Update on repair regulations -...

Update on repair regulations

NCFC Legal, Tax & Accounting Conference

February 8, 2013

© 2013 KPMG LLP, a Delaware limited liability partnership and the U.S. member firm of the KPMG network of independent member firms affiliated with KPMG International Cooperative (“KPMG International”), a Swiss entity. All rights reserved. NDPPS 142311

1

Notice

ANY TAX ADVICE IN THIS COMMUNICATION IS NOT INTENDED OR WRITTEN BY KPMG TO BE USED, AND CANNOT BE USED, BY A CLIENT OR ANY OTHER PERSON OR ENTITY FOR THE PURPOSE OF (i) AVOIDING PENALTIES THAT MAY BE IMPOSED ON ANY TAXPAYER OR (ii) PROMOTING, MARKETING OR RECOMMENDING TO ANOTHER PARTY ANY MATTERS ADDRESSED HEREIN.

You (and your employees, representatives, or agents) may disclose to any and all persons, without limitation, the tax treatment or tax structure, or both, of any transaction described in the associated materials we provide to you, including, but not limited to, any tax opinions, memoranda, or other tax analyses contained in those materials.

The information contained herein is of a general nature and based on authorities that are subject to change. Applicability of the information to specific situations should be determined through consultation with your tax adviser.

These materials are copyrighted to the company of the presenter presenting them.


2

The tangible property regulations

Organization of regulations – three “buckets”

Acquisition costs

– De minimis rule

– Materials and supplies

– Transaction costs

Repair and maintenance costs

– Unit of property

– Capitalization standards

Dispositions

– Building structural components

– General asset accounts


3

Background and update

Regulations are both temporary and proposed

2006 and 2008 proposed regulations withdrawn

– Some companies filed very favorable method changes through December 31, 2011

2011 temporary & proposed regulations issued December 23, 2011

Notice 2012-73 – November 20, 2012

– Temporary – now effective for first tax year beginning on or after January 1, 2014

Early adoption permitted for tax years beginning on or after January 1, 2012

– Proposed – certain sections will likely be modified

– Final – expect to be issued in 2013 and effective for tax years beginning on or after January 1, 2014

Two-year window for filing automatic consent method changes

Form 3115 Automatic Method Changes permitted for tax years beginning after Dec 31, 2011

– See Rev. Proc. 2012-19 and Rev. Proc. 2012-20


4

Background and update (continued)

LB&I stand down order

LB&I directive LB&I-4-0312-004 (issued March 15, 2012)

– Agents directed to discontinue exam activity for tax years beginning before Jan 1, 2012

– Agents directed not to examine issues for tax years beginning after Dec 31, 2011 but before Jan 1, 2014 (but will perform risk assessments on Form 3115s filed for possible exam)

– Time intended for taxpayers to file required method change during 2012-2013 to comply with temporary regulations. Will IRS extend stand down order into 2014?

– Agents will apply normal exam procedures for tax years beginning on or after 1/1/2014

Expected changes in final regulations from current temporary regulations

Notice 2012-73 identified the following:

– Numerous written comments were received and public hearing held 5/9/2012

– Treasury may revise de minimis rule, dispositions, safe harbor for Routine Maintenance

– Revisions will take into consideration comments including request for small business relief

Practitioners also anticipate changes to rules for dispositions of structural components of buildings, which may eliminate the need to make a general asset account election for building property


5

Background and update (continued)

Form 3115 Method Change Considerations (Automatic Change under Rev. Proc. 2011-14)

Generally favorable (negative) 481(a) adjustments taken into account in one year

Generally unfavorable (positive) 481(a) adjustments taken into account in four years

Cooperatives: Rev. Proc. 2011-14 refers to Rev. Rul. 79-45. (generally must take entire 481(a) adjustment into account in one year). (R.R. dealt with LIFO to FIFO change)

– Might a cooperative apply normal four year period for non-patronage income? What about a cooperative that distributes on a book basis and is not changing book accounting method?

Industry specific guidance in progress:

Power Generation

Gas Pipeline

Cable Companies

Retail Industry (National Retail Federation and Retail Industry Leaders Association)

Starting a “New Tangible Property Regulations Project” One Approach

© 2013 Countrymark Cooperative Holding Corp. All rights reserved.


7

One approach

We started with gaining a good understanding of what we are ACTUALLY doing now:

With the balance sheet accounts (capitalized assets);

In the P&L accounts (expense of items).

