with long-term home construction contracts defined in section 460(e)(1)(A) changing its accounting methodto stop capitalizing costs under 263A. Complete Schedule D, Part I, of Form 3115. See section 19.01 of Rev. Proc. 2022-14.Note. A change to account for exempt long-term contracts under this change is made on a cut-off basis. |
| 237 | Recharacterizing costs under the simplified resale method, the simplified production method, or the modified simplified production method—for an applicant that uses or is changingto the simplified resale method, the simplified production method, or the modified simplified production method and wants to recharacterize a section 471 cost, as defined in section 1.263A-1(d)(2), as an additional section 263A cost, as defined in section 1.263A-1(d)(3), or vice versa. See section 12.17 of Rev. Proc. 2022-14. |
| 238 | Revocation of a historic absorption ratio election—for an applicant that either (a) uses the simplified resale method with historic absorption ratio election that wants to revoke its historic absorption ratio election and change to the simplified resale method without historic absorption ratio election, or (b) uses the simplified production method with historic absorption ratio election that wants to revoke its historic absorption ratio election and change to the simplified production method without historic absorption ratio election. This change applies to a taxpayer’s first, second, or third tax year ending on or after November 20, 2018. See section 12.18 of Rev. Proc. 2022-14. |
| 239 | Obsolete. |
| 240 | Change in basis of computing reserves (section 807)—for a life insurance company changing the basis of computing any item referred to in section 807(c), as described in section 807(f), or a non-life insurance company changing the basis of computing life insurance reserves. See section 26.04 of Rev. Proc. 2022-14. |
| 241 | Late elections or revocation of elections under sections 168(k)(5), (k)(7), and (k)(10)—for an applicant within the scope of Rev. Proc. 2019-33, 2019-34 I.R.B. 662, that wants to make a late election, or to revoke an election, provided in sections 4, 5, and 6 of Rev. Proc. 2019-33 under section 168(k)(5), (k)(7), or (k)(10). See section 6.18 of Rev. Proc. 2022-14. |
| 242 | Changes in timing of income recognition under Proposed Regulations sections 1.451-3 and 1.451-8 (section 451)— for an accrual method applicant with an applicable financial statement (AFS) that is changingto (a) a method of accounting under Proposed Regulations section 1.451-3,or (b) a method of accounting for advance payments under Proposed Regulations section 1.451-8(a) or (c). This change is also for an applicant without an AFS that is changingto a method of accounting for advance payments under Proposed Regulations section 1.451-8(a) or (d).Note. This change does not apply to tax years beginning after December 31, 2020. Some changes may be made on a cut-off basis. See section 16.10 of Rev. Proc. 2022-14. |
| 243 | Late revocation of elections under section 263A(d)(3)—for an eligible small business taxpayer that wants to make a late revocation election under section 263A(d)(3) as provided in section 5.02(2)(b) of Rev. Proc. 2020-13. See section 12.19 of Rev. Proc. 2022-14.Note. The change under section 12.19 of Rev. Proc. 2022-14 must be made for the taxpayer's first, second, or third tax year beginning after the taxpayer's first tax year beginning in 2018. |
List of DCNs
| 244 | Qualified improvement property placed in service after December 31, 2017 (section 168)—for an applicant that wants to change from an impermissible to a permissible method of accounting for depreciation of any item of qualified improvement property, as defined in section 168(e)(6), that is placed in service by the taxpayer after December 31, 2017, and that is owned by the taxpayer at the beginning of the year of change. An applicant qualifies for a reduced filing requirement. See section 6.19 of Rev. Proc. 2022-14. |
|---|
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List of DCNs
| No. | Change |
|---|---|
| 245 | Certain late elections under sections 168 and 1502 or revocation of certain elections under section 168 (sections 168(g)(7), (k)(5), (k)(7), and (k)(10); and Regulations sections 1.168(k)-2 and 1.1502-68)—for an applicant within the scope of section 4 of Rev. Proc. 2020-25, 2020-19 I.R.B. 785, as modified by section 8 of Rev. Proc. 2020-50, 2020-48 I.R.B. 1122, that wants to make a late election provided in section 4.02(2) of Rev. Proc. 2020-25 under section 168(g)(7), (k)(5), (k) (7), or (k)(10). This change also applies to an applicant within the scope of section 5 of Rev. Proc. 2020-25 that wants to revoke an election provided in section 5.02(2)(b) of Rev. Proc. 2020-25 under section 168(k)(5), (k)(7), or (k)(10). This