Today, August 12, 2021, Treasury and IRS released Revenue Procedure 2021-34, which provides procedural guidance on final regulations under IRC Section 451 (the final regulations, which were published in the January 6, 2021 Internal Revenue Bulletin). The revenue procedure is generally effective for Forms 3115 filed on or after August 12, 2021.

Revenue Procedure 2021-34 modifies the list of automatic method changes contained in Revenue Procedure 2019-43 by adding new automatic method changes and modifying some existing automatic method changes. Specifically, the revenue procedure:

• Adds automatic method changes, including related inventory changes, to timely and early apply the final regulations (taxpayers must generally apply the final regulations to tax years beginning on or after January 1, 2021)
• Includes eligibility rule waivers for the first tax year that the taxpayer makes a change to apply the final regulations, whether through timely or early application of the regulations
• Provides specific rules on IRC Section 481(a) adjustments for certain accounting method changes

A more detailed Tax Alert on Revenue Procedure 2021-34 is forthcoming, and an invitation to an upcoming webcast on Wednesday, September 1, 2021 will be sent soon.