Capitalized items



9

Detail from fixed asset ledger

Sys No Decription Co Asset No Location In Svc DateAcquired

Value005088 TANK 17 REPAIRS 360 51190 11/1/2007 485,438.61 005308 TANK 25 GASOLINE STORAGE TANK RECONSTRUCTION 226-09 51190 9/1/2009 350,388.28 005926 Tank #3 Repairs CER1076 51190 6/30/2012 347,234.42 005098 REFINERY OFFICE 364 51190 12/1/2007 297,807.21 005111 FCC WYE REPLACEMENT 379 51190 1/1/2008 246,414.74 005112 FCC ORIFICE CHAMBER REPLACEMENT 380 51190 1/1/2008 243,763.99 005044 TANK 25 REPAIRS INCLUDING FLOATING ROOF, ANNULAR RING, PIPING NOZZLES 374 51190 10/1/2007 231,212.83 005140 TANK 19 INTERNAL FLOATING ROOF AND REPAIRS 388 51190 4/1/2008 220,143.60 004778 520-H-104 REHEATER 304 51190 6/1/2006 217,967.73 005693 LSG GROUND PAVING 203-08 51190 7/1/2010 210,722.00 005925 Crude Vapor Heat Exchanger Replacement (200-E-101) CER1031 51234 6/30/2012 199,490.14 n/a EQ Acq: Lease Sims Field - Tank Battery 109 5/1/2010 122,600.00 005413 PIPELINE REPLACEMENT 631 51234 12/1/2009 121,855.72 n/a Greathouse 1H: longstring casing 31 1/31/2010 45,265.67 n/a 2005 Freightliner replace Unit #4 150 4/28/2011 27,360.00 n/a 346 Engine rebuild 30 8/31/2010 5,635.29



10

ASSET N0. 360 CER Description of activity

Tank 17 Repairs

Explanation:

Tank 17 is a 25,000 bbl storage tank for gas oil…which will be taken out of service for repair in March, 2007. An API inspection will be performed in addition to inspecting and possibly replacing the floor…and upgrading the manways and nozzles to meet present code requirements.



11

ASSET N0. 360 CER Description of activity

Most of the described expenditures appear to be routine maintenance.

The “upgrades to meet code” may need to be capitalized.



12

Detail from fixed asset ledger

Sys No Decription Co Asset No Location In Svc DateAcquired

Value005088 TANK 17 REPAIRS 360 51190 11/1/2007 485,438.61 005308 TANK 25 GASOLINE STORAGE TANK RECONSTRUCTION 226-09 51190 9/1/2009 350,388.28 005926 Tank #3 Repairs CER1076 51190 6/30/2012 347,234.42 005098 REFINERY OFFICE 364 51190 12/1/2007 297,807.21 005111 FCC WYE REPLACEMENT 379 51190 1/1/2008 246,414.74 005112 FCC ORIFICE CHAMBER REPLACEMENT 380 51190 1/1/2008 243,763.99 005044 TANK 25 REPAIRS INCLUDING FLOATING ROOF, ANNULAR RING, PIPING NOZZLES 374 51190 10/1/2007 231,212.83 005140 TANK 19 INTERNAL FLOATING ROOF AND REPAIRS 388 51190 4/1/2008 220,143.60 004778 520-H-104 REHEATER 304 51190 6/1/2006 217,967.73 005693 LSG GROUND PAVING 203-08 51190 7/1/2010 210,722.00 005925 Crude Vapor Heat Exchanger Replacement (200-E-101) CER1031 51234 6/30/2012 199,490.14 n/a EQ Acq: Lease Sims Field - Tank Battery 109 5/1/2010 122,600.00 005413 PIPELINE REPLACEMENT 631 51234 12/1/2009 121,855.72 n/a Greathouse 1H: longstring casing 31 1/31/2010 45,265.67 n/a 2005 Freightliner replace Unit #4 150 4/28/2011 27,360.00 n/a 346 Engine rebuild 30 8/31/2010 5,635.29



13

ASSET N0. 379 and 380 CER Description of activity

FCC Wye Replacement

This CER is for material and labor to replace the Wye in the FCC.

FCC Orifice Chamber Replacement

The purpose of the orifice chamber is to hold back pressure on the regenerator in the FCC.



14

ASSET N0. 379 and 380 CER Description of activity

The FCC is a “unit of property” in that it can work independently, therefore the replacement of components may qualify as routine maintenance.

