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IRS Revises Revenue Procedure for Automatic Consent to Change Method of Accounting—Text of Rev. Proc. 2008-52
The IRS today released an advance copy of Rev. Proc. 2008-52 which sets forth the procedures by which a taxpayer may obtain the automatic consent of the IRS Commissioner for certain changes in method of accounting (listed in the appendix to today’s 282-page revenue procedure). A taxpayer complying with the applicable provisions of today’s guidance is deemed to have obtained the consent of the Commissioner to change its method of accounting under section 446(e).
Rev. Proc. 2008-52:
- Clarifies, modifies, amplifies, and supersedes Rev. Proc. 2002-9 (as modified, clarified, and amplified by Announcement 2002-17, Rev. Proc. 2002-19, and Rev. Proc. 2002-54)
- Consolidates automatic consent procedures for changes in several methods of accounting that were published after Rev. Proc. 2002-9
- Provides additional changes in methods of accounting for which a taxpayer may obtain automatic consent
For an electronic version of today’s guidance (282 pages):
Rev. Proc. 2008-52
To see a list of significant changes from the earlier IRS guidance, click
here.
Effective Date
Rev. Proc. 2008-52 (except as otherwise provided) generally is effective for applications filed on or after August 18, 2008, for a year of change ending on or after December 31, 2007.
The IRS will return any application that is filed with the National Office after August 18, 2008, for a year of change ending on or after December 31, 2007, if the application is filed pursuant to the Code, regulations, or other guidance published in the Internal Revenue Bulletin other than this revenue procedure and the change in method of accounting appears to be within the scope of Rev. Proc. 2008-52.
Rev. Proc. 2008-52 also provides certain transition rules for certain applications properly filed under either Rev. Proc. 97-27 or Rev. Proc. 2002-9.
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Rev. Proc. 2008-52 will appear in Internal Revenue Bulletin 2008-36 dated September 8, 2008.
For more information, contact Rick Speizman, National Partner-In-Charge, KPMG’s Exempt Organizations Tax Practice (ExoTax), at (202) 533-3084 or
rspeizma@kpmg.com
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