Internal Revenue Bulletin: 2017-15
April 10, 2017
Table of Contents
Nonacquiescence to the holding that buildings built to operate as retail stores are placed in service for depreciation purposes when substantially completed to house and secure racks, shelving and merchandise.
Nonacquiescence to the holding that, under the completed contract method of accounting, taxpayer completed a home construction contract when it incurred 95 percent of the estimated cost of constructing an entire development.
This Announcement is issued pursuant to § 521(b) of Pub. L. 106–170, the Ticket to Work and Work Incentives Improvement Act of 1999, which requires the Secretary of the Treasury to report annually to the public concerning advance pricing agreements (APAs) and the Advance Pricing and Mutual Agreement Program (APMA Program), formerly known as the Advance Pricing Agreement Program (APA Program). The first report covered calendar years 1991 through 1999. Subsequent reports covered each calendar year 2000 through 2015 separately. This eighteenth report describes the experience, structure, and activities of the APMA Program during calendar year 2016. It does not provide guidance regarding the application of the arm’s length standard.
This notice invites comments on a proposed revenue procedure that, if finalized, will provide procedures by which a taxpayer may request consent to change a method of accounting for recognizing income when the change is made for the same taxable year for which the taxpayer adopts the new financial accounting revenue recognition standards and the change is made as a result of, or directly related to, the adoption of the new revenue recognition standards.
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