Expense of items



16

Expense of items

What are we looking for?

Where do we look?



17

Expense of items

What are we looking for:

Repairs and maintenance costs

Items costing less than $100, consumables, supplies, items with a life of 12 months or less

Incidental materials and supplies – no inventory or record of consumption is maintained

Rotable and temporary spare parts

Non-incidental materials and supplies – an inventory or record of consumption is maintained

Capital items



18

Expense of items

Where are we looking?

Repairs

– 71003250 - Vehicle R&M

– 71003050 - Plant R&M

– 71003000 - Building R&M

Materials and Supplies

– 73000225 - Operating Supplies, Small Tool

– 73000215 - Operating Supplies, Plant

– 73000100 - Office Supplies/Equipment

– 71004100 - Vehicle Operation, Tires



19

Expense of items

What do we find?

Account Desc Description Amount InvoiceNum InvoiceDateRepairs & Maintenance Exp Airgas Mid America|Rental - Acetylene, argon, nitrogen, o 88.60 111728732 6/30/2011Repairs & Maintenance Exp Stinson Brothers Welding Service, Inc.|repaired mud pum 9,852.40 89412 7/11/2011Repairs & Maintenance Exp Stinson Brothers Welding Service, Inc.|made 4 chemical p 360.40 89704 7/18/2011Repairs & Maintenance Exp Airgas Mid America|1 nitrogen cylinder 41.15 111486274 7/26/2011Repairs & Maintenance Exp Airgas Mid America|Cylinder rental: acetylene, argon, nit 90.39 111752835 7/31/2011Repairs & Maintenance Exp Earl's Tank Truck Service, Inc.|Fort Branch Yard|clean 1 -21 297.58 16234 8/3/2011Repairs & Maintenance Exp VIP Cleaning Service Company, Inc.|trash can liners 35.00 9353 8/17/2011Repairs & Maintenance Exp Stinson Brothers Welding Service, Inc.|Ft Branch Yard|we 540.00 89583 8/10/2011Repairs & Maintenance Exp Memmer's Farm Store|Blade kit, 12 pk poly cut blades, sti 41.40 091203-0026 9/12/2011Repairs & Maintenance Exp Airgas Mid America|1 oxygen cylinder 88.60 111801886 9/30/2011Repairs & Maintenance Exp Earl's Tank Truck Service, Inc.|Gibson County Hwy|Spread 1,402.50 16483 9/22/2011Repairs & Maintenance Exp Earl's Tank Truck Service, Inc.|Gibson County Hwy|Spread 1,870.00 18834 9/30/2011Repairs & Maintenance Exp Airgas Mid America|acetylene surcharge 21.14 111686349 10/18/2011Repairs & Maintenance Exp Airgas Mid America|acetylene, nitogen, oxygen|cylinders 90.39 111826769 10/31/2011Repairs & Maintenance Exp Romain Cross Point Auto Park|Unit 36|Full detail 139.95 321953 11/4/2011



20

Expense of items, (continued)

Vehicle Repairs Kim Hamilton|Unit #79|oil & oil filter- service 40.34 5680 1/12/2011Vehicle Repairs Kim Hamilton|Unit # 41|alignment, ball & jon 1,376.94 5697 1/14/2011Vehicle Repairs ACT Automotive & Tire|Unit #51|brake pads, 246.10 50558 1/18/2011Vehicle Repairs NAPA Auto Parts|battery 209.70 651325 1/18/2011Vehicle Repairs Hargis Glass Plus, Inc.|Unit #79|windshield re 50.00 2571 1/19/2011Vehicle Repairs ACT Automotive & Tire|Unit #51|oil & filter-s 31.98 50623 1/20/2011Vehicle Repairs Robertson Welding & Repair Shop, LLC|Truck 437.42 113381 1/21/2011Vehicle Repairs Flora Auto PArts, Inc.|Unit #51|adapter, harne 23.36 550531 1/25/2011Vehicle Repairs ACT Automotive & Tire|Unit #51|rebuilt alter 194.56 50713 1/26/2011Vehicle Repairs Bradford Supply Company|Unit #26|coupler g 2.36 1298889 1/26/2011Vehicle Repairs National Oil Well|Unit #24|ss clamp hose, du 18.68 902850233 1/28/2011Vehicle Repairs Robertson Welding & Repair Shop, LLC|Unit # 37.84 113394 1/31/2011Vehicle Repairs ACT Automotive & Tire|Unit #40|replaced 2 t 1,217.59 50785 1/31/2011Vehicle Repairs GJ039 COUNTRYMARK INVOICE #28354 1,455.48 1/31/2011Vehicle Repairs Dusty's Tire|Trailer #61|2 tires, rim 288.94 3891 2/1/2011Vehicle Repairs NAPA Auto Parts|Unit #41|brake fluid 5.87 652312 1/31/2011Vehicle Repairs Dusty's Tire|Ford Truck|new tires 170.92 3907 2/7/2011



21

Expense of items

Don’t be overwhelmed, sampling is allowed to figure out, broadly, what you have in the buckets.



