Internal Revenue Bulletin 2019-48 (PDF rendition): IRS Revenue Procedures

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Bulletin No. 2019–48
November 25, 2019
HIGHLIGHTS
OF THIS ISSUE
These synopses are intended only as aids to the reader in
identifying the subject matter covered. They may not be
relied upon as authoritative interpretations.
ADMINISTRATIVE
Rev. Proc. 2019-45, page 1215.
This procedure publishes the method by which qualified
states can request an allocation of unused housing credit
carryover under section 42(h)(3)(D) of the Code.
EMPLOYEE PLANS
REG-132210-18, page 1232.
These proposed regulations would update the life expectan-
cy and distribution period tables that are used to calculate
required minimum distributions from qualified retirement
plans, individual retirement accounts and annuities, and
certain other tax-favored retirement arrangements.
INCOME TAX
Rev. Proc. 2019-43, page 1107.
This revenue procedure provides the List of Automatic
Changes to which the automatic change procedures
in Rev. Proc. 2015-13, 2015-5 I.R.B. 419, as clarified
and modified by Rev. Proc. 2015-33, 2015-24 I.R.B.
1067, and as modified by Rev. Proc. 2017-59, 2017-
48 I.R.B. 543, and by section 17.02(b) and (c) of Rev.
Proc. 2016-1, 2016-1 I.R.B. 1, apply.
REG-131071-18, page 1217.
This notice of proposed rulemaking provides rules regard-
ing the definition of an eligible terminated S corporation
(ETSC). In addition, these proposed regulations provide
rules relating to distributions of money by an ETSC after
the post-termination transition period (PTTP). Finally, these
proposed regulations revise current regulations to extend
the treatment of distributions of money during the PTTP to
all shareholders of the corporation and to update and clarify
the allocation of current earnings and profits to distributions
of money and other property.
Finding Lists begin on page ii.

The IRS Mission
Provide America’s taxpayers top-quality service by helping
them understand and meet their tax responsibilities and en-
force the law with integrity and fairness to all.
Introduction
The Internal Revenue Bulletin is the authoritative instrument
of the Commissioner of Internal Revenue for announcing of-
ficial rulings and procedures of the Internal Revenue Service
and for publishing Treasury Decisions, Executive Orders, Tax
Conventions, legislation, court decisions, and other items of
general interest. It is published weekly.
It is the policy of the Service to publish in the Bulletin all sub-
stantive rulings necessary to promote a uniform application
of the tax laws, including all rulings that supersede, revoke,
modify, or amend any of those previously published in the
Bulletin. All published rulings apply retroactively unless other-
wise indicated. Procedures relating solely to matters of inter-
nal management are not published; however, statements of
internal practices and procedures that affect the rights and
duties of taxpayers are published.
Revenue rulings represent the conclusions of the Service
on the application of the law to the pivotal facts stated in
the revenue ruling. In those based on positions taken in rul-
ings to taxpayers or technical advice to Service field offices,
identifying details and information of a confidential nature are
deleted to prevent unwarranted invasions of privacy and to
comply with statutory requirements.
Rulings and procedures reported in the Bulletin do not have the
force and effect of Treasury Department Regulations, but they
may be used as precedents. Unpublished rulings will not be
relied on, used, or cited as precedents by Service personnel in
the disposition of other cases. In applying published rulings and
procedures, the effect of subsequent legislation, regulations,
court decisions, rulings, and procedures must be considered,
and Service personnel and others concerned are cautioned
against reaching the same conclusions in other cases unless
the facts and circumstances are substantially the same.
The Bulletin is divided into four parts as follows:
Part I.—1986 Code.
This part includes rulings and decisions based on provisions
of the Internal Revenue Code of 1986.
Part II.—Treaties and Tax Legislation.
This part is divided into two subparts as follows: Subpart A,
Tax Conventions and Other Related Items, and Subpart B,
Legislation and Related Committee Reports.
Part III.—Administrative, Procedural, and Miscellaneous.
To the extent practicable, pertinent cross references to these
subjects are contained in the other Parts and Subparts. Also
included in this part are Bank Secrecy Act Administrative
Rulings. Bank Secrecy Act Administrative Rulings are issued
by the Department of the Treasury’s Office of the Assistant
Secretary (Enforcement).
Part IV.—Items of General Interest.
This part includes notices of proposed rulemakings, disbar-
ment and suspension lists, and announcements.
The last Bulletin for each month includes a cumulative index
for the matters published during the preceding months. These
monthly indexes are cumulated on a semiannual basis, and are
published in the last Bulletin of each semiannual period.
The contents of this publication are not copyrighted and may be reprinted freely. A citation of the Internal Revenue Bulletin as the source would be appropriate.
November 25, 2019 Bulletin No. 2019–48

Part III
26 CFR 601.204: Changes in accounting periods and in methods of accounting.
(Also Part I, §§ 56, 61, 77, 118, 162, 163, 166, 167, 168, 171, 174, 179D, 194, 195, 197, 248, 263, 263A, 267, 280F, 404, 446, 447, 448, 451, 454, 455, 460, 461, 467,
471, 472, 475, 481, 585, 709, 807, 816, 832, 833, 846, 860A-860G, 861, 904, 953, 985, 1272, 1273, 1278, 1281, 1363, 1400I, 1400L, 1400N; 1.61-1, 1.61-4, 1.61-
8, 1.77-1, 1.77-2, 1.118-2, 1.162-1, 1.162-3, 1.162-4, 1.162-11, 1.162-12, 1.166-1, 1.166-2, 1.166-4, 1.167(a)-2, 1.167(a)-3(b), 1.167(a)-4, 1.167(a)-7, 1.167(a)-8,
1.167(a)-11, 1.167(a)-14, 1.167(e)-1, 1.168(d)-1, 1.168(i)-1, 1.168(i)-4, 1.168(i)-6, 1.168(i)-7, 1.168(i)-8, 1.168(k)-1, 1.168(k)-2, 1.171-4, 1.174-1, 1.174-3, 1.174-4,
1.179-5, 1.194-1, 1.195-1, 1.197-2, 1.248-1, 1.263(a)-1, 1.263(a)-2, 1.263(a)-3, 1.263(a)-4, 1.263(a)-5, 1.263A-1, 1.263A-2, 1.263A-3, 1.263A-4, 1.263A-7, 1.267(a)-
1, 1.280F-6, 1.404(b)-1T, 1.446-1, 1.446-1T, 1.446-2, 1.446-5, 1.446-6, 1.446-7, 1.448-1T, 1.448-2, 1.451-1, 1.451-3, 1.451-8, 1.454-1, 1.455-6, 1.460-4, 1.461-1,
1.461-4, 1.461-5, 1.467-1, 1.471-1, 1.471-2, 1.471-3, 1.471-4, 1.471-5, 1.471-8, 1.472-1, 1.472-2, 1.472-6, 1.472-8, 1.481-1, 1.481-4, 1.709-1, 1.709-2, 1.832-4,
1.832-5, 1.860A-6, 1.861-18, 1.985-5, 1.985-8, 1.1016-3, 1.1245-3, 1.1272-1, 1.1273-1, 1.1273-2, 1.1363-2, 1.1374-4, 1.1400L(b)-1.)
Rev. Proc. 2019-43
LIST OF AUTOMATIC CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1112
SECTION 1 . GROSS INCOME (§ 61) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1112
.01 Up-front Payments for Network Upgrades received by Utilities
SECTION 2 . COMMODITY CREDIT LOANS (§ 77) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1112
.01 Treating amounts received as loans
SECTION 3 . TRADE OR BUSINESS EXPENSES (§ 162) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1112
.01 Advances made by a lawyer on behalf of clients
.02 ISO 9000 Costs
.03 Restaurant or tavern smallwares packages
.04 Timber grower fertilization costs
.05 Materials and supplies
.06 Repair and maintenance costs
.07 Wireline network asset maintenance allowance and units of property methods of accounting under
Rev . Proc . 2011-27
.08 Wireless network asset maintenance allowance and units of property methods of accounting under
Rev . Proc . 2011-28
.09 Method of accounting under Rev . Proc . 2011-43 for taxpayers in the business of transporting, delivering,
or selling electricity
.10 Method of accounting under Rev . Proc . 2013-24 for taxpayers in the business of generating steam or
electric power .
.11 Cable network asset capitalization methods of accounting under Rev . Proc . 2015-12
SECTION 4 . BAD DEBTS (§ 166) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1114
.01 Change from reserve method to specific charge-off method
.02 Conformity election by bank after previous election automatically revoked
SECTION 5 . INTEREST EXPENSE (§ 163) AND AMORTIZABLE BOND PREMIUM (§ 171) . . . . . . . . . . . . . . . . . . . . . . . .1114
.01 Revocation of § 171(c) election
.02 Change to comply with § 163(e)(3)
SECTION 6 . DEPRECIATION OR AMORTIZATION (§ 56(a)(1), 56(g)(4)(A), 167, 168, 197, 280F(a), 1400I,
1400L, or 1400N(d), OR FORMER § 168) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1115
.01 Impermissible to permissible method of accounting for depreciation or amortization
.02 Permissible to permissible method of accounting for depreciation
.03 Sale, lease, or financing transactions
.04 Change in general asset account treatment due to a change in the use of MACRS property
.05 Change in method of accounting for depreciation due to a change in the use of MACRS property
.06 Depreciation of qualified non-personal use vans and light trucks
.07 Impermissible to permissible method of accounting for depreciation or amortization for disposed
depreciable or amortizable property
.08 Tenant construction allowances
.09 Safe harbor method of accounting for determining the depreciation of certain tangible assets used by
wireless telecommunications carriers under Rev . Proc . 2011-22
.10 Partial dispositions of tangible depreciable assets to which the IRS’s adjustment pertains (§ 168; § 1 .168(i)-8)
.11 Depreciation of leasehold improvements (§§ 167, 168, and 197; § 1 .167(a)-4)
Bulletin No. 2019–48 1107 November 25, 2019

.12 Permissible to permissible method of accounting for depreciation of MACRS property
(§ 168; §§ 1 .168(i)-1, 1 .168(i)-7, and 1 .168(i)-8)
.13 Disposition of a building or structural component (§ 168; § 1 .168(i)-8)
.14 Dispositions of tangible depreciable assets (other than a building or its structural components)
(§ 168; § 1 .168(i)-8)
.15 Dispositions of tangible depreciable assets in a general asset account (§ 168(i)(4); § 1 .168(i)-1)
.16 Summary of certain changes in methods of accounting related to dispositions of MACRS property
.17 Depreciation of fiber optic transfer node and fiber optic cable used by a cable system operator (§§ 167 and 168)
.18 Late elections or revocation of elections under § 168(k)(5), (7), and (10)
SECTION 7 . RESEARCH AND EXPERIMENTAL EXPENDITURES (§ 174) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1139
.01 Changes to a different method or different amortization period
SECTION 8 . ELECTIVE EXPENSING PROVISIONS (§ 179D) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1140
.01 Deduction for Energy Efficient Commercial Buildings (§ 179D)
SECTION 9 . COMPUTER SOFTWARE EXPENDITURES (§§ 162, 167, and 197) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1141
.01 Computer software expenditures
SECTION 10 . START-UP EXPENDITURES AND ORGANIZATIONAL FEES (§§ 195, 248 AND 709) . . . . . . . . . . . . . . . . . .1141
.01 Start-up expenditures
.02 Organizational expenditures under § 248
.03 Organization fees under § 709
SECTION 11 . CAPITAL EXPENDITURES (§ 263) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1142
.01 Package design costs
.02 Line pack gas or cushion gas
.03 Removal costs
.04 Distributor commissions
.05 Intangibles
.06 Rotable spare parts safe harbor method .
.07 Repairable and reusable spare parts
.08 Tangible property
.09 Railroad track structure expenditures
.10 Remodel-refresh safe harbor method
SECTION 12 . UNIFORM CAPITALIZATION (UNICAP) METHODS (§ 263A) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1149
.01 Certain uniform capitalization (UNICAP) methods used by resellers and reseller-producers
.02 Certain uniform capitalization (UNICAP) methods used by producers and reseller-producers
.03 Impact fees
.04 Change to capitalizing environmental remediation costs under § 263A
.05 Change in allocating environmental remediation costs under § 263A
.06 Safe harbor methods under § 263A for certain dealerships of motor vehicles
.07 Change to not apply § 263A to one or more plants removed from the list of plants that have
a preproductive period in excess of 2 years .
.08 Change to a reasonable allocation method described in § 1 .263A-1(f)(4) for self-constructed assets
.09 Real property acquired through foreclosure
.10 Sales-Based Royalties
.11 Treatment of Sales-Based Vendor Chargebacks under a Simplified Method
.12 U .S . ratio method
.13 Depletion
.14 Interest capitalization
.15 Change to not apply § 263A to replanting costs for lost or damaged citrus plants pursuant to § 263A(d)(2)(C)
.16 Small business taxpayer exception from requirement to capitalize costs under § 263A
.17 Recharacterizing costs under the simplified resale method, simplified production method, or the
modified simplified production method
.18 Revocation of a historic absorption ratio election
SECTION 13 . LOSSES, EXPENSES AND INTEREST WITH RESPECT TO TRANSACTIONS BETWEEN
RELATED TAXPAYERS (§ 267) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1162
.01 Change to comply with § 267
SECTION 14 . DEFERRED COMPENSATION (§ 404) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1163
.01 Deferred compensation
.02 Grace period contributions
November 25, 2019 1108 Bulletin No. 2019–48

Bulletin No. 2019–48 1109 November 25, 2019
SECTION 15 . METHODS OF ACCOUNTING (§ 446) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1163
.01 Change in overall method from the cash method to an accrual method
.02 Multi-year insurance policies for multi-year service warranty contracts
.03 Taxpayers changing to overall cash method
.04 Nonaccrual-experience method
.05 Interest accruals on short-term consumer loans—Rule of 78’s method
.06 Film producer’s treatment of certain creative property costs
.07 Deduction of incentive payments to health care providers
.08 Change by bank for uncollected interest .
.09 Change from the cash method to an accrual method for specific items
.10 Multi-year service warranty contracts
.11 Overall cash method for specified transportation industry taxpayers
.12 Change to overall cash/hybrid method for certain banks
.13 Change to overall cash method for farmers
.14 Nonshareholder contributions to capital under § 118
.15 Debt issuance costs
.16 Transfers of interties under the safe harbor described in Notice 2016-36 (§ 118) .
.17 Change to or from the net asset value (NAV) method .
.18 Small business taxpayer changing to overall cash method
SECTION 16 . TAXABLE YEAR OF INCLUSION (§ 451) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1175
.01 Accrual of interest on nonperforming loans
.02 Advance rentals
.03 State or local income or franchise tax refunds
.04 Capital Cost Reduction Payments
.05 Credit card annual fees
.06 Credit card late fees
.07 Advance payments
.08 Credit card cash advance fees
.09 Retainages
.10 Change in applicable financial statements (AFS) for purposes of applying certain revenue
recognition methods of accounting .
.11 Changes in the timing of recognition of income due to the New Standards
.12 Changes in the timing of income recognition under § 451(b) or proposed § 1 .451-3, and changes
relating to advance payments under proposed § 1 .451-8
SECTION 17 . OBLIGATIONS ISSUED AT DISCOUNT (§ 454) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1183
.01 Series E, EE or I U .S . savings bonds
SECTION 18 . PREPAID SUBSCRIPTION INCOME (§ 455) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1183
.01 Prepaid subscription income
SECTION 19 . SPECIAL RULES FOR LONG-TERM CONTRACTS (§ 460) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1184
.01 Small business taxpayer exceptions from requirement to account for certain long-term contracts under
§ 460 or to capitalize costs under § 263A for certain home construction contracts
SECTION 20 . TAXABLE YEAR INCURRED (§ 461) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1184
.01 Timing of incurring liabilities for employee compensation
(1) Self-insured employee medical benefits
(2) Bonuses
(3) Vacation pay, sick pay, and severance pay
.02 Timing of incurring liabilities for real property taxes, personal property taxes, state income taxes,
and state franchise taxes
.03 Timing of incurring liabilities under a workers’ compensation act, tort, breach of contract, or violation of law
.04 Timing of incurring certain liabilities for payroll taxes
.05 Cooperative advertising
.06 Timing of incurring certain liabilities for services or insurance
.07 Rebates and allowances
.08 Ratable accrual of real property taxes
.09 California Franchise Taxes
.10 Gift cards issued as a refund for returned goods
.11 Timing of incurring liabilities under the recurring item exception to the economic performance rules

November 25, 2019 1110 Bulletin No. 2019–48
.12 Economic performance safe harbor for ratable service contracts
SECTION 21 . RENT (§ 467) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1189
.01 Change from an improper method of inclusion of rental income or expense to inclusion in accordance with
the rent allocation
SECTION 22 . INVENTORIES (§ 471) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1189
.01 Cash discounts
.02 Estimating inventory “shrinkage”
.03 Small taxpayer exception from requirement to account for inventories under § 471
.04 Qualifying volume-related trade discounts
.05 Impermissible methods of identification and valuation of inventories.
.06 Core Alternative Valuation Method
.07 Replacement cost for automobile dealers’ parts inventory
.08 Replacement cost for heavy equipment dealers’ parts inventory
.09 Rotable spare parts
.10 Advance Trade Discount Method
.11 Permissible methods of identification and valuation of inventories.
.12 Change in the official used vehicle guide utilized in valuing used vehicles
.13 Invoiced advertising association costs for new vehicle retail dealerships
.14 Rolling-average method of accounting for inventories
.15 Sales-Based Vendor Chargebacks
.16 Certain changes to the cost complement of the retail inventory method
.17 Certain changes within the retail inventory method
.18 Change from currently deducting inventories to permissible methods of identification and valuation of inventories.
.19 Small business taxpayer exception from requirement to account for inventories under § 471 .
SECTION 23 . LAST-IN, FIRST-OUT (LIFO) INVENTORIES (§ 472) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1195
.01 Change from the LIFO inventory method
.02 Determining current-year cost under the LIFO inventory method
.03 Alternative LIFO inventory method for retail automobile dealers
.04 Used vehicle alternative LIFO method
.05 Determining the cost of used vehicles purchased or taken as a trade-in
.06 Change to the inventory price index computation (IPIC) method
.07 Changes within the inventory price index computation (IPIC) method
.08 Changes to the Vehicle-Pool Method
.09 Changes within the used vehicle alternative LIFO method
.10 Changes to dollar-value pools of manufacturers
SECTION 24 . MARK-TO-MARKET ACCOUNTING METHOD (Including § 475) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1200
.01 Commodities dealers, securities traders, and commodities traders electing to use the mark-to-market
method of accounting under § 475(e) or (f)
.02 Taxpayers requesting to change their method of accounting from the mark-to-market method of
accounting described in § 475 to a realization method
SECTION 25 . BANK RESERVES FOR BAD DEBTS (§ 585) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1201
.01 Changing from the § 585 reserve method to the § 166 specific charge-off method
SECTION 26 . INSURANCE COMPANIES (§§ 807, 816, 832, 833) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1203
.01 Safe harbor method of accounting for premium acquisition expenses
.02 Certain changes in method of accounting for organizations to which § 833 applies
.03 Change in qualification as life/nonlife insurance company under § 816
.04 Changes in basis of computing reserves under § 807(f)
SECTION 27 . DISCOUNTED UNPAID LOSSES (§ 846) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1205
.01 Composite method for discounting unpaid losses
SECTION 28 . REAL ESTATE MORTGAGE INVESTMENT CONDUIT (REMIC) (§§ 860A-860G) . . . . . . . . . . . . . . . . . . . .1205
.01 REMIC Inducement Fees
SECTION 29 . FUNCTIONAL CURRENCY (§ 985) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1206
.01 Change in functional currency
SECTION 30 . ORIGINAL ISSUE DISCOUNT (§§ 1272, 1273) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1206
.01 De minimis original issue discount (OID)
.02 Proportional method of accounting for OID on a pool of credit card receivables
SECTION 31 . MARKET DISCOUNT BONDS (§ 1278) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1206

Bulletin No. 2019–48 1111 November 25, 2019
.01 Revocation of § 1278(b) election
SECTION 32 . SHORT-TERM OBLIGATIONS (§ 1281) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1207
.01 Interest income on short obligations
.02 Stated interest on short-term loans of cash method banks
EFFECTIVE DATE . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1208
EFFECT ON OTHER DOCUMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1209
PAPERWORK REDUCTION ACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1209
SIGNIFICANT CHANGES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1210
DRAFTING INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1210
LIST OF AUTOMATIC CHANGES CONTACT LIST . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .1211

