The IRS has released Rev. Proc. 2021-26 which modified its automatic consent procedures in Rev. Proc. 2019-43 , I.R.B. 2019-48, 1107, to allow certain foreign corporations to change their method of accounting for deprecation to the alternative depreciation system under Code Sec. 168(g) (ADS). Additionally, terms and conditions in Rev. Proc. 2015-13 , I.R.B. 2015-5, 419 (related to the source, separate limitation classification, and character of Code Sec. 481(a) adjustments) are revised. Finally, this revenue procedure modifies Rev. Proc. 2015-13 , I.R.B. 2015-5, 419, to clarify an existing rule that limits audit protection with respect to certain foreign corporations.
Posted by Jessica Ji, Associate Editor, Wealth Strategies Journal.