22

Take-aways

Defining “Unit of Property”;

Defining and Understanding “Routine Maintenance”;

Defining and Identifying

Capital items;

Items costing less than $100;

Consumables, supplies, items with a life of 12 months or less;

“De minimis” items;

Spare parts

Decision flow charts – capitalization vs. deductible repair


24

Unit of property

Buildings Everything Else

Default Rule Plant Property Network Assets Single UOP

Functional Interdependence

Discrete and major function

Facts & circumstances - industry specific


25

Unit of property – buildings

Entire building

Determine UOP Apply

Capitalization Standards

Building structure

Building systems

HVAC Plumbing

system Electrical system

All escalators All elevators

Fire protection Security system Gas distribution

Capitalize Improvements

to UOP

Entire building


26

Capitalization standards

Improvement standards – an amount paid must be capitalized if it results in a:

Betterment to the unit of property Adaptation of the unit of property to a new or different use

Restoration to the unit of property

Material condition or defect at acquisition or production 1.

Material addition or expansion 2.

Material increase in: Quality, Capacity, Productivity, Efficiency, or Strength

3.

Replacement and recognition of a loss on disposed of component

Gain/loss on sale of a component

Basis adjustment as a result of a casualty loss

Return to former operating condition – no longer functioning

Rebuild the property to like new condition after the class life

Replacement of major component or substantial structural part

1.

2.

3.

5.

4.

6.

Tax capitalization policy – flowchart


27

Frequently asked questions (FAQs)


29

Frequently asked questions (FAQs)

“The ‘Repair Regulations’: Frequently Asked Questions” (Tax Analysts – Tax Notes October 8, 2012) (Copy of Article in Participant Materials)

Acquisition Costs

Repair Costs, Units of Property

Capitalization Standards

Dispositions of Tangible Property

Considerations for Cooperatives


30

Acquisition costs – FAQs

If a written policy exists to deduct, for book purposes, any expenditure under a certain dollar amount, may this same method be used for tax purposes?

My IRS exam team has agreed to a more generous de minimis policy than the regulations allow. Can I continue using that policy?

Do the temporary regulations allow a deduction for all de minimis costs?

Do I calculate the ceiling at the entity level or the consolidated level?

How are materials and supplies treated under the temporary regulations?

Do I need to review every transaction or invoice for materials and supplies?

How does the tax treatment of rotable spare parts differ from that of normal spare parts?


31

Repair costs, units of property – FAQs

Since the temporary regulations now require the segmentation of buildings into smaller units in applying the capitalization standards, can the smaller units be used for depreciation purposes in establishing shorter lives than 39 years?

Is a cost segregation study now required to determine the cost of a building’s subsystems?

How does a company identify the units of property for ‘plant property’?

Regulations include an example of a tortilla machine that is not considered ‘plant property’ because it is not serving an industrial process. Does this mean that all food processing equipment is not plant property?


32

Capitalization standards – FAQs

If maintenance costs do not result in a ‘betterment” to its unit of property, may the costs be deducted under section 162(a))?

If a new backup power switch costing less than $100 is added to an existing unit of property, must the cost be capitalized?

If cost are incurred to rearrange and ‘freshen’ the interior space of an existing retail store, may the cost be deducted?

What is a ‘major component’ of a unit of property?

What if part – but not all – of a major component is replaced?

Does the routine maintenance safe harbor apply to a new part that is safer or more durable than the old part it replaced?

Can a change in accounting for repair & maintenance costs be done using a cutoff method instead of a section 481(a) adjustment?

How far back must a company compute the section 481 adjustment?


33

Dispositions – FAQs

Is there a downside to making a GAA election?

What if I don’t make the GAA election?

Should a GAA election be made for all property or only for buildings?

How does a company make a GAA election?

Can a GAA election apply to assets acquired prior to 2012?