This revenue procedure provides the List
of Automatic Changes to which the au-
tomatic change procedures in Rev . Proc .
2015-13, 2015-5 I.R.B. 419, as clarified
and modified by Rev. Proc. 2015-33,
2015-24 I.R.B. 1067, and as modified
by Rev . Proc . 2017-59, 2017-48 I .R .B .
543, and by section 17 .02(b) and (c) of
Rev . Proc . 2016-1, 2016-1 I .R .B . 1, ap-
ply. The definitions in section 3 of Rev.
Proc . 2015-13 apply to this revenue pro-
cedure .
LIST OF AUTOMATIC CHANGES
SECTION 1 . GROSS INCOME (§ 61)
.01 Up-front Payments for Network
Upgrades received by Utilities .
(1) Description of change . This change
applies to a Utility that wants to change its
method of accounting for Up-front Pay-
ments to the safe harbor method described
in Rev . Proc . 2005-35, 2005-2 C .B . 76 . In
general, this change applies to a Utility
that receives an Up-front Payment from
a Generator to finance Network Upgrades
to the Utility’s Transmission System . For
federal income tax purposes, if an Up-
front Payment is made pursuant to an In-
terconnection Agreement that satisfies all
of the conditions of section 5 .02 of Rev .
Proc . 2005-35, a Utility may treat that
Up-front Payment as not being taxable in-
come under § 61 when received (the safe
harbor method) . In addition, a Utility that
uses the safe harbor method is not entitled
to any deduction for its reimbursements of
the Up-front Payment . To the extent that
Federal Energy Regulatory Commission
(FERC) interest is deductible, it must be
properly allocated to the periods in which
it accrues . A Utility using the safe harbor
method must comply with all other appli-
cable provisions of Rev . Proc . 2005-35 .
See Rev. Proc. 2005-35 for the defini-
tions of certain terms for purposes of this
change .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
1 .01 is “91 .”
(3) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
SECTION 2 . COMMODITY CREDIT
LOANS (§ 77)
.01 Treating amounts received as loans .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for loans re-
ceived from the Commodity Credit Cor-
poration from including the loan amount
in gross income for the taxable year in
which each loan is received to treating
each loan amount as a loan .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(3) Manner of making change . This
change is made on a cut-off basis and ap-
plies only to loans received from the Com-
modity Credit Corporation on or after the
beginning of the year of change . Accord-
ingly, a § 481(a) adjustment is neither per-
mitted nor required .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
2 .01 is “1 .”
(5) Contact information . For further
information regarding a change under this
section, contact William Ruane at (202)
317-4718 (not a toll-free number) .
SECTION 3 . TRADE OR BUSINESS
EXPENSES (§ 162)
.01 Advances made by a lawyer on be-
half of clients .
(1) Description of change . This
change applies to a lawyer who advanc-
es money to pay for costs of litigation or
for other expenses on behalf of clients,
and who wants to change the method of
accounting for such advances from treat-
ing them as deductible business expens-
es to treating them as loans to clients .
This change applies to cases handled ei-
ther on a non-contingent or a contingent
fee basis . See Pelton & Gunther, P.C. v.
Commissioner, T .C . Memo . 1999-339
(non-contingent fee); Canelo v. Commis-
sioner
, 53 T .C . 217 (1969), aff ’d per cu-
riam, 447 F .2d 484 (9
th
Cir . 1971) (con-
tingent fee) .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
3 .01 is “2 .”
(3) Contact information . For further
information regarding a change under this
section, contact Joanna Trebat or Alicia
Lee-Won at (202) 317-7003 (not a toll-
free number) .
.02 ISO 9000 costs .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for costs in-
curred to obtain, maintain, and renew ISO
9000 certification to conform with Rev.
Rul. 2000-4, 2000-1 C.B. 331, as modified
by this revenue procedure .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
3 .02 is “3 .”
(3) Contact information . For further
information regarding a change under this
section, contact Justin Grill at (202) 317-
7003 (not a toll-free number) .
.03 Restaurant or tavern smallwares
packages .
(1) Description of change . This change
applies to a taxpayer engaged in the trade
or business of operating a restaurant or
tavern (within the meaning of section
4 .01 of Rev . Proc . 2002-12, 2002-1 C .B .
374) that wants to change its method of
accounting for the costs of smallwares to
the smallwares method described in Rev .
Proc. 2002-12, as modified by this reve-
nue procedure .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
3 .03 is “4 .”
(3) Contact information . For further
information regarding a change under this
section, contact Renay France at (202)
317-7003 (not a toll-free number) .
.04 Timber grower fertilization costs .
(1) Description of change . This change
applies to a timber grower that wants to
change its method of accounting to treat
post-establishment fertilization costs of an
established timber stand as ordinary and
necessary business expenses deductible
under § 162 . See Rev . Rul . 2004-62, 2004-
1 C.B. 1072, as modified by this revenue
procedure .
(2) Designated automatic accounting
method change number . The designat-
November 25, 2019 1112 Bulletin No. 2019–48

ed automatic accounting method change
number for a change under this section
3 .04 is “86 .”
(3) Contact information . For further
information regarding a change under this
section, contact Alexa Dubert at (202)
317-7003 (not a toll-free number) .
.05 Materials and supplies . See section
11 .08 of this revenue procedure .
.06 Repair and maintenance costs . See
section 11 .08 of this revenue procedure .
.07 Wireline network asset mainte-
nance allowance and units of property
methods of accounting under Rev. Proc.
2011-27 .
(1) Description of change . This change
applies to a wireline telecommunications
carrier that is within the scope of Rev .
Proc . 2011-27, 2011-18 I .R .B . 740, and
wants to change its treatment of wireline
network asset expenditures to use either
(a) the wireline network asset mainte-
nance allowance method of accounting,
or (b) all or some of the units of property
described in Rev . Proc . 2011-27 .
(2) Section 481(a) adjustment . In gen-
eral, a change to the wireline network as-
set maintenance allowance method of ac-
counting or to use all or some of the units
of property specified in Rev. Proc. 2011-
27 requires an adjustment under § 481(a) .
The § 481(a) adjustment shall not include
any amount attributable to property for
which the taxpayer elected to apply the re-
pair allowance under § 1 .167(a)-11(d)(2) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
3 .07 is “158 .”
(4) Contact information . For further
information regarding a change under this
section, contact Ian Heminsley at (202)
317-5100 (not a toll-free number) .
.08 Wireless network asset mainte-
nance allowance and units of property
methods of accounting under Rev. Proc.
2011-28 .
(1) Description of change . This change
applies to a wireless telecommunications
carrier that is within the scope of Rev .
Proc . 2011-28, 2011-18 I .R .B . 743, and
wants to change its treatment of wireless
network asset expenditures to use either
(a) the wireless network asset mainte-
nance allowance method of accounting,
or (b) all or some of the units of property
described in Rev . Proc . 2011-28 .
(2) Section 481(a) adjustment . In gen-
eral, a change to the wireless network as-
set maintenance allowance method of ac-
counting or to use all or some of the units
of property specified in Rev. Proc. 2011-
28 requires an adjustment under § 481(a) .
The § 481(a) adjustment does not include
any amount attributable to property for
which the taxpayer elected to apply the re-
pair allowance under § 1 .167(a)-11(d)(2) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
3 .08 is “159 .”
(4) Contact information . For further
information regarding a change under
this section, contact Sophia Wang at (202)
317-5100 (not a toll-free number) .
.09 Method of accounting under Rev.
Proc. 2011-43 for taxpayers in the busi-
ness of transporting, delivering, or selling
electricity .
(1) Description of change . This change
applies to a taxpayer that is within the
scope of Rev . Proc . 2011-43, 2011-37
I .R .B . 326, and wants to change its treat-
ment of transmission and distribution
property expenditures to use the meth-
od of accounting described in Rev . Proc .
2011-43 .
(2) Section 481(a) adjustment . A tax-
payer must take the entire net § 481(a) ad-
justment into account (whether positive or
negative) in computing taxable income for
the year of change . The § 481(a) adjust-
ment does not include any amount attrib-
utable to property for which the taxpayer
elected to apply the repair allowance un-
der § 1 .167(a)-11(d)(2) for any taxable
year in which the election was made . For
guidance regarding permissible § 481(a)
calculation methodologies, see section
7 .02 and Appendix A of Rev . Proc . 2011-
43 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
3 .09 is “160 .”
(4) Contact information . For further
information regarding a change under this
section, contact Natasha Mulleneaux at
(202) 317-5100 (not a toll-free number) .
.10 Method of accounting under Rev.
Proc. 2013-24 for taxpayers in the busi-
ness of generating steam or electric pow-
er .
(1) Description of change . This change
applies to a taxpayer that is within the
scope of Rev . Proc . 2013-24, 2013-22
I .R .B . 1142, and wants to change its treat-
ment of generation property expenditures
to use all or some of the unit of property
definitions and the corresponding major
component definitions described in Rev.
Proc . 2013-24 .
(2) Section 481(a) adjustment .
(a) A taxpayer must take the entire net
§ 481(a) adjustment into account (whether
positive or negative) in computing taxable
income for the year of change . For guid-
ance regarding the use of extrapolation in
computing a § 481(a) adjustment, see sec-
tions 6 .02 and Appendix B of Rev . Proc .
2013-24 .
(b) A taxpayer changing to this meth-
od of accounting must not include in the
§ 481(a) adjustment any amount attrib-
utable to property for which the taxpayer
elected to apply the repair allowance un-
der § 1 .167(a)–11(d)(2) for any taxable
year in which the repair allowance elec-
tion was made .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
3 .10 is “182 .”
(4) Contact information . For further
information regarding a change under this
section, contact Richard Gano at (202)
317-7011 (not a toll-free number) .
.11 Cable network asset capitalization
methods of accounting under Rev. Proc.
2015-12 .
(1) Description of change . This change
applies to a cable system operator that is
within the scope of Rev . Proc . 2015-12,
2015-2 I .R .B . 266, and wants to make one
or more of the of the following changes in
method of accounting:
(a) Change its treatment of cable net-
work asset expenditures to the cable net-
work asset maintenance allowance meth-
od of accounting provided in section 5 of
Rev . Proc . 2015-12;
(b) Change to use any of the unit of
property definitions provided in section 6
of Rev . Proc . 2015-12;
Bulletin No. 2019–48 1113 November 25, 2019

November 25, 2019 1114 Bulletin No. 2019–48
(c) Change to use the specific iden-
tification method for installations and
customer drop costs described in section
7 .01(1) of Rev . Proc . 2015-12;
(d) Change to use the safe harbor al-
location method for installations and
customer drop costs described in section
7 .01(2) of Rev . Proc . 2015-12; or
(e) Change to deduct the labor costs
associated with installing customer prem-
ises equipment under section 7 .02 of Rev .
Proc . 2015-12 .
(2) Concurrent automatic change . A
taxpayer that wants to make both one or
more changes in method of accounting
pursuant to this section 3 .11 and a change
to a UNICAP method under section 12 of
this revenue procedure for the same year
of change should file a single Form 3115
that includes all of these changes and must
enter the designated automatic accounting
method change numbers for all of these
changes on the appropriate line on the
Form 3115 . See section 6 .03(1)(b) of Rev .
Proc . 2015-13 for information on making
concurrent changes .
(3) Section 481(a) adjustment .
(a) In general, a change to one or more
of the changes in method of accounting
described in section 3 .11(1) of this rev-
enue procedure requires an adjustment
under § 481(a) . The § 481(a) adjustment
shall not include any amount attributable
to property for which the taxpayer elect-
ed to apply the repair allowance under
§ 1 .167(a)-11(d)(2) .
(b) Itemized listing on Form 3115 .
The taxpayer must include on Form 3115
(Rev . December 2018), Part IV, line
26, the total § 481(a) adjustment for all
changes in methods of accounting being
made . If the taxpayer is making more
than one change in method of accounting
under Rev . Proc . 2015-12, the taxpayer
must include on an attachment to Form
3115:
(i) the information required by Part
IV, line 26 for each change in method of
accounting (including the amount of the
§ 481(a) adjustment for each change in
method of accounting, which includes the
portion of the § 481(a) adjustment attrib-
utable to UNICAP);
(ii) the information required by Part
II, line 14 of Form 3115 that is associated
with each change; and
(iii) the citation to the paragraph of
Rev . Proc . 2015-12 that provides for each
proposed method of accounting .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to a method of ac-
counting provided in section 5 or 6 of Rev .
Proc . 2015-12 is “208 .” The designated
automatic accounting method change
number for a change to a method of ac-
counting provided in section 7 of Rev .
Proc . 2015-12 is “209 .”
(5) Contact information . For further
information regarding a change under this
section, contact Merrill Feldstein at (202)
317-5100 (not a toll-free number) .
SECTION 4 . BAD DEBTS (§ 166)
.01 Change from reserve method to
specific charge-off method .
(1) Description of change . This
change applies to a taxpayer (other than
a bank as defined in § 585(a)(2)) that
wants to change its method of account-
ing for bad debts from a reserve method
(or other improper method) to a specific
charge-off method that complies with
§ 166 . For procedures applicable to
banks, see § 585(c) and the regulations
thereunder and section 25 of this revenue
procedure .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
4 .01 is “5 .”
(3) Contact information . For further
information regarding a change under this
section, contact Renay France at (202)
317-7003 (not a toll-free number) .
.02 Conformity election by bank after
previous election automatically revoked .
(1) Description of change . This change
applies to a bank that wants to change
its method of accounting for bad debts
by making the conformity election under
§ 1 .166-2(d)(3)(iii)(C)(3) .
(2) Applicability . This change only ap-
plies to a bank (as defined in § 1.166-2(d)
(4)(i)) that:
(a) is subject to supervision by Federal
authorities, or by state authorities main-
taining substantially equivalent standards;
(b) has previously adopted or elected
to change to the method of accounting for
bad debts described in § 1 .166-2(d)(3);
(c) has had that previous election au-
tomatically revoked under § 1 .166-2(d)(3)
(iv)(C);
(d) meets the express determination
requirement of § 1 .166-2(d)(3)(iii)(D) for
the year of change; and
(e) now seeks the consent of the Com-
missioner to make an election under
§ 1 .166-2(d)(3)(iii)(C)(3) .
(3) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
4 .02 is “211 .”
(5) Contact information . For further
information regarding a change under this
section, contact K . Scott Brown at (202)
317-6945 (not a toll-free number) .
SECTION 5 . INTEREST EXPENSE
(§163) AND AMORTIZABLE BOND
PREMIUM (§ 171)
.01 Revocation of § 171(c) election .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for amortizable
bond premium by revoking its § 171(c)
election . Under § 171(c), a taxpayer that
holds certain taxable bonds may elect to
amortize any bond premium on the bonds
in accordance with regulations prescribed
by the Secretary . Sections 1 .171-1 through
1 .171-5 provide rules relating to the amor-
tization of bond premium by a taxpayer .
Section 1 .171-4 provides the procedures
to make a § 171(c) election to amortize
bond premium .
(2) Revocation of election . The revoca-
tion of a § 171(c) election applies to all
taxable bonds that are held by the taxpayer
on the first day of the first taxable year for
which the revocation is effective (year of
change), and to all taxable bonds that are
subsequently acquired by the taxpayer .
(3) Manner of making change . This
change is made using a cut-off basis and
applies only to taxable bonds held on or
after the beginning of the year of change .

Bulletin No. 2019–48 1115 November 25, 2019
Accordingly, a § 481(a) adjustment is nei-
ther permitted nor required .
Under the cut-off basis, for taxable
bonds held at the beginning of the year
of change, the taxpayer may not amor-
tize any remaining bond premium on the
bonds . Because the cut-off basis is pre-
scribed for this change, the basis of any
bond, adjusted for amounts previously
amortized during the period of the elec-
tion, is not affected by the revocation .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
5 .01 is “16 .”
(5) Additional requirements . On a
statement attached to the Form 3115, the
taxpayer must provide:
(a) the reason(s) for revoking the elec-
tion; and
(b) a description of the method by
which, and the date on which, the taxpay-
er made the § 171(c) election that is pro-
posed to be revoked .
(6) Audit protection . Any audit pro-
tection applicable to this change under
section 8 of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, does not preclude the Com-
missioner from examining the method
used by the taxpayer to determine the
amount of amortizable bond premium un-
der § 171(b) for a taxable year prior to the
year of change .
(7) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
.02 Change to comply with § 163(e)(3) .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method or methods of accounting to
comply with the requirements of § 163(e)
(3), which defers certain deductions attrib-
utable to original issue discount debt in-
struments held by related foreign persons .
Any portion of the original issue discount
will not be allowable as a deduction to the
U .S . person issuer until paid .
(2) Accelerated § 481(a) adjustment
period in certain situations . In addition
to the circumstances set forth in section
7 .03(4) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, the § 481 adjustment period
provided in section 7 .03 of Rev . Proc .
2015-13 will be accelerated for a U .S .
person with a remaining balance of a
§ 481(a) adjustment that arose by reason
of a change in method of accounting de-
scribed in this section 5 .02 if a debt instru-
ment subject to the change is paid off, re-
tired, or significantly modified within the
meaning of § 1 .1001-3 prior to the end of
the § 481(a) adjustment period . The por-
tion of the remaining § 481(a) adjustment
attributable to the debt instrument must be
taken into account in the taxable year the
debt instrument is paid off, retired, or sig-
nificantly modified within the meaning of
§ 1 .1001-3 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
5 .02 is “212 .”
(4) Contact information . For further
information regarding a change under this
section, contact Michael Kaercher at (202)
317-6934 (not a toll-free number) .
SECTION 6 . DEPRECIATION OR
AMORTIZATION (§ 56(a)(1), 56(g)
(4)(A), 167, 168, 197, 280F(a), 1400I,
1400L, or 1400N(d), OR FORMER
§ 168)
.01 Impermissible to permissible meth-
od of accounting for depreciation or
amortization .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to change from an
impermissible to a permissible method of
accounting for depreciation or amortiza-
tion (depreciation) for any item of depre-
ciable or amortizable property under the
taxpayer’s present or proposed method of
accounting:
(i) for which the taxpayer used the im-
permissible method of accounting in at
least two taxable years immediately pre-
ceding the year of change (but see section
6 .01(1)(b) of this revenue procedure for
property placed in service in the taxable
year immediately preceding the year of
change);
(ii) for which the taxpayer is making
a change in method of accounting under
§ 1 .446-1(e)(2)(ii)(d);
(iii) for which depreciation is deter-
mined under § 56(a)(1), § 56(g)(4)(A) (as
in effect on the day before the date of en-
actment of Public Law 115-97, 131 Stat .
2054 (Dec . 22, 2017) (the “Act”)), § 167,
§168, §197, §1400I, or §1400L(c), under
§ 168 prior to its amendment in 1986 (for-
mer § 168), or under any additional first
year depreciation deduction provision of
the Code (for example, § 168(k), § 168(l),
§ 1400L(b), or § 1400N(d)); and
(iv) that is owned by the taxpayer at
the beginning of the year of change (but
see section 6 .07 of this revenue procedure
for property disposed of before the year of
change) .
(b) Taxpayer has not adopted a method
of accounting for the item of property . If a
taxpayer does not satisfy section 6 .01(1)
(a)(i) of this revenue procedure for an item
of depreciable or amortizable property be-
cause this item of property is placed in
service by the taxpayer in the taxable year
immediately preceding the year of change
(“1-year depreciable property”), the tax-
payer may change from the impermissible
method of determining depreciation to the
permissible method of determining depre-
ciation for the 1-year depreciable proper-
ty by filing a Form 3115 for this change,
provided the § 481(a) adjustment reported
on the Form 3115 includes the amount of
any adjustment that is attributable to all
property (including the 1-year depreciable
property) subject to the Form 3115 . Alter-
natively, the taxpayer may change from
the impermissible method of determining
depreciation to the permissible method
of determining depreciation for a 1-year
depreciable property by filing an amend-
ed federal tax return for the property’s
placed-in-service year prior to the date the
taxpayer files its federal tax return for the
taxable year succeeding the placed-in-ser-
vice year .
(c) Inapplicability . This change does
not apply to:
(i) any property to which § 1016(a)(3)
(regarding property held by a tax-exempt
organization) applies;
(ii) a taxpayer that is required under
§ 263A and the regulations thereunder to
capitalize the costs with respect to which
the taxpayer wants to change its method
of accounting under this section 6 .01 if
the taxpayer is not capitalizing these costs,
unless the taxpayer concurrently chang-
es its method to capitalize these costs in
conjunction with a change to a UNICAP
method under section 12 .01, 12 .02, 12 .08,
or 12 .12 of this revenue procedure (as ap-
plicable);

