898; (2) it is changing to a required tax year, a 52-53-week tax year referencing such required year, the one-month deferral year or a 52-53-week year referencing the one-month deferral year; or (3) for post-July 10, 1989 tax years of the CFC, no U.S.
* A CFC changing to the required tax year, a 52-53-week tax year referencing such required year, the one-month deferral year or a 52-53-week year referencing the one-month deferral year, is not required to file Form 1128.
[sections][sections] 1.446-1(e)(2)(iii), Example (3) (accrual method taxpayer properly deducting unvested vacation pay in the year it is paid; changing to
the accrual method when the taxpayer adopts a completely vested vacation pay plan is not a change in method of accounting); and Example (4) (taxpayer allocating indirect overhead costs to inventory using a fixed percentage of direct costs; changing the percentage when the ratio of indirect to direct costs changes is not a change in method of accounting).
Generally, taxpayers changing to the pool-of-costs method must include the total amount of the section 481(a) adjustment in the calculation of taxable income in the year of change.
Generally, taxpayers changing to the design-by-design method must include the total amount of the section 481(a) adjustment in the calculation of taxable income for the year of change.
The ownership tax year test allows an S corporation to use a fiscal tax year if the same year is used by shareholders holding more than one-half of the issued and outstanding stock (as of the first day of the tax year to which the request relates) or if these shareholders also are changing to the tax year desired by the S corporation.
Taxpayers changing to the overall accrual method must compute an adjustment under IRC section 481(a) to prevent items from being duplicated or omitted when the change is made.
In lieu of providing the information and documentation required by Form 3115, Schedule B, Line 1, taxpayers changing to
the deferral method must:
Taxpayers changing to
the CAV method will receive audit protection for all prior years.
A taxpayer changing to a self-developed method must demonstrate that the method clearly reflects income.
* A taxpayer not currently under examination (or a taxpayer under examination if the shrinkage issue is not an issue under consideration) does receive audit protection for prior years on changing to the retail safe harbor method.
Ace is considering changing to a calendar year to allow more efficient reconciliations and comparisons of its records to the records of its two brother-sister corporations.
A year-end change will be automatically approved by the Service if the corporation is entering an affiliated group that files a consolidated return and is changing to conform to the group's year-end.
In general, this automatic consent procedure applies to any taxpayer changing to
a permissible method of accounting for depreciation for any item of property that: 1.