* A consolidated group member changing to
or from a 52-53-week tax year is not eligible for automatic consent for such change, unless the requested year is identical to the consolidated group's tax year.
20, which required that changes in accounting principle generally be recognized by including the cumulative effect of changing to
a new accounting principle on the last line prior to net income (that is, a current-period approach).
He argued that even after Supreme Court cases, the IRS has to consent to taxpayers changing to
the treatment the Court approves.
2006-12 only applies to taxpayers changing to
an accounting method provided under the Sec: 263(a) regulations; it does not apply to taxpayers changing their method using the economic performance 3 1/2-month rule or recurring-item exception.
If a taxpayer is changing to
the pool-of-costs method to account for package design costs, the section 481(a) adjustment equals all package design costs deducted or amortized in years prior to the year of change, less the amount that would have been amortized if the pool-of-costs method had been used in such years.
* A taxpayer terminating its section 444 election and changing to
its required tax year must follow the procedures described in section 1.444-1T(a)(5) of the regulations.
In lieu of providing the information and documentation required by Form 3115, Line 1, Schedule B, a taxpayer changing to
the deferral method must:
Taxpayers changing to
the CAV method must compute a Sec.
* A partnership, S corporation, electing S corporation or PSC changing to
a natural business year that satisfies the 25%-gross-receipts test, regardless of whether such year results in a greater income deferral than in the present tax year.
An automatic change is available to a corporation making an S election effective for the tax year immediately following a change in tax year if the corporation is changing to
a permitted year (defined as a calendar year, a tax year permitted under Sec.
98-60, provided the taxpayer is changing to
the "retail safe-harbor method" or from not currently deducting estimated shrinkage to a method of estimating inventory shrinkage that clearly reflects income.