SECTION 7. CHANGE IN METHOD

OF ACCOUNTING

.01 In general . (1) Except as provided in section 7.01(2) of this revenue procedure, a change to the recovery periods described in section 5 of this revenue procedure and any collateral change to the depreciation methods for all, or some of, the assets listed in that section are a change in method of accounting to which §§ 446(e) and 481 apply. See § 1.446–1(e)(2)(ii)( d )( 2 ). A taxpayer that wants to change to a method of accounting described in this revenue procedure must use the automatic change in method of accounting provisions in Rev. Proc. 2011–14, 2011–4 I.R.B. 330, or its successor, as modified by this revenue procedure.

(2) If a taxpayer placed in service assets listed in section 5 of this revenue procedure in a taxable year ending before December 30, 2003 (pre-2003 assets), the taxpayer may treat the change to the recovery periods described in section 5 of this revenue procedure and any collateral change to the depreciation methods for all, or some of, the pre-2003 assets as not a change in method of accounting and, therefore, the taxpayer files amended federal tax returns to implement the change in computing depreciation for these pre-2003 assets.

.02 Automatic change . Rev. Proc. 2011–14 is modified to add new section 6.26 to the APPENDIX, to read as follows: .26 Safe harbor method of accounting for determining the depreciation of certain tangible assets used by wireless telecommunications carriers under Rev. Proc. 2011–22. (1) Description of change . This change applies to a taxpayer that is within the scope of Rev. Proc. 2011–22 and wants to change to the recovery periods described

May 2, 2011 739 2011–18 I.R.B.

wireline network assets (as described in section 4 of this revenue procedure) used primarily to provide wireline telecommunication or broadband services. This revenue procedure does not apply to a taxpayer that is primarily a cable operator. The determination of whether a taxpayer is within the scope of this revenue procedure is made by each member of a consolidated group, by a partnership, or by an S corporation.