RP-2024-34: this revenue procedure expands the waiver of the eligibility rules to accounting method changes

Revenue Procedure 2024-34 modifies section 7 of Rev. Proc. 2024-23, 2024-23 I.R.B. 1334, to modify the procedures under section 446 of the Internal Revenue Code and §1.446-1(e) of the Income Tax Regulations for obtaining automatic consent of the Commissioner to change methods of accounting for research or experimental expenditures paid or incurred in taxable years beginning after December 31, 2021. Specifically, this revenue procedure expands the waiver of the eligibility rules in section 5.01(1)(d) and (f) of Rev. Proc. 2015-13 to accounting method changes described in section 7.01 of Rev. Proc. 2024-23 that are made in any taxable year beginning in 2022 or 2023. This revenue procedure also permits a taxpayer to make changes under section 7.01 of Rev. Proc. 2024-23 regardless of whether a change under that section has been filed for any other taxable year beginning in 2022 or 2023. Finally, for any change under section 7.01 of Rev. Proc. 2024-23 made in a taxable year beginning in 2022 or 2023 (other than the first taxable year beginning after December 31, 2021), this revenue procedure limits audit protection for research or experimental expenditures paid or incurred in the taxpayer’s first taxable year beginning after December 31, 2021 if the taxpayer failed to make a change for such expenditures for such taxable year.

WILL BE IN IRB: 2024-38 DATED: September 16, 2024

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