Comments on: How to Prepare Form 3115 for the New Tangible Property Regs

By: Steve

Steve — Thu, 16 Mar 2017 17:47:49 +0000

In reply to Steve.

Steve

March 10, 2017 at 12:16 pm

Been reading your blog long enough to know you doubt necessity of de minimis safe harbor from Rev Proc 2015-20. I get from where your coming.

None the less, we farm. We filed March 1, 2017 for 2016 return – as to not be required to prepay estimated taxes. Hurrying to file, left off from tax return the printed de minimus election, which meets written policy. Question on necessity not withstanding, in your opinion, could the election still be submitted someway that would not cause more risk than benefit?

Know of no one whom has researched TPR as much as you – so thanks for sharing.

By: Steve

Steve — Fri, 10 Mar 2017 20:16:55 +0000

Been reading your blog long enough to know you doubt necessity of de minimis safe harbor from Rev Proc 2015-20. I get from where your coming.

Know of no one whom has researched TPR as much as you – so thanks for sharing.

By: Steve

Steve — Thu, 09 Mar 2017 00:15:45 +0000

In reply to Steve. This TPR stuff is supposed to handled in a timely fashion in order to get automatic consent... You might look carefully at whether you needed to actually make the election on the return you reference...

By: Steve

Steve — Tue, 07 Mar 2017 20:52:06 +0000

Hi Steve. Been reading your blog for years. Enjoy much – thank you. Question for you on the tangible property regs.; I haven’t seen it answered elsewhere. If a self-employed taxpayer errantly sends in tax return without the de minimis safe harbor election and/or the safe harbor election for small taxpayers, can the election(s) be sent in a separate mailing with reference to the original tax return or should/could it be sent with an amended tax return? IRS FAQ on TPR only mentions the elections with regard to the “timely filed original tax returns”. Hoping that doesn’t mean a left off election can never be added. Thanks again for your business help over the years. Steve

By: Bea Beaubiennsu

Bea Beaubiennsu — Thu, 17 Sep 2015 22:17:39 +0000

In reply to Steve. Single member LLC, disregarded entities, should still have a separate identification number to ensure the recognition of that the entity us separate & apart from your personal assets.

By: Steve

Steve — Wed, 09 Sep 2015 17:35:47 +0000

In reply to Karen. Thanks Karen for kind words. As far as accounting method changes, I think some of the lists one sees aren't updated for the TPRs... which is kind of ironic. You can get the new codes in Rev. Proc. 2014-16 among other places.

By: Karen

Karen — Wed, 09 Sep 2015 15:55:29 +0000

I notice in your article reference to “code 184” change. Are you referring to the “List of Automatic Accounting Method Changes”. If so, all of the filing instructions that I can locate for the form 3115 only list 180 automatic changes. Am I reading this incorrectly? Are there updated 3115 instructions? By the way, this article has helped me more than the other readings I have done and 2 seminars that I attended. Thank you!

By: Steve

Steve — Fri, 04 Sep 2015 22:21:17 +0000

In reply to Jenny. Sorry, that's really a GAAP question and not a tax question. (We're a tax firm.)

By: Tom

Tom — Thu, 03 Sep 2015 17:15:10 +0000

I need to amend my prior comments. I only identified 2 issues in the example, not 3 elections as I stated. I concur that the safe harbor routine maintenance is a change in method; the IRS FAQ states that. However, the Small Taxpayer Safe Harbor is an annual election; the IRS FAQ states that and specifically says to not use 3115 for this.
Please accept my apology for the error.

By: Tom

Tom — Wed, 02 Sep 2015 01:44:49 +0000

The sample “Proposed Method” presented in narrative near the top of this page refers to safe harbors three (3) times in describing new accounting policies. I have seen elsewhere that these safe harbors are actually annual elections, not accounting policies. If these are in fact annual elections, is this the correct place to state them as policies? By doing so it would seem that we have now made what are intended to be annual decisions into formal policies, such that to NOT make the election in a given year where eligible would be a change in policy requiring a 3115 in the year the election is not made. Can you clarify if these are in fact annual elections and, if so, should we perhaps approach this wording differently? I suppose if you assume that the elections would be utilized every year possible this is no issue, but the question still remains if this is the appropriate place to cite these elections.
I have narrowed my need for a 3115 to 4, issues: Repairs, to indicate compliance with new regs in general; capitalization policy; identification of UOP for real estate indicating compliance with 9 building systems as distinct UOP (these 2 I think can be done as one change under 184); and
supplies (187) – we probably mostly comply already but will file to indicate that we will follow new regs regardless.
Postings to date indicate that I will only find help with Repairs/Capitalization in the book. Have there been any additions that will give an example of a 3115 and attached narrative of changes for Supplies or UOP changes?