How do I determine basis of building component dispositions?

What is a structural component for this purpose?

How is the ‘stranded basis’ of disposed of components recovered, where the company continued to depreciate the costs under its prior method?

Does a GAA election have to be made to recover the stranded basis?

Should a company start tracking the basis of building components when it first acquires them?


34

Considerations for Cooperatives – FAQs

What is the applicable period for taking into account Section 481(a) adjustments, both positive and negative, into taxable income, applicable to cooperatives?

What are the considerations for patronage allocations on a book basis versus a tax basis method?

Are there any considerations around the required 8.5 month payment period for distribution of patronage?

Application and implementation – Three “buckets” - Acquisition costs - Repair and maintenance - Dispositions

Application & implementation - Acquisition costs


37

The “first bucket” – Acquisition costs

Consider “Book conformity de minimis rule”

Determine book capitalization threshold amount for:

Is there a written plan in place at the beginning of the year?

Are the amounts expensed on an applicable financial statement (AFS)?

Calculate the ceiling limit at the entity level if possible; if not, the consolidated or affiliated levels:

The greater of

– 0.1% of tax gross receipts or

– 2% of book depreciation & amortization

Materials and supplies elected to be treated as de minimis costs are included in determining if ceiling limit is reached

Aggregate amounts below the ceiling limit are expensed same as book

Amounts above the ceiling limit are capitalized for tax

Can elect out of book conformity, “cherry-pick” applicable amounts, and capitalize and depreciate for tax


38

Example – Acquisition Costs – Numerous account types

Acquired tangible property

Nonincidental materials and

supplies

Repairs and maintenance

Incidental materials and

supplies

Multiple items that cost less than $5,000 are expensed using numerous accounts under book policy:


39

Example acquisition costs – numerous account types (continued)

Acquired tangible property expensed as de

minimis

Ceiling – greater of 1% of gross receipts or 2% of book depreciation and amortization

Identify and exclude these from the ceiling:

Nonincidental materials and

supplies deducted when

used or consumed

Incidental materials and

supplies deducted in

year purchased

Materials and supplies

capitalized and depreciated

Deduct amounts below ceiling in the year purchased:

Repairs and maintenance


40

Acquisition Costs: Materials and supplies – Common methods

Common methods:

Inventory materials and supplies and deduct when used or consumed – nonincidental

Deduct in year purchased - Incidental

Capitalize and depreciate – rotable & temporary spare parts

Deduct in the year purchased under book de minimis policy


41

Acquisition Costs: Materials and supplies

Materials and supplies (M&S) defined:

1. A component acquired to maintain, repair, or improve a unit of tangible property owned, leased, or serviced by the taxpayer

2. A unit of property with an economic useful life of 12 months or less

3. A unit of property that has an acquisition or production cost of $100 or less

4. Fuel, lubricants, water and similar items that are reasonably expected to be consumed within 12 months or less, beginning when used in the taxpayer’s operations

5. Property identified in published guidance as M&S

6. Rotable or temporary spare parts

“Non-incidental” (used or consumed) vs. “incidental” (in the year purchased)

May deduct all M&S in the year purchased under the de minimis rule

May elect to capitalize and depreciate – cannot go back (CAUTION!)


42

Acquisition Costs: Rotable and temporary spare parts

Rotable spare parts: M&S acquired for installation on a UOP, removable from UOP, repaired, and re-used Temporary spare parts: M&S used until a new or repaired part can be installed the removed and stored for later

Option 2 Capitalize and

depreciate

Option 1 Deduct full basis

on final disposition

Option 4 Deduct under de

minimis rule

Option 3 Optional method –

exchange type treatment

Application and implementation - Repair and maintenance


44

The second “bucket” – Repair and maintenance costs

Unit of property standard

New definitions, but still many grey areas

Capitalization standards

Largely same factual standards as under prior law

Exceptions and safe harbors

Routine maintenance safe harbor

Incorporation of section 263A standard for “indirect costs”


45

Repair Costs: Exception to general capitalization standard

Routine maintenance safe harbor

Routine maintenance expected to be performed more than once during property’s class life

Inapplicable to:

– Betterments

– Certain restorations

– Buildings

Distinguish repairs and maintenance expense under book min cap policy


46

Repair Costs – Apply 263A Standard for Indirect Costs

Repeal of “Plan of Rehabilitation Doctrine”

Replaced with “section 263A” standard: capitalize costs that directly benefit or are incurred by reason of improvement