November 25, 2019 1116 Bulletin No. 2019–48
(iii) any property for which a taxpayer
is making a change in depreciation under
§ 1 .446-1(e)(2)(ii)(d)(2)(vi) or (vii);
(iv) any property subject to § 167(g)
regarding property depreciated under the
income forecast method;
(v) any § 1250 property that a taxpayer
is reclassifying to an asset class of Rev .
Proc. 87-56, 1987-2 C.B. 674 (as clarified
and modified by Rev. Proc. 88-22, 1988-
1 C .B . 785), or Rev . Proc . 83-35, 1983-
1 C .B . 745, as appropriate, that does not
explicitly include § 1250 property (for
example, asset class 57 .0, Distributive
Trades and Services);
(vi) any property for which a taxpay-
er is revoking a timely valid election,
or making a late election, under § 167,
§ 168, § 179, §1400I, § 1400L(c), for-
mer § 168, § 13261(g)(2) or (3) of the
Revenue Reconciliation Act of 1993
(1993 Act), 1993-3 C .B . 1, 128 (relat-
ing to amortizable § 197 intangibles),
or any additional first year depreciation
deduction provision of the Code (for ex-
ample, § 168(k), § 168(l), § 1400L(b),
or § 1400N(d)) . A taxpayer may request
consent to revoke or make the election
by submitting a request for a letter ruling
under Rev . Proc . 2019-1, 2019-1 I .R .B .
1 (or successor) . However, if a taxpayer
is revoking or making an election under
§ 179, see § 179(c) and § 1 .179-5 . See
§ 1 .446-1(e)(2)(ii)(d)(3)(iii);
(vii) any property for which depreci-
ation is determined under § 56(g)(4)(A)
(as in effect on the day before the date of
enactment of the Act) or § 167 (other than
under § 168, § 1400I, § 1400L(c), former
§ 168, or any additional first year depreci-
ation deduction provision of the Code (for
example, § 168(k), § 168(l), § 1400L(b),
or § 1400N(d))) and a taxpayer is changing
the useful life of the property . A change in
the useful life of property is corrected by
adjustments in the applicable taxable year
provided under § 1 .446-1(e)(2)(ii)(d)(5)
(iv) . However, this section 6 .01(1)(c)(vii)
does not apply if the taxpayer is changing
to or from a useful life, recovery period, or
amortization period that is specifically as-
signed by the Code (for example, § 167(f)
(1), § 168(c)), the regulations thereunder,
or other guidance published in the Inter-
nal Revenue Bulletin and, therefore, this
change is a change in method of account-
ing (unless section 6 .01(1)(c)(xv) of this
revenue procedure applies) . See § 1 .446-
1(e)(2)(ii)(d)(3)(i);
(viii) any depreciable property for
which the use changes in the hands of the
same taxpayer . See § 1 .446-1(e)(2)(ii)(d)
(3)(ii);
(ix) any property for which depre-
ciation is determined in accordance
with § 1 .167(a)-11 (regarding the Class
Life Asset Depreciation Range System
(ADR));
(x) any change in method of account-
ing involving a change from deducting the
cost or other basis of any property as an
expense to capitalizing and depreciating
the cost or other basis, or vice versa (but
see section 11 .08 of this revenue proce-
dure for making such a change in meth-
od of accounting under the final tangible
property regulations);
(xi) any change in method of account-
ing involving a change from one permissi-
ble method of accounting for the property
to another permissible method of account-
ing for the property . For example:
(A) a change from the straight-line
method of depreciation to the income
forecast method of depreciating for vid-
eocassettes . See Rev . Rul . 89-62, 1989-1
C .B . 78; or
(B) a change from charging the depre-
ciation reserve with costs of removal and
crediting the depreciation reserve with
salvage proceeds to deducting costs of re-
moval as an expense (provided the costs of
removal are not required to be capitalized
under any provision of the Code, such as
§ 263(a)) and including salvage proceeds
in taxable income (see section 6 .02 of this
revenue procedure for making this change
for property for which depreciation is de-
termined under § 167);
(xii) any change in method of account-
ing involving both a change from treating
the cost or other basis of the property as
nondepreciable or nonamortizable prop-
erty to treating the cost or other basis of
the property as depreciable or amortizable
property and the adoption of a method
of accounting for depreciation requiring
an election under § 167, § 168, §1400I,
§ 1400L(c), former § 168, § 13261(g)(2)
or (3) of the 1993 Act, or any additional
first year depreciation deduction provi-
sion of the Code (for example, § 168(k),
§ 168(l), § 1400L(b), or § 1400N(d)) (for
example, a change in the treatment of
the space consumed in landfills placed in
service in 2006 from nondepreciable to
depreciable property (assuming section
6 .01(1)(c)(xiii) of this revenue procedure
does not apply) and the making of an
election under §168(f)(1) to depreciate
this property under the unit-of-production
method of depreciation under § 167);
(xiii) any change in method of account-
ing for any item of income or deduction
other than depreciation, even if the change
results in a change in computing deprecia-
tion under § 1 .446-1(e)(2)(ii)(d)(2)(i), (ii),
(iii), (iv), (v), (vi), (vii), or (viii) . For ex-
ample, a change in method of accounting
involving:
(A) a change in inventory costs (for ex-
ample, when property is reclassified from
inventory property to depreciable prop-
erty, or vice versa) (but see section 11 .02
of this revenue procedure for making a
change in method of accounting from in-
ventory property to depreciable property
for unrecoverable line pack gas or unre-
coverable cushion gas, and section 11 .06
of this revenue procedure for making a
change in method of accounting from in-
ventory property to depreciable property
for rotable spare parts); or
(B) a change in the character of a trans-
action from sale to lease, or vice versa (but
see section 6 .03 of this revenue procedure
for making this change);
(xiv) a change from determining de-
preciation under § 168 to determining
depreciation under former § 168 for any
property subject to the transition rules in
§ 203(b) or § 204(a) of the Tax Reform
Act of 1986, 1986-3 (Vol . 1) C .B . 1, 60-
80;
(xv) any change in the placed-in-ser-
vice date of a depreciable or amortizable
property . This change is corrected by ad-
justments in the applicable taxable year
provided under § 1 .446-1(e)(2)(ii)(d)(5)
(v); or
(xvi) any property for which the tax-
payer has claimed a federal income tax
credit (e.g., the rehabilitation credit under
§ 47) .
(2) Certain eligibility rules inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change . If
during any of the five taxable years end-
ing with the year of change, a taxpayer re-
quested or made a change in method of ac-

Bulletin No. 2019–48 1117 November 25, 2019
counting from expensing to capitalizing,
or vice versa, the cost or other basis of an
asset, the eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13 is not applicable
to a change under this section 6 .01 for that
same asset .
(3) Additional requirements . A taxpay-
er also must comply with the following:
(a) Permissible method of accounting
for depreciation . A taxpayer must change
to a permissible method of accounting for
depreciation for the item of depreciable
or amortizable property . The permissible
method of accounting is the same method
that determines the depreciation allowable
for the item of property (as provided in
section 6 .01(7) of this revenue procedure) .
(b) Statements required . A taxpayer
(including a qualified small taxpayer as
defined in section 6.01(4)(b) of this rev-
enue procedure) must provide the follow-
ing statements, if applicable, and attach
them to the completed Form 3115:
(i) a detailed description of the present
and proposed methods of accounting . A
general description of these methods of
accounting is unacceptable (for example,
MACRS to MACRS, erroneous method
to proper method, claiming less than the
depreciation allowable to claiming the de-
preciation allowable);
(ii) to the extent not provided elsewhere
on the Form 3115, a statement describing
the taxpayer’s business or income-pro-
ducing activities . Also, if the taxpayer has
more than one business or income-pro-
ducing activity, a statement describing the
taxpayer’s business or income-producing
activity in which the item of property at
issue is primarily used by the taxpayer;
(iii) to the extent not provided else-
where on the Form 3115, a statement of
the facts and law supporting the proposed
method of accounting, new classification
of the item of property, and new asset
class in, as appropriate, Rev . Proc . 87-56
or Rev . Proc . 83-35 . If the taxpayer is the
owner and lessor of the item of property
at issue, the statement of the facts and law
supporting the new asset class also must
describe the business or income-produc-
ing activity in which that item of property
is primarily used by the lessee;
(iv) to the extent not provided else-
where on the Form 3115, a statement iden-
tifying the year in which the item of prop-
erty was placed in service by the taxpayer;
(v) if any item of property is public
utility property within the meaning of
§ 168(i)(10) or former § 167(I)(3)(A), as
applicable, a statement providing that the
taxpayer agrees to the following addition-
al terms and conditions:
(A) a normalization method of ac-
counting (within the meaning of former
§ 167(I)(3)(G), former § 168(e)(3)(B), or
§ 168(i)(9), as applicable) will be used for
the public utility property subject to the
Form 3115;
(B) as of the beginning of the year of
change, the taxpayer will adjust its de-
ferred tax reserve account or similar re-
serve account in the taxpayer’s regulatory
books of account by the amount of the de-
ferral of federal income tax liability asso-
ciated with the § 481(a) adjustment appli-
cable to the public utility property subject
to the Form 3115; and
(C) within 30 calendar days of filing
the federal income tax return for the year
of change, the taxpayer will provide a
copy of the completed Form 3115 to any
regulatory body having jurisdiction over
the public utility property subject to the
Form 3115;
(vi) if the taxpayer is changing the clas-
sification of an item of § 1250 property
placed in service after August 19, 1996, to
a retail motor fuels outlet under § 168(e)
(3)(E)(iii), a statement containing the fol-
lowing representation: “For purposes of
§ 168(e)(3)(E)(iii) of the Internal Revenue
Code, the taxpayer represents that (A) 50
percent or more of the gross revenue gen-
erated from the item of § 1250 property is
from the sale of petroleum products (not
including gross revenue from related ser-
vices, such as the labor cost of oil changes
and gross revenue from the sale of non-
petroleum products such as tires and oil
filters), (B) 50 percent or more of the floor
space in the item of property is devoted to
the sale of petroleum products (not includ-
ing floor space devoted to related services,
such as oil changes and floor space devot-
ed to nonpetroleum products such as tires
and oil filters), or (C) the item of § 1250
property is 1,400 square feet or less .”; and
(vii) if the taxpayer is changing the
classification of an item of property from
§ 1250 property to § 1245 property under
§ 168 or former § 168, a statement of the
facts and law supporting the new § 1245
property classification, and a statement
containing the following representation:
“Each item of depreciable property that
is the subject of the Form 3115 filed un-
der section 6 .01 of Rev . Proc . 2019-43 for
the year of change beginning [Insert the
date], and that is reclassified from [Insert,
as appropriate: nonresidential real prop-
erty, residential rental property, qualified
leasehold improvement property, quali-
fied restaurant property, qualified retail
improvement property, qualified improve-
ment property as defined in § 168(e)(6) (as
amended by § 13204 of the Act), 19-year
real property, 18-year real property, or
15-year real property] to an asset class of
[Insert, as appropriate, either: Rev. Proc.
87-56, 1987-2 C.B. 674, or Rev. Proc.
83-35, 1983-1 C.B. 745] that does not ex-
plicitly include § 1250 property, is § 1245
property for depreciation purposes .”
(4) Reduced filing requirement for
qualified small taxpayers .
(a) In general. A qualified small tax-
payer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16c, 17, and 19;
(v) Part IV, all lines except line 25; and
(vi) Schedule E .
(b) Definition of qualified small tax-
payer. A “qualified small taxpayer” is
a taxpayer whose average annual gross
receipts, as determined under § 1 .263(a)-
3(h)(3), for the three preceding taxable
years is less than or equal to $10,000,000 .
(5) Section 481(a) adjustment . Be-
cause the adjusted basis of the property
is changed as a result of a method change
made under this section 6 .01 (see section
6 .01(6) of this revenue procedure), items
are duplicated or omitted . Accordingly,
this change is made with a § 481(a) adjust-
ment . This adjustment may result in either
a negative § 481(a) adjustment (a decrease
in taxable income) or a positive § 481(a)
adjustment (an increase in taxable in-
come) and may be a different amount for
regular tax, alternative minimum tax, and
adjusted current earnings purposes . This

November 25, 2019 1118 Bulletin No. 2019–48
§ 481(a) adjustment equals the differ-
ence between the total amount of depre-
ciation taken into account in computing
taxable income for the property under the
taxpayer’s present method of accounting
(including the amount attributable to any
property described in section 6 .01(1)(b) of
this revenue procedure that is included in
the taxpayer’s Form 3115), and the total
amount of depreciation allowable for the
property under the taxpayer’s proposed
method of accounting (as determined un-
der section 6 .01(7) of this revenue proce-
dure, and including the amount attribut-
able to any property described in section
6 .01(1)(b) of this revenue procedure that
is included in the taxpayer’s Form 3115),
for open and closed years prior to the year
of change . However, the amount of the
§ 481(a) adjustment must be adjusted to
account for the proper amount of the de-
preciation allowable that is required to
be capitalized under any provision of the
Code (for example, § 263A) at the begin-
ning of the year of change .
(6) Basis adjustment . As of the begin-
ning of the year of change, the basis of
depreciable property to which this section
6.01 applies must reflect the reductions
required by § 1016(a)(2) for the depreci-
ation allowable for the property (as deter-
mined under section 6 .01(7) of this reve-
nue procedure) .
(7) Meaning of depreciation allowable .
(a) In general . Section 6 .01(7) of this
revenue procedure provides the amount of
the depreciation allowable determined un-
der § 56(a)(1), § 56(g)(4)(A) (as in effect
on the day before the date of enactment of
the Act), § 167, § 168, § 197, §1400I, or
§ 1400L(c), or former § 168 . This amount,
however, may be limited by other provi-
sions of the Code (for example, § 280F) .
(b) Section 56(a)(1) property . The de-
preciation allowable for any taxable year
for property for which depreciation is de-
termined under § 56(a)(1) is determined
by using the depreciation method, recov-
ery period, and convention provided for
under § 56(a)(1) that applies for the prop-
erty’s placed-in-service date .
(c) Section 56(g)(4)(A) property . The
depreciation allowable for any taxable
year for property for which depreciation
is determined under § 56(g)(4)(A) (as in
effect on the day before the date of enact-
ment of the Act) is determined by using
the depreciation method, recovery period
or useful life, as applicable, and conven-
tion provided for under § 56(g)(4)(A)
(as in effect on the day before the date of
enactment of the Act) that applies for the
property’s placed-in-service date .
(d) Section 167 property . Generally, for
any taxable year, the depreciation allow-
able for property for which depreciation
is determined under § 167, is determined
either:
(i) under the depreciation method ad-
opted by the taxpayer for the property; or
(ii) if that depreciation method does not
result in a reasonable allowance for depre-
ciation or the taxpayer has not adopted a
depreciation method for the property, un-
der the straight-line depreciation method .
For determining the estimated useful
life and salvage value of the property, see
§ 1 .167(a)-1(b) and (c), respectively .
The depreciation allowable for any tax-
able year for property subject to § 167(f)
(regarding certain property excluded from
§ 197) is determined by using the depre-
ciation method and useful life prescribed
in § 167(f) . If computer software is de-
preciated under § 167(f)(1) and is quali-
fied property (as defined in § 168(k)(2)
as amended by the Act and § 1 .168(k)-2),
qualified property (as defined in § 168(k)
(2) as in effect on the day before the date
of enactment of the Act and § 1 .168(k)-1),
50-percent bonus depreciation property
(as defined in § 168(k)(4) (as in effect on
the day before the date of enactment of
the Economic Stimulus Act of 2008, Pub .
L . No . 110-185, 122 Stat . 613 (February
13, 2008)) and § 1.168(k)-1), qualified
disaster assistance property (as defined in
§ 168(n)(2) (as in effect on the day before
the date of enactment of the Tax Technical
Corrections Act of 2018, Pub . L . No . 115-
141, Division U, 132 Stat . 1211 (March
23, 2018)), qualified New York Liberty
Zone (Liberty Zone) property (as defined
in § 1400L(b)(2) (as in effect on the day
before the date of enactment of the Tax
Technical Corrections Act of 2018) and
§ 1.1400L(b)-1), qualified Gulf Opportu-
nity Zone (GO Zone) property (as defined
in § 1400N(d)(2) (as in effect on the day
before the date of enactment of the Tax
Technical Corrections Act of 2018) and
sections 2 .02 and 2 .03 of Notice 2006-77,
2006-2 C.B. 590, as clarified, modified,
and amplified by Notice 2007-36, 2007-
1 C.B. 1000), specified Gulf Opportunity
Zone extension property (GO Zone exten-
sion property) (as defined in § 1400N(d)
(6) (as in effect on the day before the date
of enactment of the Tax Technical Correc-
tions Act of 2018) and section 4 of Notice
2007-36), or qualified Recovery Assis-
tance (RA) property (as defined in sections
2 .02 and 2 .03 of Notice 2008-67, 2008-32
I .R .B . 307), the depreciation allowable for
that computer software under § 167(f)(1)
is also determined by taking into account
the additional first year depreciation de-
duction provided by § 168(k), § 168(n) (as
in effect on the day before the date of en-
actment of the Tax Technical Corrections
Act of 2018), § 1400L(b) (as in effect on
the day before the date of enactment of the
Tax Technical Corrections Act of 2018),
or § 1400N(d) (as in effect on the day
before the date of enactment of the Tax
Technical Corrections Act of 2018), or by
§ 15345(a)(1) and (d)(1) of the Food, Con-
servation, and Energy Act of 2008, Pub .
L . No . 110-246, 122 Stat . 1651 (June 18,
2008), as applicable, unless the taxpayer
made a timely valid election not to deduct
any additional first year depreciation for
the computer software .
(e) Section 168 property . The depreci-
ation allowable for any taxable year for
property for which depreciation is deter-
mined under § 168, is determined as fol-
lows:
(i) by using either:
(A) the general depreciation system in
§ 168(a); or
(B) the alternative depreciation sys-
tem in § 168(g) if the property is re-
quired to be depreciated under the al-
ternative depreciation system pursuant
to § 168(g)(1) or other provisions of the
Code (for example, property described in
§ 263A(e)(2)(A) or § 280F(b)(1)) . Prop-
erty required to be depreciated under the
alternative depreciation system pursu-
ant to § 168(g)(1) includes property in a
class (as set out in § 168(e)) for which
the taxpayer made a timely valid election
under § 168(g)(7);
(ii) if the property is qualified property,
50-percent bonus depreciation property,
qualified disaster assistance property, Lib-
erty Zone property, GO Zone property, GO
Zone extension property, or RA property,
by also taking into account the additional
first year depreciation deduction provided

Bulletin No. 2019–48 1119 November 25, 2019
by § 168(k), § 168(n) (as in effect on the
day before the date of enactment of the
Tax Technical Corrections Act of 2018),
§ 1400L(b) (as in effect on the day before
the date of enactment of the Tax Technical
Corrections Act of 2018), or § 1400N(d)
(as in effect on the day before the date of
enactment of the Tax Technical Correc-
tions Act of 2018), or by § 15345(a)(1)
and (d)(1) of the Food, Conservation, and
Energy Act of 2008, as applicable, unless
the taxpayer made a timely valid election
not to deduct the additional first year de-
preciation (or made a deemed election not
to deduct the additional first year depreci-
ation; for further guidance, see, for exam-
ple, Rev . Proc . 2002-33, 2002-1 C .B . 963,
Rev . Proc . 2003-50, 2003-2 C .B . 119, No-
tice 2006-77, Notice 2008-67, section 5 of
Rev . Proc . 2011-26, 2011-16 I .R .B . 664,
Rev . Proc . 2015-48, 2015-40 I .R .B . 469,
or Rev . Proc . 2019-33, 2019-34 I .R .B .
662) for the class of property (as defined
in § 1 .168(k)-2(f)(1)(ii), § 1 .168(k)-1(e)
(2), § 1 .1400L(b)-1(e)(2), or section 4 .02
of Notice 2006-77, as applicable) in which
that property is included;
(iii) if the property is qualified second
generation biofuel plant property (as de-
fined in § 168(l)(2) and (3)) or qualified
cellulosic biofuel plant property (as de-
fined in former § 168(l)(2) and (3)), by
also taking into account the additional
first year depreciation deduction provided
by § 168(l)(1), unless the taxpayer made
a timely valid election not to deduct the
additional first year depreciation for the
property; and
(iv) if the property is qualified reuse
and recycling property (as defined in
§ 168(m)(2)), by also taking into account
the additional first year depreciation de-
duction provided by § 168(m)(1), unless
the taxpayer made a timely valid election
not to deduct the additional first year de-
preciation for the property .
(f) Section 197 property . The amorti-
zation allowable for any taxable year for
an amortizable § 197 intangible (including
any property for which a timely election
under § 13261(g)(2) of the 1993 Act was
made) is determined in accordance with
§ 1 .197-2(f) .
(g) Former § 168 property . The depre-
ciation allowable for any taxable year for
property subject to former § 168 is deter-
mined by using either:
(i) the accelerated method of cost re-
covery applicable to the property (for ex-
ample, for 5-year property, the recovery
method under former § 168(b)(1)); or
(ii) the straight-line method applicable
to the property if the property is required
to be depreciated under the straight-line
method (for example, property described
in former § 168(f)(2) or former § 280F(b)
(2)) or if the taxpayer elected to determine
the depreciation allowance under the op-
tional straight-line percentage (for exam-
ple, the straight-line method in former
§ 168(b)(3)) .
(h) Qualified revitalization building .
The depreciation allowable for any tax-
able year for any qualified revitalization
building (as defined in § 1400I(b)(1) (as in
effect on the day before the date of enact-
ment of the Tax Technical Corrections Act
of 2018)) for which the taxpayer has made
a timely valid election under § 1400I(a) is
determined as follows:
(i) if the taxpayer elected to deduct
one-half of any qualified revitalization
expenditures (as defined in § 1400I(b)(2)
and as limited by § 1400I(c) (as in effect
on the day before the date of enactment
of the Tax Technical Corrections Act of
2018)) chargeable to a capital account
with respect to the qualified revitalization
building for the taxable year in which the
building is placed in service by the tax-
payer, the depreciation allowable for the
qualified revitalization building’s placed-
in-service year is equal to one-half of the
qualified revitalization expenditures for
the building and the depreciation allow-
able for the remaining depreciable basis
of the qualified revitalization building for
its placed-in-service year and subsequent
taxable years is determined using the
general depreciation system of § 168(a)
or the alternative depreciation system of
§ 168(g), as applicable; or
(ii) if the taxpayer elected to amortize
all of the qualified revitalization expen-
ditures chargeable to a capital account
with respect to the qualified revitalization
building ratably over the 120-month pe-
riod beginning with the month in which
the building is placed in service, the de-
preciation allowable for the qualified re-
vitalization expenditures is determined
in accordance with this election and the
depreciation allowable for the remaining
depreciable basis of the qualified revital-
ization building is determined using the
general depreciation system of § 168(a)
or the alternative depreciation system of
§ 168(g), as applicable .
(i) Qualified New York Liberty Zone
leasehold improvement property . The
depreciation allowable for any taxable
year for qualified New York Liberty Zone
leasehold improvement property (as de-
fined in § 1400L(c)(2) (as in effect on the
day before the date of enactment of the
Tax Technical Corrections Act of 2018))
is determined by using the depreciation
method and recovery period prescribed in
§ 1400L(c) (as in effect on the day before
the date of enactment of the Tax Techni-
cal Corrections Act of 2018) unless the
taxpayer made a timely valid election un-
der § 1400L(c)(5) (as in effect on the day
before the date of enactment of the Tax
Technical Corrections Act of 2018) not to
use that recovery period .
(8) Concurrent automatic change .
(a) A taxpayer making this change for
more than one asset for the same year of
change should file a single Form 3115
for all such assets and provide a single
net § 481(a) adjustment for all the chang-
es included in that Form 3115 . If one or
more of the changes in that single Form
3115 generate a negative § 481(a) adjust-
ment and other changes in that same Form
3115 generate a positive § 481(a) adjust-
ment, the taxpayer may provide a single
negative § 481(a) adjustment for all the
changes that are included in that Form
3115 generating such adjustment and a
single positive § 481(a) adjustment for all
the changes that are included in that Form
3115 generating such adjustment . For ex-
ample, a taxpayer files a single Form 3115
to change the depreciation methods, re-
covery periods, and/or conventions under
§ 168(a) resulting from the reclassification
of two computers from nonresidential real
property to 5-year property, one office
desk from nonresidential real property to
7-year property, and two office desks from
5-year property to 7-year property . On
that Form 3115, the taxpayer must pro-
vide either (i) a single net § 481(a) adjust-
ment that covers all the changes resulting
from all of these reclassifications, or (ii)
a single negative § 481(a) adjustment that
covers the changes resulting from the re-
classifications of the two computers and
one office desk from nonresidential real

