Rev. Proc. 2024-34: Expanded waiver of eligibility rules to accounting method changes to address short tax years
Obtaining automatic consent to change accounting methods for expenditures paid or incurred in tax years starting after December 31, 2021
The IRS today released Rev. Proc. 2024-34 to modify procedures under section 446 for obtaining automatic consent to change accounting methods for expenditures paid or incurred in tax years starting after December 31, 2021.
Specifically, the revenue procedure:
- Expands the waiver of the eligibility rules in Rev. Proc. 2015-13 to accounting method changes described in Rev. Proc. 2024-23 that are made in any tax year beginning in 2022 or 2023
- Permits a taxpayer to make changes under Rev. Proc. 2024-23 regardless of whether a change under that section has been filed for any other tax year beginning in 2022 or 2023
In addition, for any change under Rev. Proc. 2024-23 made in a tax year beginning in 2022 or 2023 (other than the first tax year beginning after December 31, 2021), Rev. Proc 2024-34 limits audit protection for research or experimental expenditures paid or incurred in the taxpayer’s first tax year beginning after December 31, 2021, if the taxpayer failed to make a change for such expenditures for such tax year.