change also applies to an applicant within the scope of section 5 of Rev. Proc. 2020-50 that wants to make a late election under section 168(k)(5), (k)(7), or (k)(10); Regulations section 1.168(k)-2(c) (component election); Regulations section 1.1502-68(c)(4) (designated transaction election); or Proposed Regulations section 1.168(k)-2(c) (proposed component election) as provided in section 5.02(2) of Rev. Proc. 2020-50. Finally, this change also applies to a taxpayer within the scope of section 6 of Rev. Proc. 2020-50 that wants to revoke an election under section 168(k)(5), (k)(7), or (k)(10); or a proposed component election as provided in section 6.02(2)(b) of Rev. Proc. 2020-50. An applicant qualifies for a reduced filing requirement. See section 6.20 of Rev. Proc. 2022-14. |
| 246 | Change in depreciation as a result of applying the additional first year depreciation regulations (section 168(k) and Regulations sections 1.168(k)-2 and 1.1502-68)—This change applies to an applicant within the scope of section 4 of Rev. Proc. 2020-50, 2020-48 I.R.B. 1122, that wants to change its method of accounting for depreciation under section 168 from an impermissible method to a permissible method to comply with Regulations section 1.168(k)-2 or 1.1502-68, as applicable, for depreciable property and specified plants within the scope of section 4 of Rev. Proc. 2020-50. An applicant qualifies for a reduced filing requirement. See section 4.03 of Rev. Proc. 2020-50 and section 6.21(3) of Rev. Proc. 2022-14. |
| 247 | Change in depreciation as a result of applying the additional first year depreciation regulations (section 168(k) and Regulations sections 1.168(k)-2 and 1.1502-68)—This change applies to an applicant within the scope of section 4 of Rev. Proc. 2020-50, 2020-48 I.R.B. 1122, that wants to change its method of accounting for depreciation under section 168 from a permissible method to another permissible method to comply with Regulations 1.168(k)-2 or 1.1502-68, as applicable, for depreciable property and specified plants within the scope of section 4 of Rev. Proc. 2020-50. An applicant qualifies for a reduced filing requirement. See section 4.04 of Rev. Proc. 2020-50 and section 6.21(4) of Rev. Proc. 2022-14.**Note.**This change is implemented on a cut-off basis. |
| 248 | Depreciation of tangible property under section 168(g) by CFCs—for a CFC (as defined in section 957(a)) that seeks to change its method of accounting for depreciation of an item of property that is described in section 168(g)(1)(A) (except for property excluded from the application of section 168 as a result of section 168(f)) and owned by the CFC at the beginning of the year of change to the permissible depreciation method, convention, and recovery period prescribed under the alternative depreciation system in section 168(g) for such property in determining the CFC’s gross and taxable income under section 1.952-2 as well as its earnings and profits under sections 964 and 986(b) and the regulations thereunder. This change is effective for a Form 3115 filed on or after May 11, 2021, for a tax year of a CFC ending before January 1, 2024. See section 6.22 of Rev. Proc. 2022-14. |
| 249 | Timing of incurring liabilities for commissions (section 461)—for an accrual method applicantto treat commissions as incurred in the tax year in which all events have occurred that establish the fact of the liability to pay a commission and the amount of the liability can be determined with reasonable accuracy.Note. This change does not apply to an applicant that is required under section 263A to capitalize the costs with respect to which the applicant wants to change its method of accounting if the applicant is not capitalizing these costs, unless the applicant concurrently changes its method to capitalize these costs. See section 20.01(4) of Rev. Proc. 2022-14. |
List of DCNs
| 250 | Changes in timing of income recognition related to Regulations section 1.451-3, other than cost offset (section 451) —for an accrual method applicant with an applicable financial statement (AFS)to (a) change to comply with Regulations section 1.451-3(b) to determine the amount of gross income that is taken into account as AFS revenue by making the AFS revenue adjustments provided in Regulations sections 1.451-3(b)(2)(i) or (ii) (including a change for specified credit card fees under Regulations sections 1.451-3(j)(2) and 1.1275-2(l)), (b) change to comply with the transaction price allocation rules in Regulations section 1.451-3(d),or (c) change to a method described in Regulations section 1.451-3(h)(4) when an applicant’s AFS covers mismatched reportable periods.Note. Some changes related to inventory sales may require netting of section 481(a) adjustments. A change to make the AFS revenue adjustments provided in Regulations sections 1.451-3(b)(2)(i) or (ii) applies only to tax years beginning before January 1, 2021, and to the applicant’s first, second, or third tax year beginning after December 31, 2020. See section 16.10 of Rev. Proc. 2022-14. |
