IRS modifies procedural guidance for section 174 method changes
The Treasury Department and the Internal Revenue Service on December 17 issued Rev. Proc. 2025-08, which modifies the automatic consent procedures for accounting method changes for section 174 specified research or experimental expenditures. Specifically, it expands the waiver of eligibility rules in Rev. Proc. 2015-13 to include changes made for taxable years beginning in 2022, 2023, or 2024, and permits taxpayers to use the automatic consent procedures regardless of whether the taxpayer made a change for the same item for any other taxable year beginning in 2022, 2023, or 2024.
This revenue procedure is effective for Forms 3115. Application for Change in Accounting Method, filed on or after December 17, 2024.
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Details on the revenue procedure are available in a new alert from Deloitte Tax LLP.
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