Rev. Proc. 2015-13 for such change if, at
Internal Revenue Bulletin 2023-28 · 2026-10-03 edition · updated 2026-10-04 · United States
the time of filing, the taxpayer’s method of accounting for the item being changed by the corresponding cost-offset related inventory method change, as defined in section 5.06 of Rev. Proc. 2015-13 (or successor), is an issue under consideration for the taxable year under examination. However, if the taxpayer ultimately receives audit protection for the corresponding cost-offset related inventory method change under section 8.02(1)(f) of Rev. Proc. 2015-13, then the preceding sentence does not apply and the normal audit protection rules in section 8 of Rev. Proc. 2015-13 apply.
(7) Concurrent automatic changes . (a) Changes under this section 16.08 . A taxpayer that wants to make one or more concurrent changes in method of accounting under this section 16.08 and a change in overall method of accounting to an accrual method under section 15.01 of this revenue procedure for the same year of change may file a single Form 3115 that includes all of the changes. Except as otherwise required by section 16.08(4)(b) (ii) of this revenue procedure, the taxpayer may not net the § 481(a) adjustment from one change with the § 481(a) adjustment from another change, and must separately state the § 481(a) adjustment for each change. If a taxpayer makes a concurrent change in method of accounting to allocate transaction price and/or payments under section 16.08(2)(a)(i), (ii), or section 16.08(2)(b) of this revenue procedure, the taxpayer is required to make the allocation change before any other change described in section 16.08(2)(a)(i), (ii), or section 16.08(2)(b) of this revenue procedure, as applicable.
(b) Concurrent cost offset change and cost-offset related inventory method change . See section 6.03(1)(b) of Rev.
| Changes related to § 1.451-3 other than cost offset | 16.08(2)(a)(i)(A), (B), (F), (G) | 250 |
|---|---|---|
| Changes related to cost offset under § 1.451-3, except concurrent cost-offset related inventory method changes |
16.08(2)(a)(i)(C), (D) | 251 |
| Changes related to the deferral method for advance payments - § 1.451-8 other than cost offset |
16.08(2)(a)(ii)(B), (C), (G) and (H), 16.08(2)(b) (ii) or (vi) |
252 |
| Changes related to cost offset under § 1.451-8, except concurrent cost-offset related inventory method changes |
16.08(2)(a)(ii)(D), (E), 16.08(2)(b)(iii) or (iv) | 253 |
| Changes related to full-inclusion method under § 1.451-8(b) | 16.08(2)(a)(ii)(A) and (C), 16.08(2)(b)(i) | 254 |
| Changes related to cost offsets resulting from concurrent cost- offset related inventory changes |
16.08(2)(a)(i)(E), 16.08(2)(a)(ii)(F), and 16.08(2) (b)(v)(E) |
255 |
Bulletin No. 2023–28 1293 July 10, 2023
(10) Contact information . For further information regarding a change under this section, contact Sharon Horn at (202) 317-7003 (not a toll-free number). For further information regarding a change under this section for OID and specified fees (including specified credit card fees), contact Chris Lieu at (202) 317-6945 (not a toll-free number).
Get a plain-English answer with a citation back to this text.
Ask AI about this code