Bulletin No. 2014–9 February 24, 2014

the 2014 calendar year (1) state housing credit ceiling under section 42(h) of the Code, (2) private activity bond volume cap under section 146, and (3) private activity bond volume limit under section 142(k) are reproduced.

Rev. Proc. 2014–16, page 606. Rev. Proc. 2014–16 provides the procedures by which a taxpayer may obtain the automatic consent of the Commissioner of Internal Revenue to change to certain methods of accounting for amounts paid to acquire, produce, or improve tangible property, as well as to change to a reasonable method described in § 1.126A–1(f)(4) for self-constructed assets. The revenue procedure also provides the procedures for changing to a permissible method of accounting under section 263A(b)(2) and § 1.263–3(a)(1) for certain costs related to real property acquired through foreclosure or another similar transaction. Finally, the revenue procedure modifies section 3.09 of the APPENDIX to Rev. Proc. 2011–14 regarding a change to the method of accounting described in Rev. Proc. 2011–43 for taxpayers in the business of transporting, delivering, or selling electricity.

Rev. Proc. 2014–20, page 614. This revenue procedure provides a safe harbor under which the Internal Revenue Service will, under certain, defined circumstances, treat indebtedness that is secured by 100 percent of the ownership interest in a disregarded entity that holds real property as indebtedness that is secured by real property for purposes of § 108(c)(3)(A) of the Internal Revenue Code. This revenue procedure will assist taxpayers with so-called “mezzanine” financing in workouts and similar circumstances.