November 25, 2019 1120 Bulletin No. 2019–48
property to 5-year property and 7-year
property, respectively, and a single pos-
itive § 481(a) adjustment that covers the
changes resulting from the reclassifica-
tions of the two office desks from 5-year
property to 7-year property .
(b) A taxpayer making both this
change and a change to a UNICAP meth-
od under section 12 .01, 12 .02, 12 .08, or
12 .12 of this revenue procedure (as appli-
cable) for the same year of change should
file a single Form 3115 for both changes,
in which case the taxpayer must enter the
designated automatic accounting method
change numbers for both changes on the
appropriate line on that Form 3115 . See
section 6 .03(1)(b) of Rev . Proc . 2015-13
for information on making concurrent
changes. For example, a qualified small
taxpayer must include on the single Form
3115 the information required by section
6 .01(4)(a) of this revenue procedure for
this change and the information required
by the lines on Form 3115 applicable
to the UNICAP method change, includ-
ing Part II line 14 and 15, Part IV, and
Schedule D, and must include a separate
response to each line on Form 3115 that
is applicable to both changes (such as
Part II lines 6b, 7, 8b, 14, and, as appli-
cable for this change, Part IV) for which
the taxpayer’s response is different for
this change and the change to a UNICAP
method .
(9) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .01 is “7 .”
(10) Contact information . For further
information regarding a change under this
section, contact James Liechty at (202)
317-7005 (not a toll-free number) .
.02 Permissible to permissible method
of accounting for depreciation .
(1) Description of change . This change
applies to a taxpayer that wants to change
from a permissible method of accounting
for depreciation under § 56(g)(4)(A)(iv)
(as in effect on the day before the date
of enactment of the Act) or § 167 to an-
other permissible method of accounting
for depreciation under § 56(g)(4)(A)(iv)
(as in effect on the day before the date
of enactment of Public Law 115-97, 131
Stat . 2054 (Dec . 22, 2017) (the “Act”)) or
§ 167 . Pursuant to § 1 .167(a)-7(a) and (c),
a taxpayer may account for depreciable
property either by treating each individual
asset as an account or by combining two
or more assets in a single account and, for
each account, depreciation allowances are
computed separately .
(2) Applicability .
(a) In general . This change applies to
any taxpayer wanting to make a change
in method of accounting for depreciation
specified in section 6.02(4) of this reve-
nue procedure for the property in an ac-
count:
(i) for which the present and proposed
methods of accounting for depreciation
specified in section 6.02(4) of this revenue
procedure are permissible methods for the
property under § 56(g)(4)(A)(iv) (as in
effect on the day before the date of enact-
ment of the Act) or § 167; and
(ii) that is owned by the taxpayer at the
beginning of the year of change .
(b) Inapplicability . This change does
not apply to:
(i) a taxpayer that is required under
§ 263A and the regulations thereunder to
capitalize the costs with respect to which
the taxpayer wants to change its method
of accounting under this section 6 .02 if
the taxpayer is not capitalizing these costs,
unless the taxpayer concurrently chang-
es its method to capitalize these costs in
conjunction with a change to a UNICAP
method under section 12 .01, 12 .02, 12 .08,
or 12 .12 of this revenue procedure (as ap-
plicable);
(ii) any property to which § 1016(a)(3)
(regarding property held by a tax-exempt
organization) applies;
(iii) any property described in § 167(f)
(regarding certain property excluded from
§ 197);
(iv) any property subject to § 167(g)
(regarding property depreciated under the
income forecast method);
(v) any property for which depreciation
is determined under § 56(a)(1), § 56(g)(4)
(A)(i), (ii), (iii), or (v) (as in effect on the
day before the date of enactment of the
Act), § 168, § 1400I (as in effect on the
day before the date of enactment of the
Tax Technical Corrections Act of 2018,
Pub . L . No . 115-141, Division U, 132 Stat .
1211 (March 23, 2018)), § 1400L(c) (as in
effect on the day before the date of enact-
ment of the Tax Technical Corrections Act
of 2018), § 168 prior to its amendment in
1986 (former § 168), or any additional first
year depreciation deduction provision of
the Code (for example, § 168(k), § 168(l),
§ 1400L(b) (as in effect on the day before
the date of enactment of the Tax Technical
Corrections Act of 2018), or § 1400N(d)
(as in effect on the day before the date of
enactment of the Tax Technical Correc-
tions Act of 2018));
(vi) any property that the taxpayer elect-
ed under § 168(f)(1) or former § 168(e)(2)
to exclude from the application of, respec-
tively, § 168 or former § 168;
(vii) any property for which depreci-
ation is determined in accordance with
§ 1 .167(a)-11 (ADR);
(viii) any depreciable property for
which the taxpayer is changing the depre-
ciation method pursuant to § 1 .167(e)-1(b)
(change from declining-balance method
to straight-line method), § 1 .167(e)-1(c)
(certain changes for § 1245 property),
or § 1 .167(e)-1(d) (certain changes for
§ 1250 property) . These changes must be
made prospectively and are not permitted
under the cited regulations for property
for which the depreciation is determined
under § 168, § 1400I (as in effect on the
day before the date of enactment of the
Tax Technical Corrections Act of 2018),
§ 1400L(c) (as in effect on the day before
the date of enactment of the Tax Technical
Corrections Act of 2018), former § 168,
or any additional first year depreciation
deduction provision of the Code (for ex-
ample, § 168(k), § 168(l), § 1400L(b) (as
in effect on the day before the date of en-
actment of the Tax Technical Corrections
Act of 2018), or § 1400N(d) (as in effect
on the day before the date of enactment
of the Tax Technical Corrections Act of
2018)); or
(ix) any distributor commissions (as
defined by section 2 of Rev. Proc. 2000-
38, 2000-2 C.B. 310, as modified by Rev.
Proc . 2007-16, 2007-1 C .B . 358) for which
the taxpayer is changing the useful life
under the distribution fee period method
or the useful life method (both described
in Rev . Proc . 2000-38) . A change in this
useful life is corrected by adjustments in
the applicable taxable year provided under
§ 1 .446-1(e)(2)(ii)(d)(5)(iv) .
(3) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .

Bulletin No. 2019–48 1121 November 25, 2019
(4) Changes covered . This section 6 .02
only applies to the following changes in
methods of accounting for depreciation:
(a) a change from the straight-line
method to the sum-of-the-years-digits
method, the sinking fund method, the
unit-of-production method, or the declin-
ing-balance method using any proper per-
centage of the straight-line rate;
(b) a change from the declining-bal-
ance method using any percentage of the
straight-line rate to the sum-of-the-years-
digits method, the sinking fund method,
or the declining-balance method using a
different proper percentage of the straight-
line rate;
(c) a change from the sum-of-the-years-
digits method to the sinking fund method,
the declining-balance method using any
proper percentage of the straight-line rate,
or the straight-line method;
(d) a change from the unit-of-produc-
tion method to the straight-line method;
(e) a change from the sinking fund
method to the straight-line method, the
unit-of-production method, the sum-of-
the-years-digits method, or the declin-
ing-balance method using any proper per-
centage of the straight-line rate;
(f) a change in the interest factor used
in connection with a compound interest
method or sinking fund method;
(g) a change in averaging convention
as set forth in § 1 .167(a)-10(b) . Howev-
er, as specifically provided in § 1.167(a)-
10(b), in any taxable year in which an av-
eraging convention substantially distorts
the depreciation allowance for the taxable
year, it may not be used (see Rev . Rul . 73-
202, 1973-1 C .B . 81);
(h) a change from charging the de-
preciation reserve with costs of removal
and crediting the depreciation reserve
with salvage proceeds to deducting costs
of removal as an expense and including
salvage proceeds in taxable income as
set forth in § 1 .167(a)-8(e)(2) . See Rev .
Rul . 74-455, 1974-2 C .B . 63 . This sec-
tion 6 .02 applies to this change, however,
only if:
(i) the change is applied to all items in
the account for which the change is being
made; and
(ii) the removal costs are not required
to be capitalized under any provision of
the Code (for example, § 263(a), 263A, or
280B);
(i) a change from crediting the depreci-
ation reserve with the salvage proceeds re-
alized on normal retirement sales to com-
puting and recognizing gains and losses
on the sales (see Rev . Rul . 70-165, 1970-1
C .B . 43);
(j) a change from crediting ordinary
income (including the combination meth-
od of crediting the lesser of estimated
salvage value or actual salvage proceeds
to the depreciation reserve, with any ex-
cess of salvage proceeds over estimated
salvage value credited to ordinary in-
come) with the salvage proceeds realized
on normal retirement sales, to computing
and recognizing gains and losses on the
sales (see Rev . Rul . 70-166, 1970-1 C .B .
44);
(k) a change from item accounting for
specific assets to multiple asset account-
ing (pooling) for the same assets, or vice
versa;
(l) a change from one type of multiple
asset accounting (pooling) for specific as-
sets to a different type of multiple asset
accounting (pooling) for the same assets;
(m) a change from one method de-
scribed in Rev . Proc . 2000-38 for amortiz-
ing distributor commissions (as defined by
section 2 of Rev . Proc . 2000-38) to anoth-
er method described in Rev . Proc . 2000-38
for amortizing distributor commissions; or
(n) a change from pooling to a single
asset, or vice versa, for distributor com-
missions (as defined by section 2 of Rev.
Proc . 2000-38) for which the taxpayer is
using the distribution fee period method
or the useful life method (both described
in Rev . Proc . 2000-38) .
(5) Additional requirements . A taxpay-
er also must comply with the following:
(a) Basis for depreciation . At the be-
ginning of the year of change, the basis
for depreciation of property to which this
change applies is the adjusted basis of the
property as provided in § 1011 at the end
of the taxable year immediately preced-
ing the year of change (determined under
taxpayer’s present method of accounting
for depreciation) . If applicable under the
taxpayer’s proposed method of account-
ing for depreciation, this adjusted basis is
reduced by the estimated salvage value of
the property (for example, a change to the
straight-line method) .
(b) Rate of depreciation . The rate of de-
preciation for property changed to:
(i) the straight-line or the sum-of-the-
years-digits method of depreciation must
be based on the remaining useful life of
the property as of the beginning of the
year of change; or
(ii) the declining-balance method of
depreciation must be based on the useful
life of the property measured from the
placed-in-service date, and not the expect-
ed remaining life from the date the change
becomes effective .
(c) Regulatory requirements . For
changes in method of depreciation to the
sum-of-the-years-digits or declining-bal-
ance method, the property must meet the
requirements of § 1 .167(b)-0 or 1 .167(c)-
1, as appropriate .
(d) Public utility property . If any item
of property is public utility property with-
in the meaning of former § 167(l)(3)(A),
the taxpayer (including a qualified small
taxpayer as defined in section 6.01(4)(b)
of this revenue procedure) must attach to
the Form 3115 a statement providing that
the taxpayer agrees to the following addi-
tional terms and conditions:
(i) a normalization method of ac-
counting within the meaning of former
§ 167(l)(3)(G) will be used for the pub-
lic utility property subject to the Form
3115; and
(ii) within 30 calendar days of filing the
federal income tax return for the year of
change, the taxpayer will provide a copy
of the completed Form 3115 to any reg-
ulatory body having jurisdiction over the
public utility property subject to the Form
3115 .
(6) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(e) Part IV, line 25; and
(f) Schedule E .
(7) Section 481(a) adjustment . Because
the adjusted basis of the property is not
changed as a result of a method change

November 25, 2019 1122 Bulletin No. 2019–48
made under this section 6 .02, no items are
being duplicated or omitted . Accordingly,
a § 481(a) adjustment is neither required
nor permitted .
(8) Concurrent automatic change .
(a) A taxpayer making this change for
more than one asset for the same year of
change should file a single Form 3115 for
all such assets .
(b) A taxpayer making both this change
and a change to a UNICAP method un-
der section 12 .01, 12 .02, 12 .08, or 12 .12
of this revenue procedure (as applicable)
for the same year of change should file
a single Form 3115 for both changes, in
which case the taxpayer must enter the
designated automatic accounting method
change numbers for both changes on the
appropriate line on that Form 3115 . See
section 6 .03(1)(b) of Rev . Proc . 2015-13
for information on making concurrent
changes. For example, a qualified small
taxpayer must include on the single Form
3115 the information required by section
6 .02(6) of this revenue procedure for this
change and the information required by
the lines on Form 3115 applicable to the
UNICAP method change, including Part
II line 14 and 15, Part IV, and Schedule
D, and must include a separate response to
each line on Form 3115 that is applicable
to both changes (such as Part II lines 6b, 7,
8b, 14, and, as applicable for this change,
Part IV) for which the taxpayer’s response
is different for this change and the change
to a UNICAP method .
(9) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .02 is “8 .”
(10) Contact information . For further
information regarding a change under
this section, contact Bruce Chang at (202)
317-7005 (not a toll-free number) .
.03 Sale, lease, or financing transac-
tions .
(1) Description of change and scope .
(a) Applicability . This change applies
to a taxpayer that wants to change its
method of accounting from:
(i) improperly treating property as sold
by the taxpayer to properly treating prop-
erty as leased or financed by the taxpayer;
(ii) improperly treating property as
leased by the taxpayer to properly treating
property as sold or financed by the taxpay-
er;
(iii) improperly treating property as fi-
nanced by the taxpayer to properly treat-
ing property as sold or leased by the tax-
payer;
(iv) improperly treating property as
purchased by the taxpayer to properly
treating property as leased by the taxpay-
er; and
(v) improperly treating property as
leased by the taxpayer to properly treating
property as purchased by the taxpayer .
(b) Inapplicability . This change does
not apply to:
(i) a rent-to-own dealer that wants to
change its method of accounting for rent-
to-own contracts described in section 3 of
Rev . Proc . 95-38, 1995-2 C .B . 397; or
(ii) a taxpayer that holds assets for sale
or lease, if any asset so held is not the sub-
ject of a sale or lease transaction as of the
beginning of the year of change .
(2) Manner of making the change .
A taxpayer changing its method of ac-
counting under this section 6 .03 must
submit a statement with the Form 3115
that provides the name of the counter-
party to the sale, lease, or financing
transactions as of the beginning of the
year of change .
(3) No ruling on the characterization
of any transaction as a sale, lease, or fi-
nancing transaction . The consent granted
under section 9 of Rev . Proc . 2015-13 for
a change specified in this section 6.03 is
not a determination by the Commission-
er that the taxpayer has properly charac-
terized any transaction as a sale, lease, or
financing transaction and does not create
any presumption that the proposed char-
acterization of any transaction as a sale,
lease, or financing transaction is permis-
sible . The director will ascertain wheth-
er the taxpayer’s characterization of any
transaction as a sale, lease, or financing
transaction is permissible .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .03 is “10 .”
(5) Contact information . For further
information regarding a change under this
section, contact Edward Schwartz at (202)
317-7006 (not a toll-free number) .
.04 Change in general asset account
treatment due to a change in the use of
MACRS property .
(1) Description of change . This change
applies to a taxpayer that wants to change
the method of accounting for general as-
set account treatment of MACRS prop-
erty (as defined in § 1.168(b)-1(a)(2))
to the method of accounting provided in
§ 1 .168(i)-1(c)(2)(ii)(I) or § 1 .168(i)-1(h)
(2), which applies when there is a change
in the use of MACRS property pursuant to
§ 1 .168(i)-4(d) .
(2) Manner of making change .
(a) The change is made on a modified
cut-off basis (as defined in § 1.446-1(e)(2)
(ii)(d)(5)(iii)) and, thus, the adjusted de-
preciable basis of the MACRS property as
of the beginning of the year of change is
recovered using the proposed method of
accounting for general asset account treat-
ment . Accordingly, a § 481(a) adjustment
is neither permitted nor required . See
§ 1 .168(i)-1(h)(2)(ii) and (iii) for more in-
formation regarding how to establish the
general asset account when a change in
the use of MACRS property occurs pursu-
ant to § 1 .168(i)-4(d) .
(b) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(v) Part IV, line 25; and
(vi) Schedule E .
(3) Concurrent automatic change . A
taxpayer making this change for more
than one asset for the same year of change
should file a single Form 3115 for all such
assets .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .04 is “87 .”
(5) Contact information . For further
information regarding a change under this

