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This procedure expands, for a limited period, the availability of automatic consent for controlled foreign corporations (“CFCs”) to change their methods of accounting for depreciation to the alternative depreciation system under section 168(g) in order to ease the burden on CFCs of conforming their income and earnings and profits computations with their qualified business asset investment computations. This procedure also prescribes terms and conditions for accounting method changes made on behalf of CFCs, to ensure that section 481(a) adjustments resulting from CFCs’ method changes are properly included in computations of tested income and tested loss. Finally, this procedure clarifies the audit protection rule in section 8.02(5) of Rev. Proc. 2015-13.
26 CFR 601.204: Changes in accounting periods and in methods of accounting.
(Also Part I, §§ 167, 168, 446, 481, 951A, 954, 964, 986; 1.446-1, 1.481-1, 1.951A-3, 1.952-2, 1.964-1.)
This Announcement announces that the new or updated census tract boundaries and numbers adopted by the U.S. Census Bureau for purposes of the 2020 decennial census have no effect on the boundaries or tract numbers of any qualified opportunity zone listed in Notice 2018-48, 2018-28 I.R.B. 9, or Notice 2019-42, 2019-29 I.R.B. 352.
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