|---|---|
| 251 | Changes in timing of income recognition related to cost offset, except concurrent cost-offset related inventory method changes (section 451)—for an accrual method applicant with an AFSto (a) applyor (b) not apply a cost offset method to determine the amount of an item of gross income from the sale of inventory that is required to be included in gross income under the AFS income inclusion rule in Regulations section 1.451-3(b).Note. An applicant that also needs to comply with Regulations section 1.451-3(c)(5)(ii) as a result of a concurrent cost-offset related inventory method may also need to make a change under DCN 255 for the same year of change. Some changes related to inventory sales may require netting of section 481(a) adjustments. See section 16.10 of Rev. Proc. 2022-14. |
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List of DCNs
| No. | Change |
|---|---|
| 252 | Changes in timing of income recognition related to the deferral method for advance payments (section 451)—for an applicant with an AFS to changeto (a) the deferral method provided in Regulations section 1.451-8(c), (b) the specified goods method described in Regulations section 1.451-8(f) when accounting for advance payments using the deferral method, (c) a method described in Regulations section 1.451-8(c)(7) when an applicant’s AFS covers mismatched reporting periods,or (d) comply with the payment allocation rules in Regulations section 1.451-8(c)(8). This change is also for applicants without an AFS to changeto (a) the deferral method provided in Regulations section 1.451-8(d)(3),or (b) a payment allocation method described in Regulations section 1.451-8(d)(4)(ii).Note. Some changes related to inventory sales may require netting of section 481(a) adjustments. See section 16.10 of Rev. Proc. 2022-14. |
| 253 | Changes in timing of income recognition related to advance payment cost offset, except concurrent cost-offset related inventory method changes (section 451)—for an applicant with or without an AFS to changeto (a) applyor (b) not apply an advance payment cost offset method to determine the amount of an advance payment from the sale of inventory that is required to be included in gross income under either the full inclusion method in Regulations section 1.451-8(b) or the deferral method in Regulations section 1.451-8(c), as applicable.Note. An applicant that also needs to comply with Regulations section 1.451-8(e)(8)(ii) as a result of a concurrent cost-offset related inventory method change may also need to make a change under DCN 255 for the same year of change. Some changes related to inventory sales may require netting of section 481(a) adjustments. See section 16.10 of Rev. Proc. 2022-14. |
| 254 | Changes in timing of income recognition related to the full inclusion method (section 451)—for an applicant to change to the full inclusion method provided in Regulations section 1.451-8(b)or, in the case of an applicant with an AFS, to changeto the specified goods method described in Regulations section 1.451-8(f) when accounting for advance payments using the full inclusion method.Note. Some changes related to inventory sales may require netting of section 481(a) adjustments. See section 16.10 of Rev. Proc. 2022-14. |
| 255 | Changes in timing of income recognition related to cost offsets resulting from concurrent cost-offset related inventory method changes (section 451)—for an applicant with an AFS to changeto comply with Regulations section 1.451-3(c)(5)(ii) or Regulations section 1.451-8(e)(8)(ii) as a result of a concurrent cost-offset related inventory method change or because the applicant determines its cost of goods in progress offset by reference to costs that the applicant has impermissibly capitalized and/ without an AFS to changeto comply with Regulations section 1.451-8(e)(8)(ii) as a result of a concurrent cost-offset related inventory method change or because the applicant determines its cost of goods in progress offset by reference to costs that the applicant has impermissibly capitalized and/ more than one change under DCN 255 for the same year of change may be required to net the section 481(a) adjustments in certain circumstances. This change requires a section 481(a) adjustment spread period that mirrors a corresponding cost-offset related inventory method change. In very limited situations, this change may be made on an amended return. See section 16.10 of Rev. Proc. 2022-14. |
