Cost Segregation

The IRS released Notice 2017-6, which better allows taxpayers to take advantage of the Tangible Property Regulations (TPRs). Taxpayers generally are not permitted to make an automatic method change if they made or requested a change for the same item during any of the five tax years ending with the year of change. This effectively prevents taxpayers from using the automatic change procedures to change the treatment of the same item more than once within a five-year period....

The IRS recently released an Audit Techniques Guide titled “Capitalization of Tangible Property”. Audit Techniques Guides (ATGs) help IRS examiners during audits by providing insight into issues unique to specific industries. While designed to provide guidance for IRS employees, these guides are useful to business owners and tax professionals as they are more reader-friendly than the code and regulations, and they often discuss the implications of case law as well as other relevant authorities....