Bulletin No. 2019–48 1123 November 25, 2019
section, contact Elizabeth Binder at (202)
317-7005 (not a toll-free number) .
.05 Change in method of accounting
for depreciation due to a change in the use
of MACRS property .
(1) Description of change . This change
applies to a taxpayer that wants to (a)
change the method of accounting for de-
preciation of MACRS property (as de-
fined in § 1.168(b)-1(a)(2)) to the method
of accounting for depreciation provided
in § 1 .168(i)-4, which applies when there
is a change in the use of MACRS prop-
erty, or (b) revoke the election provided
in § 1 .168(i)-4(d)(3)(ii) to disregard a
change in the use of MACRS property .
See § 1 .168(i)-4(g)(2) .
(2) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(e) Part IV, all lines except line 25; and
(f) Schedule E .
(3) Section 481(a) adjustment . A tax-
payer changing its method of accounting
under this section 6 .05 is required to cal-
culate a § 481(a) adjustment as of the first
day of the year of change as if the pro-
posed method of accounting had always
been used by the taxpayer beginning with
the taxable year in which the change in the
use of the MACRS property occurred by
the taxpayer .
(4) Concurrent automatic change . A
taxpayer making this change for more
than one asset for the same year of change
should file a single Form 3115 for all such
assets and provide a single net § 481(a)
adjustment for all the changes included
in that Form 3115 . If one or more of the
changes in that single Form 3115 generate
a negative § 481(a) adjustment and other
changes in that same Form 3115 generate
a positive § 481(a) adjustment, the taxpay-
er may provide a single negative § 481(a)
adjustment for all the changes that are in-
cluded in that Form 3115 generating such
adjustment and a single positive § 481(a)
adjustment for all the changes that are in-
cluded in that Form 3115 generating such
adjustment .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .05 is “88 .”
(6) Contact information . For further
information regarding a change under this
section, contact Elizabeth Binder at (202)
317-7005 (not a toll-free number) .
.06 Depreciation of qualified non-per-
sonal use vans and light trucks .
(1) Description of change . This change
applies to a taxpayer that wants to change
the method of accounting for depreciation
for certain vehicles in accordance with
§ 1 .280F-6(f)(2)(iv) . Section 1 .280F-6(f)
(2)(iv) applies to a truck or van that is a
qualified nonpersonal use vehicle as de-
fined under § 1.274-5T(k), was placed
in service by the taxpayer before July 7,
2003, and was treated by the taxpayer as a
passenger automobile under § 1 .280F-6T
as in effect prior to July 7, 2003 . If the tax-
payer files Form 3115, in accordance with
§ 1 .280F-6(f)(2)(iv), the treatment of the
truck or van will be changed from proper-
ty to which § 280F(a) applies to property
to which § 280F(a) does not apply .
(2) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(e) Part IV, all lines except line 25; and
(f) Schedule E .
(3) Concurrent automatic change . A
taxpayer making this change for more
than one asset for the same year of change
should file a single Form 3115 for all such
assets and provide a single net § 481(a)
adjustment for all the changes included
in that Form 3115 . If one or more of the
changes in that single Form 3115 generate
a negative § 481(a) adjustment and other
changes in that same Form 3115 generate
a positive § 481(a) adjustment, the taxpay-
er may provide a single negative § 481(a)
adjustment for all the changes that are in-
cluded in that Form 3115 generating such
adjustment and a single positive § 481(a)
adjustment for all the changes that are in-
cluded in that Form 3115 generating such
adjustment .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .06 is “89 .”
(5) Contact information . For further
information regarding a change under this
section, contact Bernard Harvey at (202)
317-7005 (not a toll-free number) .
.07 Impermissible to permissible meth-
od of accounting for depreciation or
amortization for disposed depreciable or
amortizable property .
(1) Description of change . This change
applies to a taxpayer that wants to make
the change in method of accounting for
depreciation or amortization (depreci-
ation) provided under section 3 of Rev .
Proc . 2007-16, 2007-1 C .B . 358, for an
item of depreciable or amortizable proper-
ty that has been disposed of by the taxpay-
er . Section 3 of Rev . Proc . 2007-16 allows
a taxpayer to make a change in method of
accounting for depreciation for the dis-
posed property if the taxpayer used an
impermissible method of accounting for
depreciation for the property under which
the taxpayer did not take into account any
depreciation allowance, or did take into
account some depreciation but less than
the depreciation allowable, in the year of
change (as defined in section 6.07(4) of
this revenue procedure) or any prior tax-
able year .
(2) Applicability .
(a) In general . Except as provided in
section 6 .07(2)(b) of this revenue proce-
dure, this section 6 .07 applies to a taxpay-
er that is changing from an impermissible
method of accounting for depreciation
to a permissible method of accounting
for depreciation for any item of depre-
ciable or amortizable property subject to
§§ 167, 168, 197, 1400I, or 1400L(c), to
former § 168, or to any additional first
year depreciation deduction provision of
the Code (for example, § 168(k), § 168(l),
§ 1400L(b), or § 1400N(d)):

November 25, 2019 1124 Bulletin No. 2019–48
(i) that has been disposed of by the
taxpayer during the year of change (as
defined in section 6.07(4) of this revenue
procedure); and
(ii) for which the taxpayer did not take
into account any depreciation allowance,
or did take into account some deprecia-
tion but less than the depreciation allow-
able (hereinafter, both are referred to as
“claimed less than the depreciation allow-
able”), in the year of change (as defined in
section 6 .07(4) of this revenue procedure)
or any prior taxable year .
(b) Inapplicability . This section 6 .07
does not apply to:
(i) any property to which § 1016(a)(3)
(regarding property held by a tax-exempt
organization) applies;
(ii) any property for which a taxpayer
is revoking a timely valid depreciation
election, or making a late depreciation
election, under the Code or regulations
thereunder, or under other guidance pub-
lished in the Internal Revenue Bulletin
(including under § 13261(g)(2) or (3) of
the Revenue Reconciliation Act of 1993
(1993 Act), 1993-3 C .B . 1, 128 (relating
to amortizable § 197 intangibles));
(iii) any property for which the taxpay-
er deducted the cost or other basis of the
property as an expense; or
(iv) any property disposed of by the
taxpayer in a transaction to which a non-
recognition section of the Code applies
(for example, § 1031, transactions subject
to § 168(i)(7)(B)) . However, this section
6 .07(2)(b)(iv) does not apply to property
disposed of by the taxpayer in a § 1031 or
§ 1033 transaction if the taxpayer elects
under § 1 .168(i)-6(i) and (j) to treat the
entire basis (that is, both the exchanged
and excess basis (as defined in § 1.168(i)-
6(b)(7) and (8), respectively) of the re-
placement MACRS property (as defined
in § 1 .168(i)-6(b)(1)) as property placed
in service by the taxpayer at the time of
replacement and treat the adjusted depre-
ciable basis of the relinquished MACRS
property (as defined in § 1.168(i)-6(b)(2))
as being disposed of by the taxpayer at the
time of disposition .
(3) Manner of making the change .
(a) Change made on an original return
for the year of change . This change may
be made on a taxpayer’s timely filed (in-
cluding any extension) original federal tax
return for the year of change (as defined
in section 6 .07(4) of this revenue proce-
dure), provided the taxpayer files the orig-
inal Form 3115 in accordance with section
6 .03(1)(a) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419 .
(b) Change made on an amended re-
turn for the year of change . This change
may also be made on an amended federal
tax return for the year of change (as de-
fined in section 6.07(4) of this revenue
procedure), provided:
(i) the taxpayer files the original Form
3115 with the taxpayer’s amended fed-
eral tax return for the year of change (as
defined in section 6.07(4) of this revenue
procedure) prior to the expiration of the
period of limitation for assessment under
§ 6501(a) for the taxable year in which the
item of depreciable or amortizable prop-
erty was disposed of by the taxpayer; and
(ii) the taxpayer’s amended federal tax
return for the year of change (as defined
in section 6 .07(4) of this revenue proce-
dure) includes the adjustments to taxable
income and any collateral adjustments to
taxable income or tax liability (for exam-
ple, adjustments to the amount or char-
acter of the gain or loss of the disposed
depreciable or amortizable property)
resulting from the change in method of
accounting for depreciation made by the
taxpayer under this section 6 .07 .
(4) Year of change . The year of change
for this change is the taxable year in which
the item of depreciable or amortizable
property was disposed of by the taxpayer .
(5) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(d) and (f) of Rev . Proc . 2015-13
do not apply to this change .
(6) Filing requirements .
(a) Notwithstanding section 6 .03(1)(a)
of Rev . Proc . 2015-13, a taxpayer making
this change in accordance with section
6 .07(3)(b) of this revenue procedure must
attach the original Form 3115 to the tax-
payer’s timely filed amended federal tax
return for the year of change and must file
the required copy (with signature) of the
Form 3115 with the IRS in Ogden, UT,
no later than when the original Form 3115
is filed with the amended federal tax re-
turn for the year of change . If a taxpayer
is making this change in accordance with
section 6 .07(3)(a) of this revenue proce-
dure, the filing requirements in section
6 .03(1)(a) of Rev . Proc . 2015-13 apply .
(b) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(v) Part IV, all lines except line 25; and
(vi) Schedule E .
(7) Section 481(a) adjustment period .
A taxpayer must take the entire § 481(a)
adjustment into account in computing tax-
able income for the year of change .
(8) Concurrent automatic change . A
taxpayer making this change for more
than one asset for the same year of change
should file a single Form 3115 for all such
assets .
(9) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .07 is “107 .”
(10) Contact information . For further
information regarding a change under this
section, contact James Liechty at (202)
317-7005 (not a toll-free number) .
.08 Tenant construction allowances .
(1) Description of change and scope .
(a) Applicability . This change applies
to a taxpayer that wants to change its
method of accounting for tenant construc-
tion allowances:
(i) from improperly treating the taxpay-
er as having a depreciable interest in the
property subject to the tenant construction
allowances for federal income tax purpos-
es to properly treating the taxpayer as not
having a depreciable interest in such prop-
erty for federal income tax purposes; or
(ii) from improperly treating the tax-
payer as not having a depreciable interest
in the property subject to the tenant con-
struction allowances for federal income
tax purposes to properly treating the tax-
payer as having a depreciable interest in
such property for federal income tax pur-
poses .
(b) Inapplicability . This change does
not apply to:

Bulletin No. 2019–48 1125 November 25, 2019
(i) any tenant construction allowance
that qualifies under § 110;
(ii) any portion of a tenant construction
allowance that is not expended on depre-
ciable property; or
(iii) any amount expended for depre-
ciable property in excess of the tenant
construction allowance .
(2) Definition . For purposes of this sec-
tion 6 .08, the term “tenant construction
allowance(s)” means any amount received
by a lessee from a lessor to construct, ac-
quire, or improve property for use by the
lessee pursuant to a lease .
(3) Manner of making the change . A
taxpayer changing its method of account-
ing under this section 6 .08 must submit
the following information:
(a) If a lessee is filing the Form 3115,
the lessee must submit a statement with
the Form 3115 that provides the amount
of the tenant construction allowance re-
ceived by the lessee, the amount of such
tenant construction allowance expended
by the lessee on property, and the name
of the lessor that provided the tenant con-
struction allowance .
(b) If a lessor is filing the Form 3115,
the lessor must submit a statement with
the Form 3115 that provides the amount
of the tenant construction allowance pro-
vided to the lessee and the name of the les-
see that received such tenant construction
allowance .
(4) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change in accordance with sec-
tion 6 .08(3)(a) of this revenue procedure:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(e) Part IV, line 25; and
(f) Schedule E .
(5) No ruling on which party has the
depreciable interest in the property sub-
ject to tenant construction allowances .
The consent granted under section 9 of
Rev. Proc. 2015-13 for a change specified
in this section 6 .08 is not a determination
by the Commissioner that the taxpayer has
properly determined that the taxpayer has,
or does not have, a depreciable interest
in the property subject to the tenant con-
struction allowances for federal income
tax purposes and does not create any pre-
sumption that the proposed determination
of which party has the depreciable interest
in such property is permissible . The direc-
tor will ascertain whether the taxpayer’s
determination of which party has the de-
preciable interest in the property subject
to the tenant construction allowances is
permissible .
(6) Concurrent automatic change . A
taxpayer making this change for more
than one asset for the same year of change
should file a single Form 3115 for all such
assets .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .08 is “145 .”
(8) Contact information . For further
information regarding a change under this
section, contact Elizabeth Binder at (202)
317-7005 (not a toll-free number) .
.09 Safe harbor method of accounting
for determining the depreciation of cer-
tain tangible assets used by wireless tele-
communications carriers under Rev. Proc.
2011-22 .
(1) Description of change . This change
applies to a taxpayer that is within the
scope of Rev . Proc . 2011-22, 2011-18
I .R .B . 737, and wants to change to the
recovery periods described in section 5
of Rev . Proc . 2011-22 and any collateral
change to the depreciation methods for all,
or some of, the assets listed in that section .
(2) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018) to
make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(e) Part IV, all lines except line 25; and
(f) Schedule E .
(3) Concurrent automatic change . A
taxpayer making this change for more
than one asset for the same year of change
should file a single Form 3115 for all such
assets and provide a single net § 481(a) ad-
justment for all the changes included in that
Form 3115 . If one or more of the changes
in that single Form 3115 generate a nega-
tive § 481(a) adjustment and other changes
in that same Form 3115 generate a positive
§ 481(a) adjustment, the taxpayer may pro-
vide a single negative § 481(a) adjustment
for all the changes that are included in that
Form 3115 generating such adjustment and
a single positive § 481(a) adjustment for all
the changes that are included in that Form
3115 generating such adjustment .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
6 .09 is “157 .”
(5) Contact information . For further
information regarding a change under this
section, contact Charles Magee at (202)
317-7005 (not a toll-free number) .
.10 Partial dispositions of tangible de-
preciable assets to which the IRS’s adjust-
ment pertains (§ 168; § 1.168(i)-8) .
(1) Description of change .
(a) Applicability . This change ap-
plies to a taxpayer that is described in
§ 1 .168(i)-8(d)(2)(iii) and, pursuant to
§ 1 .168(i)-8(d)(2)(iii), that wants to make
the partial disposition election specified in
§ 1 .168(i)-8(d)(2)(i) to the disposition of a
portion of an asset to which the IRS’s ad-
justment (as described in § 1 .168(i)-8(d)
(2)(iii)) pertains .
(b) Inapplicability . This change does
not apply to:
(i) Any asset of which the disposed
portion was a part that is not owned by
the taxpayer at the beginning of the year
of change; or
(ii) Any partial disposition election
specified in § 1.168(i)-8(d)(2)(i) that is not
made pursuant to § 1 .168(i)-8(d)(2)(iii)
(for example, this change does not apply
to the partial disposition election specified
in § 1 .168(i)-8(d)(2)(i) that is made pursu-
ant to § 1 .168(i)-8(d)(2)(iv)) .
(2) Change in method of accounting .
The IRS will treat the making of the late
election specified in section 6.10(1) of this
revenue procedure as a change in method
of accounting .

November 25, 2019 1126 Bulletin No. 2019–48
(3) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(d) and (f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, do not apply to this
change .
(4) Manner of making change .
(a) A qualified small taxpayer, as de-
fined in section 6.01(4)(b) of this reve-
nue procedure, is required to complete
only the following information on Form
3115 (Rev . December 2018) to make this
change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(v) Part IV, all lines except line 25; and
(vi) Schedule E .
(b) A taxpayer (including a qualified
small taxpayer) making this change must:
(i) Apply § 1 .168(i)-8(h)(1) and (3)
(accounting for asset disposed of);
(ii) If the asset (as determined under
§ 1 .168(i)-8(c)(4)) of which the disposed
portion is a part is properly included in
one of the asset classes 00 .11 through 00 .4
of Rev . Proc . 87-56, 1987-2 C .B . 674,
classify the replacement portion of such
asset under the same asset class as the dis-
posed portion of the asset in the taxable
year in which the replacement portion is
placed in service by the taxpayer;
(iii) If the taxpayer’s present meth-
od of accounting is not in accord with
§ 1 .168(i)-8(c)(4) (determination of asset
disposed of), change to the appropriate
asset as determined under § 1 .168(i)-8(c)
(4);
(iv) If the taxpayer continues to deduct
depreciation for the disposed portion of
the asset (as determined under § 1 .168(i)-
8(c)(4)) under the taxpayer’s present
method of accounting, change from de-
preciating such disposed portion to recog-
nizing gain or loss for the disposed por-
tion or, if § 280B and § 1 .280B-1 apply to
the disposition, change from depreciating
such disposed portion to capitalizing the
loss sustained on account of the demoli-
tion to the land on which the demolished
structure was located; and
(v) If any asset is public utility property
within the meaning of § 168(i)(10), attach
a statement to its Form 3115 providing
that the taxpayer agrees to the following
additional terms and conditions:
(A) A normalization method of ac-
counting (within the meaning of § 168(i)
(9)) will be used for the public utility
property subject to the Form 3115;
(B) Within 30 calendar days of filing
the federal income tax return for the year
of change, the taxpayer will provide a
copy of the completed Form 3115 to any
regulatory body having jurisdiction over
the public utility property subject to the
Form 3115; and
(C) As of the beginning of the year of
change, the taxpayer will adjust its de-
ferred tax reserve account or similar ac-
count in the taxpayer’s regulatory books
of account by the amount of the deferral
of federal income tax liability associated
with the § 481(a) adjustment applicable
to the public utility property subject to the
Form 3115 .
(5) Concurrent automatic change . A
taxpayer making this change for more
than one asset for the same year of change
should file a single Form 3115 for all such
assets . If the change for more than one
asset included in that Form 3115 is spec-
ified in section 6.10(1) of this revenue
procedure, the single Form 3115 should
provide a single net § 481(a) adjustment
for all such changes . If one or more of
the changes specified in section 6.10(1)
of this revenue procedure in that single
Form 3115 generate a negative § 481(a)
adjustment and other changes specified
in section 6 .10(1) of this revenue proce-
dure in that same Form 3115 generate a
positive § 481(a) adjustment, the taxpay-
er may provide a single negative § 481(a)
adjustment for all such changes that are
included in that Form 3115 generating
such negative adjustment and a single
positive § 481(a) adjustment for all such
changes that are included in that Form
3115 generating such positive adjust-
ment .
(6) Designated automatic accounting
method change number . The designated
automatic accounting method change
number for a change to the method of
accounting under this section 6 .10 is
“198 .”
(7) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .
.11 Depreciation of leasehold improve-
ments (§§ 167, 168, and 197; § 1.167(a)-4) .
(1) Description of change . This change,
as described in Rev . Proc . 2014-17, 2014-
12 I .R .B . 661, applies to a taxpayer that
wants to change its method of accounting
to comply with § 1 .167(a)-4 for leasehold
improvements in which the taxpayer has a
depreciable interest at the beginning of the
year of change:
(a) From improperly depreciating the
leasehold improvements to which § 168
applies over the term of the lease (includ-
ing renewals, if applicable) to properly
depreciating these improvements under
§ 168;
(b) From improperly amortizing
leasehold improvements to which § 197
applies over the term of the lease (includ-
ing renewals, if applicable) to properly
amortizing these improvements under
§ 197; or
(c) From improperly amortizing lease-
hold improvements to which § 167(f)(1)
applies over the term of the lease (includ-
ing renewals, if applicable) to properly
amortizing these improvements under
§ 167(f)(1) .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to a taxpayer making
this change .
(3) Manner of making change .
(a) A qualified small taxpayer, as de-
fined in section 6.01(4)(b) of this reve-
nue procedure, is required to complete
only the following information on Form
3115 (Rev . December 2018) to make this
change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19;
(v) Part IV, all lines except line 25; and
(vi) Schedule E .
(b) If any leasehold improvement is
public utility property within the meaning
of § 168(i)(10) or former § 167(l)(3)(A), a
taxpayer (including a qualified small tax-
payer) making this change must attach to
its Form 3115 a statement providing that
the taxpayer agrees to the following addi-
tional terms and conditions:

