BDO has published an article, “IRS Streamlines Automatic Consent Procedures For CFC Depreciation Method Changes, Clarifies Treatment Of Catch-Up Adjustment,” which discusses new filing procedures released by the IRS for certain foreign corporations (CFCs). The article begins as follows:
On May 11, 2021, the IRS and Treasury released Rev. Proc. 2021-26, which provides streamlined filing procedures for certain foreign corporations to obtain automatic consent to change their methods of accounting for depreciation to the alternative depreciation system (ADS) under Section 168(g). The guidance also provides additional terms and conditions applicable to Section 481(a) adjustments arising from accounting method changes of certain foreign corporations (CFC) and clarifies the applicability of an existing rule that limits audit protection with respect to certain foreign corporations.
Posted by Anthony Tran, Associate Editor, Wealth Strategies Journal