— A revenue procedure providing changes to the early application of proposed
disposition of tangible property rules (REG-110732-13) should be out by the end
of February, a Treasury Department official said.
The Internal Revenue
Service issued reproposed tangible property disposition rules in September to
accompany final rules (T.D. 9636) on how taxpayers may deduct or capitalize
their expenses for maintaining, fixing and replacing tangible property.
The forthcoming Revenue Procedure 2014-17 “will not look quite as simplified,
for lack of a better term, as 2014-16,” said Scott Mackay, a tax specialist in
the Office of Tax Policy, referring to guidance issued Jan. 24 on early
adoption of the final “repair regulations”. Mackay spoke Feb. 10 during a
Deloitte LLP Dbriefs Federal Tax series webinar.
Though the regulatory
drafters looked for areas to simplify compliance, “unfortunately, this one has
a lot of coordination built into it,” Mackay said. The guidance will explain
what taxpayers who have already made changes based on the temporary regulations
will have to do to conform with the reproposed rules, he said.
it incorporates temporary reg changes as well we've built it so that
ultimately, when we release the final rules, we can drop out the reproposed and
you'll still have the ability to use the temp reg regime for your 2013 year,”
The final regulatory package could be issued in late April
or early May, with an update to Rev. Proc. 2014-17 likely “shortly thereafter,”
Mackay said. “We don't expect to make a lot of substantive changes,” with the
update consisting primarily of a citation update providing certain
clarifications, he said.
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