Bulletin No. 2019–48 1127 November 25, 2019
(i) A normalization method of account-
ing (within the meaning of § 168(i)(9) or
former § 167(l)(3)(G)) will be used for
the public utility property subject to the
change;
(ii) As of the beginning of the year of
change, the taxpayer will adjust its de-
ferred tax reserve account or similar ac-
count in the taxpayer’s regulatory books
of account by the amount of the deferral
of federal income tax liability associated
with the § 481(a) adjustment applicable
to the public utility property subject to the
change; and
(iii) Within 30 calendar days of filing
the federal income tax return for the year
of change, the taxpayer will provide a
copy of the completed Form 3115 to any
regulatory body having jurisdiction over
the public utility property subject to the
change .
(4) Concurrent automatic change .
(a) A taxpayer making this change for
more than one asset for the same year of
change should file a single Form 3115 for
all such assets and provide a single net
§ 481(a) adjustment for all the changes
included in that Form 3115 . If one or
more of the changes in that single Form
3115 generate a negative § 481(a) ad-
justment and other changes in that same
Form 3115 generate a positive § 481(a)
adjustment, the taxpayer may provide a
single negative § 481(a) adjustment for
all the changes that are included in that
Form 3115 generating such adjustment
and a single positive § 481(a) adjustment
for all the changes that are included in
that Form 3115 generating such adjust-
ment .
(b) A taxpayer making both this change
and a change to a UNICAP method un-
der section 12 .01, 12 .02, 12 .08, or 12 .12
of this revenue procedure (as applicable)
for the same year of change should file
a single Form 3115 for all such changes
and must enter the designated automatic
accounting method change numbers for
the changes on the appropriate line on the
Form 3115 . See section 6 .03(1)(b) of Rev .
Proc . 2015-13 for information on making
concurrent changes . For example, a qual-
ified small taxpayer must include on the
single Form 3115 the information required
by section 6 .11(3)(a) of this revenue pro-
cedure for this change and the information
required by the lines on Form 3115 appli-
cable to the UNICAP method change, in-
cluding Part II line 14 and 15, Part IV, and
Schedule D, and must include a separate
response to each line on Form 3115 that is
applicable to both changes (such as Part II
lines 6b, 7, 8b, 14, and, as applicable for
this change, Part IV) for which the taxpay-
er’s response is different for this change
and the change to a UNICAP method .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to a method of ac-
counting under this section 6 .11 is “199 .”
(6) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .
.12 Permissible to permissible method
of accounting for depreciation of MACRS
property (§ 168; §§ 1.168(i)-1, 1.168(i)-7,
and 1.168(i)-8) .
(1) Description of change .
(a) Applicability . This change, as de-
scribed in Rev . Proc . 2014-54, 2014-41
I .R .B . 675, applies to a taxpayer that
wants to make a change in method of ac-
counting for depreciation that is specified
in section 6 .12(3) of this revenue proce-
dure for an asset:
(i) to which § 168 applies (MACRS
property);
(ii) for which the present and proposed
methods of accounting are permissible
methods of accounting under § 1 .168(i)-1,
§ 1 .168(i)-7, or § 1 .168(i)-8, as applica-
ble; and
(iii) that is owned by the taxpayer at the
beginning of the year of change .
(b) Inapplicability . This change does
not apply to any property that is not de-
preciated under § 168 under the taxpayer’s
present and proposed methods of account-
ing .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to a taxpayer making
this change .
(3) Changes covered . This section 6 .12
only applies to the following changes in
methods of accounting for depreciation of
MACRS property:
(a) For the items of MACRS property
not subject to a general asset account elec-
tion under § 168(i)(4) and the regulations
thereunder—
(i) a change from single asset accounts
(or item accounts) for specific items of
MACRS property to multiple asset ac-
counts (or pools) for the same assets, or
vice versa, in accordance with § 1 .168(i)-7;
(ii) a change from grouping specific
items of MACRS property in multiple as-
set accounts to a different grouping of the
same assets in multiple asset accounts in
accordance with § 1 .168(i)-7(c);
(iii) a change in the method of iden-
tifying which assets in multiple asset
accounts or which portions of assets
have been disposed of by the taxpayer
from the specific identification method
under § 1.168(i)-8(g)(1) to the first-in,
first-out (FIFO) method of accounting
under § 1 .168(i)-8(g)(2)(i) or the mod-
ified FIFO method of accounting under
§ 1 .168(i)-8(g)(2)(ii);
(iv) a change in the method of identi-
fying which assets in multiple asset ac-
counts or which portions of assets have
been disposed of by the taxpayer from
the FIFO method of accounting under
§ 1.168(i)-8(g)(2)(i) or the modified FIFO
method of accounting under § 1 .168(i)-(g)
(2)(ii) to the specific identification method
under § 1 .168(i)-8(g)(1);
(v) a change in the method of identify-
ing which assets in multiple asset accounts
or which portions of assets have been dis-
posed of by the taxpayer from the FIFO
method of accounting under § 1 .168(i)-
8(g)(2)(i) to the modified FIFO method of
accounting under § 1 .168(i)-8(g)(2)(ii), or
vice versa;
(vi) a change in the method of iden-
tifying which mass assets (as defined in
§ 1 .168(i)-8(b)(3)) in multiple asset ac-
counts or which portions of mass assets
have been disposed of by the taxpayer
from the specific identification method
under § 1 .168(i)-8(g)(1) to a mortali-
ty dispersion table in accordance with
§ 1 .168(i)-8(g)(2)(iii);
(vii) a change in the method of iden-
tifying which mass assets (as defined in
§ 1 .168(i)-8(b)(3)) in multiple asset ac-
counts or which portions of mass assets
have been disposed of by the taxpayer
from the FIFO method of accounting
under § 1 .168(i)-8(g)(2)(i) or the mod-
ified FIFO method of accounting under
§ 1 .168(i)-8(g)(2)(ii) to a mortality disper-
sion table in accordance with § 1 .168(i)-
8(g)(2)(iii);

November 25, 2019 1128 Bulletin No. 2019–48
(viii) a change in the method of iden-
tifying which mass assets (as defined in
§ 1 .168(i)-8(b)(3)) in multiple asset ac-
counts or which portions of mass assets
have been disposed of by the taxpayer
from a mortality dispersion table in ac-
cordance with § 1 .168(i)-8(g)(2)(iii) to
the specific identification method under
§ 1 .168(i)-8(g)(1), the FIFO method of
accounting under § 1 .168(i)-8(g)(2)(i), or
the modified FIFO method of accounting
under § 1 .168(i)-8(g)(2)(ii);
(ix) if § 1 .168(i)-8(f)(2) applies (dis-
position of an asset in a multiple asset
account) and it is impracticable from the
taxpayer’s records to determine the un-
adjusted depreciable basis of the asset
disposed of, a change in the method of
determining the unadjusted depreciable
basis of all assets in the same multiple as-
set account from one reasonable method
to another reasonable method; or
(x) if § 1 .168(i)-8(f)(3) applies (dis-
position of a portion of an asset) and it is
impracticable from the taxpayer’s records
to determine the unadjusted depreciable
basis of the disposed portion of the asset,
a change in the method of determining
the unadjusted depreciable basis of all
disposed portions of the asset from one
reasonable method to another reasonable
method; and
(b) For the items of MACRS property
subject to a general asset account elec-
tion under § 168(i)(4) and the regulations
thereunder—
(i) a change from grouping specific
items of MACRS property in general as-
set accounts to a different grouping of the
same assets in general asset accounts in
accordance with § 1 .168(i)-1(c);
(ii) a change in the method of identify-
ing which assets or which portions of as-
sets have been disposed of by the taxpayer
from the specific identification method
under § 1 .168(i)-1(j)(2)(i)(A) to the FIFO
method of accounting under § 1 .168(i)-
1(j)(2)(i)(B) or the modified FIFO method
of accounting under § 1 .168(i)-1(j)(2)(i)
(C);
(iii) a change in the method of identi-
fying which assets or which portions of
assets have been disposed of by the tax-
payer from the FIFO method of account-
ing under § 1 .168(i)-1(j)(2)(i)(B) or the
modified FIFO method of accounting un-
der § 1.168(i)-1(j)(2)(i)(C) to the specific
identification method under § 1.168(i)-
1(j)(2)(i)(A);
(iv) a change in the method of identi-
fying which assets or which portions of
assets have been disposed of by the tax-
payer from the FIFO method of account-
ing under § 1 .168(i)-1(j)(2)(i)(B) to the
modified FIFO method of accounting un-
der § 1 .168(i)-1(j)(2)(i)(C), or vice versa;
(v) a change in the method of identi-
fying which mass assets (as defined in
§ 1 .168(i)-1(b)(6)) or which portions of
mass assets that are in a separate general
asset account in accordance with § 1 .168-
1(c)(2)(ii)(H), have been disposed of by
the taxpayer from the specific identifica-
tion method under § 1 .168(i)-1(j)(2)(i)(A)
to a mortality dispersion table in accor-
dance with § 1 .168(i)-1(j)(2)(i)(D);
(vi) a change in the method of iden-
tifying which mass assets (as defined in
§ 1 .168(i)-1(b)(6)) or which portions of
mass assets that are in a separate general
asset account in accordance with § 1 .168-
1(c)(2)(ii)(H), have been disposed of by
the taxpayer from the FIFO method of ac-
counting under § 1 .168(i)-1(j)(2)(i)(B) or
the modified FIFO method of accounting
under § 1 .168(i)-1(j)(2)(i)(C) to a mor-
tality dispersion table in accordance with
§ 1 .168(i)-1(j)(2)(i)(D);
(vii) a change in the method of iden-
tifying which mass assets (as defined in
§ 1 .168(i)-1(b)(6)), or which portions of
mass assets that are in a separate general
asset account in accordance with § 1 .168-
1(c)(2)(ii)(H), have been disposed of by
the taxpayer from a mortality dispersion
table in accordance with § 1 .168(i)-1(j)(2)
(i)(D) to the specific identification method
under § 1 .168(i)-1(j)(2)(i)(A), the FIFO
method of accounting under § 1 .168(i)-
1(j)(2)(i)(B), or the modified FIFO meth-
od of accounting under § 1 .168(i)-1(j)(2)
(i)(C); or
(viii) if § 1 .168(i)-1(j)(3) applies (basis
of a disposed asset or a disposed portion
of an asset in a general asset account) and
it is impracticable from the taxpayer’s re-
cords to determine the unadjusted depre-
ciable basis of the disposed asset or the
disposed portion of the asset, a change in
the method of determining the unadjusted
depreciable basis of all assets in the same
general asset account from one reasonable
method to another reasonable method .
(4) Manner of making change .
(a) The changes in methods of account-
ing specified in section 6.12(3)(a)(i) and
(ii) and section 6 .12(3)(b)(i) of this reve-
nue procedure are made using a modified
cut-off method under which the unadjust-
ed depreciable basis and the depreciation
reserve of the asset as of the beginning of
the year of change are accounted for using
the proposed method of accounting .
(i) If the change specified in section
6 .12(3)(a)(i) of this revenue procedure
is a change to a single asset account, the
new single asset account must include a
beginning balance for both the unadjust-
ed depreciable basis and the depreciation
reserve of the asset included in that single
asset account .
(ii) If the change specified in section
6 .12(3)(a)(i) or (ii) of this revenue pro-
cedure is a change to a multiple asset
account (either a new one or a different
grouping), the multiple asset account must
include a beginning balance for both the
unadjusted depreciable basis and the de-
preciation reserve . The beginning balance
for the unadjusted depreciable basis of
each multiple asset account is equal to the
sum of the unadjusted depreciable bases
as of the beginning of the year of change
for all assets included in that multiple as-
set account . The beginning balance of the
depreciation reserve of each multiple asset
account is equal to the sum of the greater
of the depreciation allowed or allowable
as of the beginning of the year of change
for all assets included in that multiple as-
set account .
(iii) The change specified in section
6 .12(3)(b)(i) of this revenue procedure re-
quires the general asset account to include
a beginning balance for both the unadjust-
ed depreciable basis and the depreciation
reserve . The beginning balance for the
unadjusted depreciable basis of each gen-
eral asset account is equal to the sum of
the unadjusted depreciable bases as of the
beginning of the year of change for all as-
sets included in that general asset account .
The beginning balance of the depreciation
reserve of each general asset account is
equal to the sum of the greater of the de-
preciation allowed or allowable as of the
beginning of the year of change for all as-
sets included in that general asset account .
(b) The changes in methods of account-
ing specified in section 6.12(3)(a)(iii),
(vi), (ix), and (x) and section 6 .12(3)(b)

Bulletin No. 2019–48 1129 November 25, 2019
(ii), (v), and (viii) of this revenue proce-
dure are made using a cut-off method and
apply to dispositions occurring on or after
the beginning of the year of change .
(c) Even though the changes in meth-
ods of accounting specified in section
6 .12(3)(a)(iv), (v), (vii), and (viii) and
section 6 .12(3)(b)(iii), (iv), (vi), and (vii)
of this revenue procedure are changes
from one permissible method of account-
ing to another permissible method of ac-
counting, these changes are made with a
§ 481(a) adjustment . However, see section
6 .12(4)(f) of this revenue procedure for
an exception . For the changes in methods
of accounting specified in section 6.12(3)
(b)(iii), (iv), (vi), and (vii) of this revenue
procedure, the § 481(a) adjustment should
be zero unless § 1 .168(i)-1(e)(3) applies to
the asset subject to the change .
(d) A qualified small taxpayer, as de-
fined in section 6.01(4)(b) of this reve-
nue procedure, is required to complete
only the following information on Form
3115 (Rev . December 2018) to make this
change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19 if the qualified small
taxpayer is not making a change in method
of accounting specified in section 6.12(3)
(a)(ix) and (x) and section 6 .12(3)(b)(viii)
of this revenue procedure;
(v) Part II, all lines except lines 13,
15b, 16c, 17, and 19 if the qualified small
taxpayer is making a change in method
of accounting specified in section 6.12(3)
(a)(ix) or (x) or section 6 .12(3)(b)(viii) of
this revenue procedure;
(vi) Part IV; and
(vii) Schedule E .
(e) If any asset subject to this change
is public utility property within the mean-
ing of § 168(i)(10), a taxpayer (includ-
ing a qualified small taxpayer) making
this change must attach to its Form 3115
a statement providing that the taxpayer
agrees to the following additional terms
and conditions:
(i) A normalization method of account-
ing (within the meaning of § 168(i)(9))
will be used for the public utility property
subject to the change;
(ii) As of the beginning of the year of
change, the taxpayer will adjust its de-
ferred tax reserve account or similar ac-
count in the taxpayer’s regulatory books
of account by the amount of the deferral
of federal income tax liability associated
with the § 481(a) adjustment applicable to
a change in method of accounting speci-
fied in section 6.12(3)(a)(iv), (v), (vii), or
(viii) or section 6 .12(3)(b)(iii), (iv), (vi),
or (vii) of this revenue procedure made
for the public utility property subject to
the change; and
(iii) Within 30 calendar days of filing
the federal income tax return for the year
of change, the taxpayer will provide a
copy of the completed Form 3115 to any
regulatory body having jurisdiction over
the public utility property subject to the
change .
(f) A taxpayer that met the scope re-
quirements of section 4 of Rev . Proc .
2015-20, 2015-9 I .R .B . 694, and that
changed its method of accounting under
section 6 .37(3)(a)(iv), (a)(v), (a)(vii), or
(a)(viii) of Rev . Proc . 2015-14 (which is
now section 6 .12(3)(a)(iv), (a)(v), (a)(vii),
or (a)(viii) of this revenue procedure) by
following section 5 of Rev . Proc . 2015-
20 is required to calculate a § 481(a) ad-
justment as of the first day of the year of
change that takes into account only dispo-
sitions in taxable years beginning on or
after January 1, 2014 .
(5) No audit protection . A taxpayer
calculating a § 481(a) adjustment under
section 6 .12(4)(f) of this revenue proce-
dure that takes into account only dispo-
sitions in taxable years beginning on or
after January 1, 2014, does not receive au-
dit protection under section 8 .01 of Rev .
Proc . 2015-13 for dispositions subject to
a change under section 6 .12(3)(a)(iv), (a)
(v), (a)(vii), or (a)(viii) of this revenue
procedure in taxable years beginning be-
fore January 1, 2014 . See section 5 .03 of
Rev . Proc . 2015-20 .
(6) Concurrent change .
(a) A taxpayer making this change for
more than one asset for the same year of
change should file a single Form 3115
for all such assets . If the change for more
than one asset included in that Form 3115
is specified in section 6.12(3)(a)(iv), (v),
(vii), or (viii) or section 6 .12(3)(b)(iii),
(iv), (vi), or (vii) of this revenue proce-
dure, the single Form 3115 also should
provide a single net § 481(a) adjustment
for all such changes . If one or more
changes specified in section 6.12(3)(a)
(iv), (v), (vii), or (viii) or section 6 .12(3)
(b)(iii), (iv), (vi), or (vii) of this reve-
nue procedure in that single Form 3115
generate a negative § 481(a) adjustment
and other changes specified in section
6 .12(3)(a)(iv), (v), (vii), or (viii) or sec-
tion 6 .12(3)(b)(iii), (iv), (vi), or (vii)
of this revenue procedure in that same
Form 3115 generate a positive § 481(a)
adjustment, the taxpayer may provide a
single negative § 481(a) adjustment for
all such changes that are included in that
Form 3115 generating such negative ad-
justment and a single positive § 481(a)
adjustment for all such changes that are
included in that Form 3115 generating
such positive adjustment .
(b) A taxpayer making this change and
any change listed in section 6 .12(6)(b)
(i)-(iv) of this revenue procedure for the
same year of change should file a single
Form 3115 for all such changes and must
enter the designated automatic accounting
method change numbers for the changes
on the appropriate line on the Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes. For example, a qualified small
taxpayer must include on the single Form
3115 the information required to be com-
pleted on Form 3115 by a qualified small
taxpayer under this revenue procedure
for each change in method of accounting
included on that Form 3115 . The listed
changes are:
(i) A change under section 6 .01 of this
revenue procedure;
(ii) A change under section 6 .13 of this
revenue procedure;
(iii) A change under section 6 .14 of this
revenue procedure;
(iv) A change under section 6 .15 of this
revenue procedure; and
(v) A change under section 11 .07(3)(c)
of this revenue procedure .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to a method of ac-
counting under this section 6 .12 is “200 .”
(8) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .

November 25, 2019 1130 Bulletin No. 2019–48
.13 Disposition of a building or struc-
tural component (§ 168; § 1.168(i)-8) .
(1) Description of change .
(a) Applicability . This change, as de-
scribed in Rev . Proc . 2014-54, 2014-41
I .R .B . 675, applies to a taxpayer that wants
to make a change in method of account-
ing that is specified in section 6.13(3) of
this revenue procedure for disposing of a
building or a structural component or dis-
posing of a portion of a building (includ-
ing its structural components) to which
the partial disposition rule in § 1 .168(i)-
8(d)(1) applies. These specified chang-
es are consistent with §§ 1 .168(i)-8(b)
(2), 1 .168(i)-8(c)(4)(ii)(A), (B), and (D),
1 .168(i)-8(f), and 1 .168(i)-8(g), as appli-
cable . This change also affects the deter-
mination of gain or loss from disposing
of the building, the structural component,
or the portion of the building (including
its structural components) and may af-
fect whether the taxpayer must capitalize
amounts paid to restore a unit of property
(as determined under § 1 .263(a)-3(e) or
(f)) under § 1 .263(a)-3(k) .
(b) Inapplicability . This change does
not apply to the following:
(i) Any asset (as determined under
§ 1 .168(i)-8(c)(4)) that is not depreciated
under § 168 under the taxpayer’s present
method of accounting and, if applicable,
under the taxpayer’s proposed method of
accounting;
(ii) Any asset subject to a general as-
set account election under § 168(i)(4) and
the regulations thereunder (but see section
6 .15 of this revenue procedure for mak-
ing a change in method of accounting for
dispositions of tangible depreciable assets
subject to a general asset account elec-
tion);
(iii) Any multiple buildings, condo-
minium units, or cooperative units that
are treated as a single building under the
taxpayer’s present method of accounting,
or will be treated as a single building un-
der the taxpayer’s proposed method of ac-
counting, pursuant to § 1 .1250-1(a)(2)(ii);
(iv) Any disposition of a portion of
an asset in a transaction described in the
last sentence in § 1 .168(i)-8(d)(1) for
which the taxpayer did not make a partial
disposition election in accordance with
§ 1 .168(i)-8(d)(2)(ii), (iii), or (iv), as ap-
plicable (but see section 6 .10 of this reve-
nue procedure for making a partial dispo-
sition election pursuant to § 1 .168(i)-8(d)
(2)(iii)); or
(v) Any demolition of a structure to
which § 280B and § 1 .280B-1 apply .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to a taxpayer making
this change .
(3) Covered changes . This section 6 .13
only applies to the following changes in
methods of accounting for a building (in-
cluding its structural components), con-
dominium unit (including its structural
components), cooperative unit (including
its structural components), or an improve-
ment or addition (including its structural
components) thereto:
(a) For purposes of applying § 1 .168(i)-
8(c)(4) (determination of asset disposed
of), a change to the appropriate asset as
determined under § 1 .168(i)-8(c)(4)(ii)
(A), (B), or (D), as applicable;
(b) If the taxpayer makes the change
specified in section 6.13(3)(a) of this rev-
enue procedure, and if the taxpayer dis-
posed of the asset as determined under
section 6 .13(3)(a) of this revenue proce-
dure in a taxable year prior to the year of
change but under its present method of ac-
counting continues to deduct depreciation
for such disposed asset, a change from
depreciating the disposed asset to recog-
nizing gain or loss upon disposition or, if
§ 280B and § 1 .280B-1 apply to the dis-
position, change from depreciating such
disposed asset to capitalizing the loss sus-
tained on account of the demolition to the
land on which the demolished structure
was located;
(c) If the taxpayer makes the change
specified in section 6.13(3)(a) of this
revenue procedure, and if the taxpayer
disposed of a portion of the asset as de-
termined under section 6 .13(3)(a) of this
revenue procedure in a transaction de-
scribed in the first sentence in § 1.168(i)-
8(d)(1) in a taxable year prior to the year
of change but under its present method of
accounting continues to deduct deprecia-
tion for such disposed portion, a change
from depreciating the disposed portion
to recognizing gain or loss upon disposi-
tion or, if § 280B and § 1 .280B-1 apply to
the disposition, change from depreciating
such disposed portion to capitalizing the
loss sustained on account of the demoli-
tion to the land on which the demolished
structure was located;
(d) If the taxpayer’s present method
of accounting for its buildings (includ-
ing their structural components), condo-
minium units (including their structural
components), cooperative units (includ-
ing their structural components), and im-
provements or additions (including its
structural components) thereto that are
depreciated under § 168 is in accord with
§ 1 .168(i)-8(c)(4)(ii)(A), (B), and (D),
and if the taxpayer disposed of an asset
as determined under § 1 .168(i)-8(c)(4)(ii)
(A), (B), or (D), as applicable, in a taxable
year prior to the year of change but under
its present method of accounting contin-
ues to deduct depreciation for such dis-
posed asset, a change from depreciating
the disposed asset to recognizing gain or
loss upon disposition or, if § 280B and §
1 .280B-1 apply to the disposition, change
from depreciating such disposed asset to
capitalizing the loss sustained on account
of the demolition to the land on which the
demolished structure was located;
(e) If the taxpayer’s present method
of accounting for its buildings (includ-
ing their structural components), condo-
minium units (including their structural
components), cooperative units (includ-
ing their structural components), and im-
provements or additions (including its
structural components) thereto that are
depreciated under § 168 is in accord with
§ 1 .168(i)-8(c)(4)(ii)(A), (B), and (D), and
if the taxpayer disposed of a portion of an
asset as determined under § 1 .168(i)-8(c)
(4)(ii)(A), (B), or (D), as applicable, in a
transaction described in the first sentence
in § 1 .168(i)-8(d)(1) in a taxable year prior
to the year of change but under its present
method of accounting continues to deduct
depreciation for such disposed portion,
a change from depreciating the disposed
portion to recognizing gain or loss upon
disposition or, if § 280B and § 1 .280B-1
apply to the disposition, change from de-
preciating such disposed portion to capi-
talizing the loss sustained on account of
the demolition to the land on which the
demolished structure was located;
(f) A change in the method of identify-
ing which assets in multiple asset accounts
or which portions of assets have been dis-
posed of from a method of accounting
not specified in § 1.168(i)-8(g)(1) or (2)

