Legal Alert: Rev. Proc. 2021-34, IRS guidance for implementing the final Section 451 regulations

On August 12, 2021, the IRS released Rev. Proc. 2021-34, setting forth procedural guidance to implement the final Section 451 regulations (Final Regulations). In a lengthy 70-page piece of guidance, the revenue procedure not only provides accounting method changes and the terms and conditions to comply with the Final Regulations by its effective date, (tax years beginning on or after January 1, 2021), it also permits taxpayers to early adopt the Final Regulations for the 2020 tax year. With the addition of six new automatic accounting method changes, as well as the myriad of modifications made to existing automatic accounting method changes, Rev. Proc. 2021-34 is definitive guidance for any taxpayer considering filing an accounting method change to implement the Final Regulations. This alert provides a preliminary review of the new guidance.

Read the full Legal Alert here.

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