Implications for store refreshes/remodels


47

Repair vs. improvement determination

Facts and circumstances determination vs. bright-line rules

General framework of temporary regulations

Regulatory accounting method – Specific to FERC, FCC, STB

Industry specific guidance – Network Assets

– Rev. Proc. 2011-27 (wireline assets) – 12 percent

– Rev. Proc. 2011-28 (wireless assets) – 5 percent

– Rev. Proc. 2011-43 (electric T&D): percentage of units of linear property replaced

– Additional IIRs expected


48

Review current capitalization policies/accounting methods

Assess and Document Current Policies

Review GAAP and or tax capitalization policies

Obtain tax FA download

Separate “remodel” assets from “line-item” assets

Separate further based on logical relationships (location, project, etc.)

Apply capitalization standards in temporary regulations and UOP definitions

– For buildings, use the building structure and building systems

Document findings

– Invoices

– Interviews

Develop new tax capitalization policy, if applicable

Assess possible system changes going forward


49

Action items – Repairs and maintenance

Action items

Analyze current method for repairs relative to new capitalization standards

Determine if method change is necessary

File Forms 3115

Prepare and file applicable Form 3115s (Rev. Proc. 2012-19)

Favorable method changes:

– Deducting repair and maintenance costs (Automatic Change 162)

– Routine maintenance safe harbor (Automatic Change 171)

Unfavorable method changes:

– Capitalizing improvements to tangible property (Automatic Change 174)

– Regulatory accounting method (Automatic Change 163)

Application and Implementation – Dispositions


51

The “third bucket” – Dispositions

Generally, for this purpose, a “disposition” is a transfer of ownership of the asset or the permanent withdrawal of an asset from the trade or business.

Includes:

– Sale or exchange

– Retirement

– Physical abandonment

– Destruction

– Transfer to a supplies, scrap, or similar account

– Retirement of a structural component of a building

– Involuntary conversion


52

The “third bucket” – Dispositions (continued)

New “default” rule: discontinue depreciating basis of “components” upon disposition

Example: new roof – capitalize cost of new roof, discontinue depreciating basis of old roof

Required to deduct remaining basis of old roof?

Deducting remaining basis of retired components prevents deducting cost of replacement under “restoration” standards

– Roofs

– Windows

General asset accounts (“GAAs”)

Generally, any combination of assets by vintage, MACRS class life, and depreciation methods

Provides flexibility following dispositions

– Leave basis of component in GAA, continue depreciating, and perhaps deduct repair costs, or

– Recover remaining basis immediately and capitalize replacement costs


53

Dispositions – Comparison

Default Treatment

General Asset Account Election

Depreciation stops Gain or loss recognized

1. Depreciation continues - no immediate recovery of basis

2. Optional Termination of GAA if:

Disposition of all or last asset in GAA, or Qualifying disposition


54

Structural component dispositions – Assessment

Assessment process

Review current retirement policies (GAAP and or Tax)

Determine whether building structural components were retired in prior years

Tax fixed asset ledger review

Group assets by location/property and sort by tax life to identify section 1250 real property

Sort the 1250 real property assets by placed in service date to identify the original assets placed in service for each location

Once the original assets have been identified, determine if there are assets placed in service during subsequent tax years that represent the same structural components as the original assets


55

Dispositions – Action items

Consider making “late” GAA election for all property acquired before 2012

Automatic change in accounting method

Must be made within 2 years of regulations’ effective date

Consider scrubbing fixed asset records for remaining “stranded basis” and recovering through an accounting method change

Can be done independently of GAA election, and vice versa

Prepare and file applicable Form 3115s (Rev. Proc. 2012-20)

Disposition of a building or structural component (with no GAA election) (Automatic Change 177)

Dispositions of tangible depreciable assets other than buildings and structural components (Automatic Change 178)

Late election to use general asset accounts (Automatic change 180)

Late election to recognize gain or loss on item in qualifying disposition (retirement of structural components, for example) (Automatic change 180)



56

Contact information

David Antoni

267-256-1627

[email protected]

John Hiatt

317-238-8236

[email protected]

mailto:[email protected]

mailto:[email protected]

Thank you


The KPMG name, logo and “cutting through complexity” are registered trademarks or trademarks of KPMG International.


Date post:	23-Mar-2020
Category:	Documents
Upload:	others
View:	0 times
Download:	0 times

Update on repair regulations -...

Documents