Bulletin No. 2019–48 1131 November 25, 2019
(i), (ii), or (iii) (for example, the last-in,
first-out (LIFO) method of accounting)
to a method of accounting specified in
§ 1 .168(i)-8(g)(1) or (2)(i), (ii), or (iii), as
applicable;
(g) If § 1 .168(i)-8(f)(2) applies (dis-
position of an asset in a multiple asset
account) and it is practicable from the
taxpayer’s records to determine the unad-
justed depreciable basis of the disposed
asset, a change in the method of determin-
ing the unadjusted depreciable basis of the
disposed asset from a method of not using
the taxpayer’s records to a method of us-
ing the taxpayer’s records;
(h) If § 1 .168(i)-8(f)(2) applies (dis-
position of an asset in a multiple asset
account) and it is impracticable from the
taxpayer’s records to determine the unad-
justed depreciable basis of the disposed
asset, a change in the method of determin-
ing the unadjusted depreciable basis of all
assets in the same multiple asset account
from an unreasonable method (for exam-
ple, discounting the cost of the replace-
ment asset to its placed-in-service year
cost using the Consumer Price Index) to a
reasonable method;
(i) If § 1 .168(i)-8(f)(3) applies (dis-
position of a portion of an asset) and it is
practicable from the taxpayer’s records to
determine the unadjusted depreciable ba-
sis of the disposed portion of the asset, a
change in the method of determining the
unadjusted depreciable basis of the dis-
posed portion of the asset from a method
of not using the taxpayer’s records to a
method of using the taxpayer’s records;
(j) If § 1 .168(i)-8(f)(3) applies (dis-
position of a portion of an asset) and it is
impracticable from the taxpayer’s records
to determine the unadjusted depreciable
basis of the disposed portion of the asset,
a change in the method of determining the
unadjusted depreciable basis of the dis-
posed portion of the asset from an unrea-
sonable method (for example, discounting
the cost of the replacement portion of the
asset to its placed-in-service year cost us-
ing the Consumer Price Index) to a rea-
sonable method; or
(k) A change from recognizing gain
or loss under § 1 .168(i)-8T upon the dis-
position of an asset (as determined under
§ 1 .168(i)-8(c)(4)(ii)(A), (B), or (D), as
applicable) included in a general asset
account to recognizing gain or loss upon
the disposition of the same asset under
§ 1 .168(i)-8 if: (A) the taxpayer made
the change specified in section 6.11 of
Rev . Proc . 2016-29, 2016-21 I .R .B . 880,
section 6 .34 of Rev . Proc . 2015-14, 2015-
5 I .R .B . 450, or section 6 .34 of the AP-
PENDIX to Rev . Proc . 2011-14, 2011-4
I.R.B. 330, as clarified and modified by
Rev . Proc . 2012-39, 2012-41 I .R .B . 470,
Rev . Proc . 2014-17, 2014-12 I .R .B . 661,
and Rev . Proc . 2014-54, 2014-41 I .R .B .
675 (revocation of a general asset account
election); (B) the taxpayer made a qualify-
ing disposition election under § 1 .168(i)-
1T(e)(3)(iii) in a taxable year prior to the
year of change for the disposition of such
asset; (C) the taxpayer’s present method
of accounting for such asset is in accord
with § 1 .168(i)-8(c)(4)(ii)(A), (B), or (D),
as applicable; and (D) the taxpayer recog-
nized a gain or loss under § 1 .168(i)-8T
upon the disposition of such asset in a tax-
able year prior to the year of change .
(4) Examples . The following examples
illustrate the covered changes specified in
section 6 .13(3) of this revenue procedure .
(a) Example 1 . X, a calendar-year taxpayer, ac-
quired and placed in service a building and its struc-
tural components in 2000 . In 2005, X constructed
and placed in service an addition to this building .
X depreciates the building, the addition, and their
structural components under § 168 . A change by X
to treating the original building (including its struc-
tural components) as an asset and the addition to
the building (including the structural components
of such addition) as a separate asset for disposition
purposes is a change described in section 6 .13(3)
(a) of this revenue procedure solely for purposes of
§ 1 .168(i)-8(c)(4) .
(b) Example 2 . Y, a calendar year taxpayer, ac-
quired and placed in service a building and its struc-
tural components in 1990 . Y depreciates this build-
ing and its structural components under § 168 . In
2000, a tornado damaged the roof and, as a result,
Y replaced the entire roof of the building . Y did not
recognize a loss on the retirement of the original roof
and continues to depreciate the original roof . Y also
capitalized the cost of the replacement roof and has
been depreciating this roof under § 168 since 2000 .
Because the original roof was disposed of as a result
of a casualty event described in § 165, a change by
Y from depreciating the original roof to recognizing
a loss upon its retirement is a covered change de-
scribed in section 6 .13(3)(e) of this revenue proce-
dure solely for purposes of § 1 .168(i)-8 .
(c) Example 3 . The facts are the same as in Ex-
ample 2, except a tornado did not occur, but Y still
replaced the entire roof of the building in 2000 . Be-
cause the original roof was not disposed of as a result
of any of the events described in the first sentence in
§ 1 .168(i)-8(d)(1) that require a partial disposition, a
partial disposition election must be made to change
from depreciating the original roof to recognizing a
loss upon its retirement . Pursuant to section 6 .13(1)
(b)(iv) of this revenue procedure, section 6 .13 does
not apply to the disposition of the original roof in
2000 .
(5) Manner of making change .
(a) A taxpayer (including a quali-
fied small taxpayer as defined in section
6 .01(4)(b) of this revenue procedure)
making this change must attach to its
Form 3115 a statement with the following:
(i) A description of the assets to which
this change applies;
(ii) If the taxpayer is making a change
specified in section 6.13(3)(a) of this rev-
enue procedure, a description of the assets
for disposition purposes under the taxpay-
er’s present and proposed methods of ac-
counting;
(iii) If the taxpayer is making the
change specified in section 6.13(3)(f) of
this revenue procedure, a description of
the methods of identifying which assets
have been disposed of under the taxpay-
er’s present and proposed methods of ac-
counting;
(iv) If the taxpayer is making the
change specified in section 6.13(3)(h) or
(j) of this revenue procedure, a description
of the methods of determining the unad-
justed depreciable basis of the disposed
asset or disposed portion of the asset, as
applicable, under the taxpayer’s present
and proposed methods of accounting; and
(v) If any asset is public utility prop-
erty within the meaning of § 168(i)(10),
a statement providing that the taxpayer
agrees to the following additional terms
and conditions:
(A) A normalization method of ac-
counting (within the meaning of § 168(i)
(9)) will be used for the public utility
property subject to the application;
(B) As of the beginning of the year of
change, the taxpayer will adjust its de-
ferred tax reserve account or similar ac-
count in the taxpayer’s regulatory books
of account by the amount of the deferral
of federal income tax liability associated
with the § 481(a) adjustment applicable
to the public utility property subject to the
application; and
(C) Within 30 calendar days of filing
the federal income tax return for the year
of change, the taxpayer will provide a
copy of the completed application to any
regulatory body having jurisdiction over
the public utility property subject to the
application .

November 25, 2019 1132 Bulletin No. 2019–48
(b) A qualified small taxpayer, as de-
fined in section 6.01(4)(b) of this reve-
nue procedure, is required to complete
only the following information on Form
3115 (Rev . December 2018) to make this
change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19 if the qualified small
taxpayer is not making a change in method
of accounting specified in section 6.13(3)
(h) and (j) of this revenue procedure;
(v) Part II, all lines except lines 13,
15b, 16c, 17, and 19 if the qualified small
taxpayer is making a change in method of
accounting specified in section 6.13(3)(h)
or (j) of this revenue procedure;
(v) Part IV, all lines except line 25; and
(vi) Schedule E .
(6) No ruling on asset . The consent
granted under section 9 of Rev . Proc .
2015-13 for a change specified in section
6 .13(3)(a) of this revenue procedure is not
a determination by the Commissioner that
the taxpayer is using the appropriate asset
under § 1 .168(i)-8(c)(4) for determining
what asset is disposed of by the taxpayer
and does not create any presumption that
the proposed asset is permissible under
§ 1 .168(i)-8(c)(4) . The director will ascer-
tain whether the taxpayer’s determination
of its asset under § 1 .168(i)-8(c)(4) is per-
missible .
(7) Section 481(a) adjustment .
(a) A taxpayer changing its method of
accounting under this section 6 .13 may
use statistical sampling in determining
the § 481(a) adjustment by following the
guidance provided in Rev . Proc . 2011-42,
2011-37 I .R .B . 318 .
(b) A taxpayer that met the scope re-
quirements of section 4 of Rev . Proc .
2015-20, 2015-9 I .R .B . 694, and that
changed its method of accounting under
section 6 .38 of Rev . Proc . 2015-14 (which
is now this section 6 .13) by following sec-
tion 5 of Rev . Proc . 2015-20 is required
to calculate a section § 481(a) adjustment
as of the first day of the year of change
that takes into account only dispositions in
taxable years beginning on or after Janu-
ary 1, 2014 .
(8) Section 481(a) adjustment period .
(a) A taxpayer must take the entire
amount of the § 481(a) adjustment into
account in computing taxable income for
the year of change:
(i) If the taxpayer is making the change
specified in section 6.13(3)(a) of this rev-
enue procedure and if the taxpayer recog-
nized a gain or loss under § 1 .168(i)-8T
on the disposition of the asset (or if appli-
cable, a portion thereof) in a taxable year
prior to the year of change;
(ii) If the taxpayer is making the change
specified in section 6.13(3)(k) of this reve-
nue procedure; or
(iii) If the taxpayer is a qualified tax-
payer as defined in section 4.01 of Rev.
Proc . 2015-56, 2015-49 I .R .B . 827, and
that is within the scope of section 3 of Rev .
Proc . 2015-56, and is making the change
specified in section 5.02(5)(b) of Rev.
Proc. 2015-56 on or before the first tax-
able year that the qualified taxpayer uses
the remodel-refresh safe harbor provided
in section 5 .02 of Rev . Proc . 2015-56 .
(b) If section 6 .13(8)(a) of this revenue
procedure does not apply, see section 7 .03
of Rev . Proc . 2015-13 for the § 481(a) ad-
justment period .
(c) Example. (i) Y, a fiscal year taxpayer with a
taxable year beginning December 1 and ending No-
vember 30, acquired and placed in service a building
and its structural components in 2000 . Y depreciates
this building and its structural components under
§ 168 . The roof is a structural component of the
building . Y replaced the entire roof in June 2010 . On
its federal tax return for the taxable year ended No-
vember 30, 2010, Y did not recognize a loss on the
retirement of the original roof and continues to de-
preciate the original roof . Y also capitalized the cost
of the replacement roof and has been depreciating
this roof under § 168 since June 2010 . The adjusted
depreciable basis of the original roof at the time of
its retirement in 2010 (taking into account the appli-
cable convention) is $11,000, and Y claimed depre-
ciation of $1,000 for such roof after its retirement
(taking into account the applicable convention) and
before the taxable year ended November 30, 2013
(2012 taxable year) . Also the 12-month allowable
depreciation deduction for the original roof is $500
for the 2012 taxable year, $500 for the taxable year
ended November 30, 2014 (2013 taxable year), and
$500 for the taxable year ended November 30, 2015
(2014 taxable year) .
(ii) In accordance with § 1 .168(i)-8T(c)(4)(ii)
(A) and (B) and section 6 .29(3)(a) and (b) of the AP-
PENDIX to Rev. Proc. 2011-14, as modified by Rev.
Proc. 2012-20, 2012-14 I.R.B. 700, Y filed with its
federal income tax return for the taxable year ended
November 30, 2013, a Form 3115 to treat the build-
ing as an asset and each structural component of the
building as a separate asset for disposition purposes
and also to change from depreciating the original
roof to recognizing a loss upon its retirement . The
amount of the net negative § 481(a) adjustment on
this Form 3115 is $10,000 (adjusted depreciable
basis of $11,000 for the original roof at the time of
its retirement (taking into account the applicable
convention) less depreciation of $1,000 claimed for
such roof after its retirement (taking into account the
applicable convention) and before the 2012 taxable
year) .
(iii) Y complies with § 1 .168(i)-8 beginning with
its taxable year ended November 30, 2016 (2015 tax-
able year) . For Y’s 2015 taxable year, the late partial
disposition election under section 6 .10 of Rev . Proc .
2016-29 does not apply. Y also decides not to file a
private letter ruling requesting an extension of time
under § 301 .9100-3 of the Procedure and Admin-
istration Regulations to make a partial disposition
election for the original roof . In accordance with
section 6.13(3)(a) of this revenue procedure, Y files
a Form 3115 with its federal income tax return for
the 2015 taxable year to change to treating the orig-
inal building (including its original roof and other
original structural components) as an asset and the
replacement roof as a separate asset for disposition
purposes . Because the late partial disposition elec-
tion under section 6 .10 of Rev . Proc . 2016-29 does
not apply for Y’s 2015 taxable year and Y did not
receive a private letter ruling granting an extension
of time under § 301 .9100-3 to make a partial dispo-
sition election for the original roof, Y does not rec-
ognize the net loss of $10,000 upon the retirement
of the original roof under § 1 .168(i)-8 and Y will
continue to depreciate the original roof . Thus, the
net positive § 481(a) adjustment for this change is
$8,500 (net loss of $10,000 claimed on the 2012 re-
turn for the retirement of the original roof less depre-
ciation of $1,500 for the original roof for the 2012,
2013, and 2014 taxable years) and is included in Y’s
taxable income for the 2015 taxable year .
(9) No audit protection . A taxpayer
calculating a § 481(a) adjustment under
section 6 .13(7)(b) of this revenue proce-
dure that takes into account only dispo-
sitions in taxable years beginning on or
after January 1, 2014, does not receive au-
dit protection under section 8 .01 of Rev .
Proc . 2015-13 for dispositions subject to
a change under this section 6 .13 in taxable
years beginning before January 1, 2014 .
See section 5 .04 of Rev . Proc . 2015-20 .
(10) Concurrent automatic change .
(a) A taxpayer making this change for
more than one asset for the same year of
change should file a single Form 3115 for
all such assets and provide a single net
§ 481(a) adjustment for all the changes
included in that Form 3115 . If one or
more of the changes in that single Form
3115 generate a negative § 481(a) ad-
justment and other changes in that same
Form 3115 generate a positive § 481(a)
adjustment, the taxpayer may provide a
single negative § 481(a) adjustment for
all the changes that are included in that

Bulletin No. 2019–48 1133 November 25, 2019
Form 3115 generating such negative ad-
justment and a single positive § 481(a)
adjustment for all the changes that are in-
cluded in that Form 3115 generating such
positive adjustment .
(b) A taxpayer making this change and
any change listed in section 6 .13(10)(b)
(i)-(iv) of this revenue procedure for the
same year of change should file a single
Form 3115 for all of such changes and
must enter the designated automatic ac-
counting method change numbers for the
changes on the appropriate line on the
Form 3115 . See section 6 .03(1)(b) of Rev .
Proc . 2015-13 for information on making
concurrent changes . For example, a qual-
ified small taxpayer must include on the
single Form 3115 the information required
to be completed on Form 3115 by a qual-
ified small taxpayer under this revenue
procedure for each change in method of
accounting included on that Form 3115 .
The listed changes are:
(i) A change under section 6 .01 of this
revenue procedure;
(ii) A change under section 6 .12 of this
revenue procedure;
(iii) A change under section 6 .14 of this
revenue procedure; and
(iv) A change under section 6 .15 of this
revenue procedure .
(11) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to the method of ac-
counting under this section 6 .13 is “205 .”
(12) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .
.14 Dispositions of tangible deprecia-
ble assets (other than a building or its
structural components) (§ 168; § 1.168(i)-
8) .
(1) Description of change .
(a) Applicability . This change, as de-
scribed in Rev . Proc . 2014-54, 2014-41
I .R .B . 675, applies to a taxpayer that
wants to make a change in method of
accounting that is specified in section
6 .14(3) of this revenue procedure for dis-
posing of § 1245 property or a depreciable
land improvement or disposing of a por-
tion of § 1245 property or a depreciable
land improvement to which the partial
disposition rule in § 1 .168(i)-8(d)(1) ap-
plies. These specified changes are consis-
tent with §§ 1 .168(i)-8(c)(4)(i), 1 .168(i)-
8(c)(4)(ii)(C) and (D), 1 .168(i)-8(f), and
1 .168(i)-8(g), as applicable . This change
also affects the determination of gain or
loss from disposing of the § 1245 prop-
erty, the depreciable land improvement,
or a portion of the § 1245 property or de-
preciable land improvement, and may af-
fect whether the taxpayer must capitalize
amounts paid to restore a unit of property
(as determined under § 1 .263(a)-3(e) or
(f)) under § 1 .263(a)-3(k) .
(b) Inapplicability . This change does
not apply to the following:
(i) Any asset (as determined under
§ 1 .168(i)-8(c)(4)) that is not depreciated
under § 168 under the taxpayer’s present
method of accounting and, if applicable,
under the taxpayer’s proposed method of
accounting;
(ii) Any building (including its struc-
tural components), condominium unit
(including its structural components),
cooperative unit (including its structural
components), or an improvement or addi-
tion (including its structural components)
thereto (but see section 6 .13 of this rev-
enue procedure for making this change);
(iii) Any asset subject to a general as-
set account election under § 168(i)(4) and
the regulations thereunder (but see section
6 .15 of this revenue procedure for making
a change for dispositions of tangible de-
preciable assets subject to a general asset
account election); or
(iv) Any disposition of a portion of
an asset in a transaction described in the
last sentence in § 1 .168(i)-8(d)(1) for
which the taxpayer did not make a partial
disposition election in accordance with
§ 1 .168(i)-8(d)(2)(ii), (iii), or (iv), as ap-
plicable (but see section 6 .10 of this reve-
nue procedure for making a partial dispo-
sition election pursuant to § 1 .168(i)-8(d)
(2)(iii)) .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to a taxpayer making
this change .
(3) Covered changes . This section 6 .14
only applies to the following changes in
methods of accounting for a § 1245 prop-
erty, a depreciable land improvement, or
an improvement or addition thereto:
(a) For purposes of applying § 1 .168(i)-
8(c)(4) (determination of asset disposed
of), a change to the appropriate asset as
determined under § 1 .168(i)-8(c)(4)(i), (ii)
(C), or (ii)(D), as applicable;
(b) If the taxpayer makes the change
specified in section 6.14(3)(a) of this rev-
enue procedure, and if the taxpayer dis-
posed of the asset as determined under
section 6 .14(3)(a) of this revenue proce-
dure in a taxable year prior to the year
of change but continues to deduct depre-
ciation for such disposed asset under the
taxpayer’s present method of accounting,
a change from depreciating the disposed
asset to recognizing gain or loss upon dis-
position;
(c) If the taxpayer makes the change
specified in section 6.14(3)(a) of this
revenue procedure, and if the taxpayer
disposed of a portion of the asset as de-
termined under section 6 .14(3)(a) of this
revenue procedure in a transaction de-
scribed in the first sentence in § 1.168(i)-
8(d)(1) in a taxable year prior to the year
of change but under its present method of
accounting continues to deduct deprecia-
tion for such disposed portion, a change
from depreciating the disposed portion
to recognizing gain or loss upon dispo-
sition;
(d) If the taxpayer’s present method of
accounting for its § 1245 property, depre-
ciable land improvements, or improve-
ments or additions thereto is in accord
with § 1 .168(i)-8(c)(4)(i) or (ii), as appli-
cable, and if the taxpayer disposed of an
asset as determined under § 1 .168(i)-8(c)
(4)(i) or (ii), as applicable, in a taxable
year prior to the year of change but under
its present method of accounting contin-
ues to deduct depreciation for this dis-
posed asset, a change from depreciating
the disposed asset to recognizing gain or
loss upon disposition;
(e) If the taxpayer’s present method
of accounting for its § 1245 property,
depreciable land improvements, or im-
provements or additions thereto is in ac-
cord with § 1 .168(i)-8(c)(4)(i) or (ii), as
applicable, and if the taxpayer disposed of
a portion of an asset as determined under
§ 1 .168(i)-8(c)(4)(i) or (ii), as applicable,
in a transaction described in the first sen-
tence in § 1 .168(i)-8(d)(1) in a taxable
year prior to the year of change but under
its present method of accounting contin-
ues to deduct depreciation for such dis-
posed portion, a change from depreciating

