Application of the Tangible Property Regulations to Individuals

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The program will address how the recently issued final tangible property regulations apply to individuals, trusts and estates.   In general many (but not all) individuals, estates and trusts are subject to the tangible property regulations (TPR).  The final regulations do not include any provisions that exempt individuals, estates or trusts from the TPR.

The TPR – including any accounting method changes and relevant elections – apply to all individuals, estates or trusts that acquire tangible property or repair tangible property in a §162 or §212 activity reported on, but not necessarily limited to, a (i) Schedule C, Net Profit from Business (Sole Proprietorship), (ii) Schedule E, Supplemental Income and Loss, (iii) Schedule F, Profit or Loss From Farming, (iv) Form 8435, Farm Rental Income and Expenses, or (v) Form 2106, Employee Business Expenses (or Form 2106-EZ).  The TPR also apply to a not-for-profit activity (i.e., a hobby) to the extent the taxpayer acquires tangible property or repairs tangible property in the course of the activity and to the extent these expenses are deductible against the activity’s gross income under §183(b) and Reg. §1.183-1(b)(1) or otherwise are required to be capitalized under general accounting principles.

The program provides a general overview of the regulations, discusses their impact on affected taxpayers’ filing requirements, including exceptions from the filing requirements, and offers a practical approach to complying with the new regulations. Finally, the program will cover the application of the IRS’s recent attempt in Revenue Procedure 2015-20 to simplify the accounting method change aspect of the regulations.

Educational Objectives:
• General Understanding of the Application of Tangible Property Regulations to business activities undertaken by individuals, estates and trusts (typically reported on Schedule C, E, or F)
• Whether a Form 3115, Application for Change in Accounting Method, is needed to comply with the new regulations
• Application of the new regulations, including applicable elections, for tax year 2014 and thereafter 

Who would benefit most from attending this program?
Practitioners that have income tax compliance engagements with individuals, estates, and/or trusts.



David is an Executive Director in the National Tax Department of Ernst & Young LLP in Washington, DC. Throughout his career, David has focused primarily on the taxation of individuals, trusts, S corporations, and partnerships. 

Prior to joining Ernst & Young LLP in March 2014, David was an attorney in the Passthroughs and Special Industries division of the Office of Chief Counsel, Internal Revenue Service. Within Chief Counsel, David specialized in Federal income taxation of estates & trusts, S corporations, and partnerships (Subchapters J, K, and S of the Internal Revenue Code), and certain other tax matters of general applicability to individuals and estates & trusts. 

Before joining Chief Counsel, David was an associate in the tax practice of Arnold & Porter LLP in Washington, DC. Prior to joining Arnold & Porter LLP, David spent eight years in the Private Client Advisors group of Deloitte Tax LLP. 

David earned a Bachelor of Science in Accounting from Syracuse University and a J.D. from University of Pittsburgh. He also earned a LL.M. in Taxation from Georgetown University Law Center, and has served as an adjunct professor in the same program since 2009.   David is a Certified Financial Planner, Certified Public Accountant in the District of Columbia and a member of the Bar in the District of Columbia and Pennsylvania.


Scott is a Partner in the National Tax Department of Ernst & Young LLP in Washington, DC.  Throughout his career, Scott has focused primarily on federal income taxation, specializing in capitalization & cost recovery.
Before joining EY, Scott spent two plus years as a Taxation Specialist at the U.S. Treasury Department’s Office of Tax Policy.  At Treasury, Scott was responsible for developing and reviewing regulations and other published guidance, including leading the finalization of the Tangible Property Regulations (TPR) and several industry-specific capitalization safe harbors.   
Prior to Treasury, Scott was a member of the Washington National Tax Department of another Big 4 firm where he was responsible for quality assurance regarding federal tax accounting methods and periods, including drafting and reviewing tax opinions, technical memoranda, and IRS ruling requests.

Scott has a bachelor of business administration and a master’s degree of science in taxation from the University of Miami.  He is a Florida CPA and a member of the American Institute of Certified Public Accountants and the American Bar Association.