| 256 | Timing of incurring inventory costs (section 461)—for an accrual method applicant to change its method for one or more inventory coststo treat such costs as incurred in accordance with Regulations sections 1.461-1(a)(2) and 1.461-4(d)(4) if certain conditions are met. This change must be made for an applicant’s early application year, or, if the applicant does not apply Regulations section 1.451-3 and/ beginning on or after January 1, 2021. See section 20.13 of Rev. Proc. 2022-14. |
| 257 | Change in overall method from the cash method to an accrual method for the mandatory section 448 year (section 446)—for an applicant that is required by section 448 to changefrom the overall cash methodto an overall accrual method in the applicant’s mandatory section 448 year. See section 15.01 of Rev. Proc. 2022-14. |
| 258 | Change in overall method from the cash method to an accrual method for a taxpayer subject to section 447 (section 446)—for an applicant subject to section 447 that is required by section 447 to changefrom the overall cash methodto an overall accrual method. See section 15.01 of Rev. Proc. 2022-14. |
| 259 | Accrual method for inventories, and the cash method for computing all other items of income and expense (section 446)— for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) changing to an accounting method in which a small business taxpayer uses an accrual method for purchases and sales of inventories and uses the cash method for computing all other items of income and expense. Complete certain lines of Schedule A, Part I, of Form 3115. See section 15.17 of Rev. Proc. 2022-14 |
List of DCNs
| 260 | Inventory exception for a small business taxpayer (section 471)—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) changing its section 471 inventory methodto the section 471(c) NIMS inventory method provided in Regulations section 1.471-1(b)(4). See section 22.18 of Rev. Proc. 2022-14. |
|---|---|
| 261 | Inventory exception for a small business taxpayer (section 471)—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) changing its accounting method for inventory items under section 471to one of the following methods: (a) the AFS section 471(c) inventory method provided in Regulations section 1.471-1(b)(5), for taxpayers with an AFS, as defined in Regulations section 1.471(b)(5)(ii); or (b) the non-AFS section 471(c) inventory method provided in Regulations section 1.471-1(b)(6), for taxpayers that do not have an AFS. See section 22.18 of Rev. Proc. 2022-14. |
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List of DCNs
| No. | Change |
|---|---|
| 262 | Changes within a section 471(c) inventory method—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) making changeswithin a section 471(c) inventory method. See section 22.19 of Rev. Proc. 2022-14.Note. This change does not receive audit protection. Additionally, reduced Form 3115 filing requirements apply to this change. |
| 263 | Change from a small business taxpayer section 471(c) inventory method to an inventory method under section 471(a)—for a qualifying applicant with average annual gross receipts of $25 million or less (adjusted for inflation) changing from using a small business taxpayer inventory method under section 471(c) inventory methodto an inventory method under section 471(a). See section 22.20 of Rev. Proc. 2022-14. |
| 264 | Certain late elections under sections 168(j)(3), 168(l)(3)(D), and 181(a)(1)—for an applicant making a late election (1) not to apply section 168(j) for qualified Indian reservation property placed in service after December 31, 2017, for its 2018 or 2019 tax year; (2) not to apply section 168(l) for qualified second generation biofuel plant property placed in service after December 31, 2017, for its 2018 or 2019 tax year; or (3) to apply section 181 to the production costs for its 2018 or 2019 tax year of any qualified film, television, or live theatrical production, commenced by the taxpayer after December 31, 2017. See section 6.23 of Rev. Proc. 2022-14. |
| 265 | Research and experimental expenditures (section 174)—to charging specified research or experimental expenditures to capital account and amortizing such expenditures over a 5- or 15-year period, as applicable. See section 7.02 of Rev. Proc. 2022-14.Note. For specified research or experimental expenditures paid or incurred in the first tax year beginning after December 31, 2021, this change is implemented on a cut-off basis. For specified research or experimental expenditures paid or incurred in any year of change later than the first tax year beginning after December 31, 2021, this change is implemented with a modified section 481(a) adjustment. This change applies to amounts paid or incurred in tax years beginning after December 31, 2021. For amounts paid or incurred in tax years beginning before January 1, 2022, see DCN 17. |
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