November 25, 2019 1134 Bulletin No. 2019–48
the disposed portion to recognizing gain
or loss upon disposition;
(f) A change in the method of identify-
ing which assets in multiple asset accounts
or which portions of assets have been dis-
posed of from a method of accounting
not specified in § 1.168(i)-8(g)(1) or (2)
(i), (ii), or (iii) (for example, the last-in,
first-out (LIFO) method of accounting)
to a method of accounting specified in
§ 1 .168(i)-8(g)(1) or (2)(i), (ii), or (iii), as
applicable;
(g) If § 1 .168(i)-8(f)(2) applies (dis-
position of an asset in a multiple asset
account) and it is practicable from the
taxpayer’s records to determine the unad-
justed depreciable basis of the disposed
asset, a change in the method of determin-
ing the unadjusted depreciable basis of the
disposed asset from a method of not using
the taxpayer’s records to a method of us-
ing the taxpayer’s records;
(h) If § 1 .168(i)-8(f)(2) applies (dis-
position of an asset in a multiple asset
account) and it is impracticable from the
taxpayer’s records to determine the unad-
justed depreciable basis of the disposed
asset, a change in the method of determin-
ing the unadjusted depreciable basis of all
assets in the same multiple asset account
from an unreasonable method (for exam-
ple, discounting the cost of the replace-
ment asset to its placed-in-service year
cost using the Consumer Price Index) to a
reasonable method;
(i) If § 1 .168(i)-8(f)(3) applies (dispo-
sition of a portion of an asset) and it is
practicable from the taxpayer’s records
to determine the unadjusted deprecia-
ble basis of the disposed portion of the
asset, a change in the method of deter-
mining the unadjusted depreciable basis
of the disposed portion of the asset from
a method of not using the taxpayer’s re-
cords to a method of using the taxpayer’s
records;
(j) If § 1 .168(i)-8(f)(3) applies (dis-
position of a portion of an asset) and it is
impracticable from the taxpayer’s records
to determine the unadjusted depreciable
basis of the disposed portion of the asset,
a change in the method of determining the
unadjusted depreciable basis of the dis-
posed portion of the asset from an unrea-
sonable method (for example, discounting
the cost of the replacement portion of the
asset to its placed-in-service year cost us-
ing the Consumer Price Index) to a rea-
sonable method; or
(k) A change from recognizing gain or
loss under § 1 .168(i)-8T upon the dispo-
sition of a section 1245 property, depre-
ciable land improvement, or improvement
or addition thereto included in a general
asset account to recognizing gain or loss
upon the disposition of the same asset un-
der § 1 .168(i)-8 if: (A) the taxpayer made
the change specified in section 6.11 of
Rev . Proc . 2016-29, section 6 .34 of Rev .
Proc . 2015-14, or section 6 .34 of the AP-
PENDIX to Rev . Proc . 2011-14 (revoca-
tion of a general asset account election);
(B) the taxpayer made a qualifying dispo-
sition election under § 1 .168(i)-1T(e)(3)
(iii) in a taxable year prior to the year of
change for the disposition of such asset;
(C) the taxpayer’s present method of ac-
counting for such asset is in accord with
§ 1 .168(i)-8(c)(4)(i) or (ii), as applicable;
and (D) the taxpayer recognized a gain or
loss under § 1 .168(i)-8T on the disposition
of such asset in a taxable year prior to the
year of change .
(4) Manner of making change .
(a) A taxpayer (including a quali-
fied small taxpayer as defined in section
6 .01(4)(b) of this revenue procedure)
making this change must attach to its
Form 3115 a statement with the following:
(i) A description of the assets to which
this change applies;
(ii) If the taxpayer is making a change
specified in section 6.14(3)(a) of this rev-
enue procedure, a description of the assets
for disposition purposes under the taxpay-
er’s present and proposed methods of ac-
counting;
(iii) If the taxpayer is making the
change specified in section 6.14(3)(f) of
this revenue procedure, a description of
the methods of identifying which assets
have been disposed of under the taxpay-
er’s present and proposed methods of ac-
counting;
(iv) If the taxpayer is making the
change specified in section 6.14(3)(h) or
(j) of this revenue procedure, a description
of the methods of determining the unad-
justed depreciable basis of the disposed
asset or disposed portion of the asset, as
applicable, under the taxpayer’s present
and proposed methods of accounting; and
(v) If any asset is public utility prop-
erty within the meaning of § 168(i)(10),
a statement providing that the taxpayer
agrees to the following additional terms
and conditions:
(A) A normalization method of ac-
counting (within the meaning of § 168(i)
(9)) will be used for the public utility
property subject to the application;
(B) As of the beginning of the year of
change, the taxpayer will adjust its de-
ferred tax reserve account or similar ac-
count in the taxpayer’s regulatory books
of account by the amount of the deferral
of federal income tax liability associated
with the § 481(a) adjustment applicable
to the public utility property subject to the
application; and
(C) W ithin 30 calendar days of filing
the federal income tax return for the year
of change, the taxpayer will provide a
copy of the completed application to any
regulatory body having jurisdiction over
the public utility property subject to the
application .
(b) A qualified small taxpayer, as de-
fined in section 6.01(4)(b) of this reve-
nue procedure, is required to complete
only the following information on Form
3115 (Rev . December 2018) to make this
change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19 if the qualified small
taxpayer is not making a change in method
of accounting specified in section 6.14(3)
(h) and (j) of this revenue procedure;
(v) Part II, all lines except lines 13,
15b, 16c, 17, and 19 if the qualified small
taxpayer is making a change in method of
accounting specified in section 6.14(3)(h)
or (j) of this revenue procedure;
(v) Part IV, all lines except line 25; and
(vi) Schedule E .
(5) No ruling on asset . The consent
granted under section 9 of Rev . Proc .
2015-13 for a change specified in section
6 .14(3)(a) of this revenue procedure is not
a determination by the Commissioner that
the taxpayer is using the appropriate asset
under § 1 .168(i)-8(c)(4) for determining
what asset is disposed of by the taxpayer
and does not create any presumption that
the proposed asset is permissible under
§ 1 .168(i)-8(c)(4) . The director will ascer-

Bulletin No. 2019–48 1135 November 25, 2019
tain whether the taxpayer’s determination
of its asset under § 1 .168(i)-8(c)(4) is per-
missible .
(6) Section 481(a) adjustment .
(a) A taxpayer changing its method of
accounting under section 6 .14 of the reve-
nue procedure may use statistical sampling
in determining the § 481(a) adjustment by
following the guidance provided in Rev .
Proc . 2011-42, 2011-37 I .R .B . 318 .
(b) A taxpayer that met the scope re-
quirements of section 4 of Rev . Proc .
2015-20, 2015-9 I .R .B . 694, and that
changed its method of accounting under
section 6 .39 of Rev . Proc . 2015-14 (which
is now this section 6 .14) by following sec-
tion 5 of Rev . Proc . 2015-20 is required
to calculate a section § 481(a) adjustment
as of the first day of the year of change
that takes into account only dispositions in
taxable years beginning on or after Janu-
ary 1, 2014 .
(7) Section 481(a) adjustment period .
(a) A taxpayer must take the entire
amount of the § 481(a) adjustment into
account in computing taxable income for
the year of change:
(i) If the taxpayer is making the change
specified in section 6.14(3)(a) of this rev-
enue procedure and if the taxpayer recog-
nized a gain or loss under § 1 .168(i)-8T on
the disposition of the § 1245 property, de-
preciable land improvement, or improve-
ment or addition thereto (or if applicable,
a portion of such asset) in a taxable year
prior to the year of change; or
(ii) If the taxpayer is making the change
specified in section 6.14(3)(k) of this reve-
nue procedure .
(b) If section 6 .14(7)(a) of this revenue
procedure does not apply, see section 7 .03
of Rev . Proc . 2015-13 for the § 481(a) ad-
justment period .
(8) No audit protection . A taxpayer
calculating a § 481(a) adjustment under
section 6 .14(6)(b) of this revenue proce-
dure that takes into account only dispo-
sitions in taxable years beginning on or
after January 1, 2014, does not receive au-
dit protection under section 8 .01 of Rev .
Proc . 2015-13 for dispositions subject to
a change under this section 6 .14 in taxable
years beginning before January 1, 2014 .
See section 5 .05 of Rev . Proc . 2015-20 .
(9) Concurrent automatic change .
(a) A taxpayer making this change for
more than one asset for the same year of
change should file a single Form 3115 for
all such assets and provide a single net
§ 481(a) adjustment for all the changes in-
cluded in that Form 3115 . If one or more
of the changes in that single Form 3115
generate a negative § 481(a) adjustment
and other changes in that same Form 3115
generate a positive § 481(a) adjustment,
the taxpayer may provide a single nega-
tive § 481(a) adjustment for all the chang-
es that are included in that Form 3115
generating such negative adjustment and a
single positive § 481(a) adjustment for all
the changes that are included in that Form
3115 generating such positive adjustment .
(b) A taxpayer making this change and
any change listed in section 6 .14(9)(b)(i)-
(iv) of this revenue procedure for the same
year of change should file a single Form
3115 for all of such changes and must en-
ter the designated automatic accounting
method change numbers for the changes
on the appropriate line on the Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes. For example, a qualified small
taxpayer must include on the single Form
3115 the information required to be com-
pleted on Form 3115 by a qualified small
taxpayer under this revenue procedure
for each change in method of accounting
included on that Form 3115 . The listed
changes are:
(i) A change under section 6 .01 of this
revenue procedure;
(ii) A change under section 6 .12 of this
revenue procedure;
(iii) A change under section 6 .13 of this
revenue procedure; and
(iv) A change under section 6 .15 of this
revenue procedure .
(10) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to the method of ac-
counting under this section 6 .14 is “206 .”
(11) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .
.15 Dispositions of tangible depre-
ciable assets in a general asset account
(§ 168(i)(4); § 1.168(i)-1) .
(1) Description of change .
(a) Applicability . This change, as de-
scribed in Rev . Proc . 2014-54, 2014-41
I .R .B . 675, applies to a taxpayer that wants
to make a change in method of account-
ing that is specified in section 6.15(3) of
this revenue procedure for disposing of
an asset subject to a general asset account
election under § 168(i)(4) and the regula-
tions thereunder. These specified changes
are consistent with §§ 1 .168(i)-1(e)(1),
1 .168(i)-1(e)(2)(viii), and 1 .168(i)-1(j),
as applicable . This change also may affect
the determination of gain or loss from dis-
posing of the asset and may affect whether
the taxpayer must capitalize amounts paid
to restore a unit of property (as deter-
mined under § 1 .263(a)-3(e) or (f)) under
§ 1 .263(a)-3(k) .
(b) Inapplicability . This change does
not apply to the following:
(i) Any asset (as determined under
§ 1 .168(i)-1(e)(2)(viii)) that is not depre-
ciated under § 168 under the taxpayer’s
present method of accounting and, if ap-
plicable, proposed method of accounting;
or
(ii) Any asset not subject to a general
asset account election under § 168(i)(4)
and the regulations thereunder (but see
sections 6 .13 and 6 .14 of this revenue
procedure for making a change for dispo-
sitions of tangible depreciable assets not
subject to a general asset account elec-
tion) .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to a taxpayer making
this change .
(3) Covered changes . This section 6 .15
only applies to the following changes in
methods of accounting for an asset subject
to a general asset account election under
§ 168(i)(4) and the regulations thereunder:
(a) For purposes of applying § 1 .168(i)-
1(e)(2)(viii) (determination of asset dis-
posed of), a change to the appropriate as-
set as determined under § 1 .168(i)-1(e)(2)
(viii)(A) or (B), as applicable;
(b) A change in the method of identify-
ing which assets or which portions of as-
sets have been disposed of from a method
of accounting not specified in § 1.168(i)-
1(j)(2)(i)(A), (B), (C), or (D) (for exam-
ple, the last-in, first-out (LIFO) method
of accounting) to a method of accounting
specified in § 1.168(i)-1(j)(2)(i)(A), (B),
(C), or (D), as applicable;
(c) If § 1 .168(i)-1(j)(3) applies (ba-
sis of disposed asset or disposed portion

November 25, 2019 1136 Bulletin No. 2019–48
of an asset) and it is practicable from the
taxpayer’s records to determine the unad-
justed depreciable basis of the disposed
asset or the disposed portion of an asset,
as applicable, a change in the method of
determining the unadjusted depreciable
basis of the disposed asset or the disposed
portion of an asset, as applicable, from
a method of not using the taxpayer’s re-
cords to a method of using the taxpayer’s
records; or
(d) If § 1 .168(i)-1(j)(3) applies (basis
of disposed asset or disposed portion of
an asset) and it is impracticable from the
taxpayer’s records to determine the unad-
justed depreciable basis of the disposed
asset or the disposed portion of an asset,
as applicable, a change in the method of
determining the unadjusted depreciable
basis of all assets in the same general as-
set account from an unreasonable method
(for example, discounting the cost of the
replacement asset to its placed-in-service
year cost using the Consumer Price Index)
to a reasonable method .
(4) Manner of making change .
(a) A taxpayer (including a quali-
fied small taxpayer as defined in section
6 .01(4)(b) of this revenue procedure)
making this change must attach to its
Form 3115 a statement with the following:
(i) A description of the assets to which
this change applies;
(ii) If the taxpayer is making the
change specified in section 6.15(3)(a) of
this revenue procedure, a description of
the assets for disposition purposes under
the taxpayer’s present and proposed meth-
ods of accounting;
(iii) If the taxpayer is making the
change specified in section 6.15(3)(b) of
this revenue procedure, a description of
the methods of identifying which assets
have been disposed of under the taxpay-
er’s present and proposed methods of ac-
counting;
(iv) If the taxpayer is making the
change specified in section 6.15(3)(d) of
this revenue procedure, a description of
the methods of determining the unadjust-
ed depreciable basis of the disposed asset
or disposed portion of the asset, as appli-
cable, under the taxpayer’s present and
proposed methods of accounting; and
(v) If any asset is public utility prop-
erty within the meaning of § 168(i)(10),
a statement providing that the taxpayer
agrees to the following additional terms
and conditions:
(A) A normalization method of ac-
counting (within the meaning of § 168(i)
(9)) will be used for the public utility
property subject to the application;
(B) As of the beginning of the year of
change, the taxpayer will adjust its de-
ferred tax reserve account or similar ac-
count in the taxpayer’s regulatory books
of account by the amount of the deferral
of federal income tax liability associated
with the § 481(a) adjustment applicable
to the public utility property subject to the
application; and
(C) Within 30 calendar days of filing
the federal income tax return for the year
of change, the taxpayer will provide a
copy of the completed application to any
regulatory body having jurisdiction over
the public utility property subject to the
application .
(b) A qualified small taxpayer, as de-
fined in section 6.01(4)(b) of this reve-
nue procedure, is required to complete
only the following information on Form
3115 (Rev . December 2018) to make this
change:
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19 if the qualified small
taxpayer is not making a change in method
of accounting specified in section 6.15(3)
(a) and (d) of this revenue procedure;
(v) Part II, all lines except lines 13,
15b, 16c, 17, and 19 if the qualified small
taxpayer is making a change in method of
accounting specified in section 6.15(3)(a)
or (d) of this revenue procedure;
(v) Part IV, all lines except line 25;
and
(vi) Schedule E .
(5) No ruling on asset . The consent
granted under section 9 of Rev . Proc .
2015-13 for a change specified in section
6 .15(3)(a) of this revenue procedure is
not a determination by the Commissioner
that the taxpayer is using the appropriate
asset under § 1 .168(i)-1(e)(2)(viii) for de-
termining what asset is disposed of by the
taxpayer and does not create any presump-
tion that the proposed asset is permissible
under § 1 .168(i)-1(e)(2)(viii) . The director
will ascertain whether the taxpayer’s de-
termination of its asset under § 1 .168(i)-
1(e)(2)(viii) is permissible .
(6) Section 481(a) adjustment period .
(a) A taxpayer must take the entire
amount of the § 481(a) adjustment into
account in computing taxable income for
the year of change:
(i) If the taxpayer makes the change
specified in section 6.15(3)(a) of this rev-
enue procedure and if the taxpayer recog-
nized a gain or loss under § 1 .168(i)-1T or
§ 1 .168(i)-8T, as applicable, on the dispo-
sition of a portion of the asset in a taxable
year prior to the year of change; or
(iii) If the taxpayer is a qualified tax-
payer as defined in section 4.01 of Rev.
Proc . 2015-56, 2015-49 I .R .B . 827, and
that is within the scope of section 3 of Rev .
Proc . 2015-56, and is making the change
specified in section 5.02(5)(b) of Rev.
Proc. 2015-56 on or before the first tax-
able year that the qualified taxpayer uses
the remodel-refresh safe harbor provided
in section 5 .02 of Rev . Proc . 2015-56 .
(b) If section 6 .15(6)(a) of this revenue
procedure does not apply, see section 7 .03
of Rev . Proc . 2015-13 for the § 481(a) ad-
justment period .
(c) Example. (i) X, a fiscal year taxpayer with a
taxable year beginning December 1 and ending No-
vember 30, acquired and placed in service a building
and its structural components in 2000 . X depreciates
this building and its structural components under
§ 168 . The roof is a structural component of the
building . X replaced the entire roof in June 2010 . On
its federal tax return for the taxable year ended No-
vember 30, 2010, X did not recognize a loss on the
retirement of the original roof and continues to de-
preciate the original roof . X also capitalized the cost
of the replacement roof and has been depreciating
this roof under § 168 since June 2010 . The adjusted
depreciable basis of the original roof at the time of
its retirement in 2010 (taking into account the appli-
cable convention) is $11,000, and X claimed depre-
ciation of $1,000 for such roof after its retirement
(taking into account the applicable convention) and
before the taxable year ended November 30, 2013
(2012 taxable year) . Also the 12-month allowable
depreciation deduction for the original roof is $500
for the 2012 taxable year, $500 for the taxable year
ended November 30, 2014 (2013 taxable year), and
$500 for the taxable year ended November 30, 2015
(2014 taxable year) .
(ii) In accordance with § 1 .168(i)-1T and section
6 .32(1)(a) of the APPENDIX to Rev . Proc . 2011-14,
as modified by Rev. Proc. 2012-20, 2012-14 I.R.B.
700, X filed with its federal tax return for the taxable
year ended November 30, 2013, a Form 3115 to: (1)
make a late general asset account election to include
the building (including its structural components)
placed in service in 2000 in one general asset ac-
count and the replacement roof in a separate general

Bulletin No. 2019–48 1137 November 25, 2019
asset account; and (2) make a late qualifying disposi-
tion election for the retirement of the original roof in
2010 . As a result, X removed the original roof from
the general asset account and reported a net negative
§ 481(a) adjustment on this Form 3115 of $10,000
(adjusted depreciable basis of $11,000 for the orig-
inal roof at the time of its retirement (taking into
account the applicable convention) less depreciation
of $1,000 claimed for such roof after its retirement
(taking into account the applicable convention) and
before the 2012 taxable year) .
(iii) X complies with § 1 .168(i)-1 beginning
with its taxable year ended November 30, 2016
(2015 taxable year) . In accordance with section
6.15(3)(a) of this revenue procedure, X files a Form
3115 with its federal income tax return for the
2015 taxable year to change to treating the build-
ing (including its original roof and other original
structural components) placed in service in 2000
as an asset and the replacement roof as a separate
asset for disposition purposes . As a result, X must
include the original roof that X retired in 2010 in
the general asset account . Thus, the net positive
§ 481(a) adjustment for this change is $8,500 (net
loss of $10,000 claimed on the 2012 return for the
retirement of the original roof less depreciation of
$1,500 for the original roof for the 2012, 2013, and
2014 taxable years) and is included in X’s taxable
income for the 2015 taxable year .
(7) Concurrent automatic change .
(a) A taxpayer making this change for
more than one asset for the same year of
change should file a single Form 3115 for
all such assets and provide a single net
§ 481(a) adjustment for all the changes in-
cluded in that Form 3115 . If one or more
of the changes in that single Form 3115
generate a negative § 481(a) adjustment
and other changes in that same Form 3115
generate a positive § 481(a) adjustment,
the taxpayer may provide a single nega-
tive § 481(a) adjustment for all the chang-
es that are included in that Form 3115
generating such negative adjustment and a
single positive § 481(a) adjustment for all
the changes that are included in that Form
3115 generating such positive adjustment .
(b) A taxpayer making this change and
any change listed in section 6 .15(7)(b)(i)-
(iv) of this revenue procedure for the same
year of change should file a single Form
3115 for all of such changes and must en-
ter the designated automatic accounting
method change numbers for the changes
on the appropriate line on the Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes. For example, a qualified small
taxpayer must include on the single Form
3115 the information required to be com-
pleted on Form 3115 by a qualified small
taxpayer under this revenue procedure
for each change in method of accounting
included on that Form 3115 . The listed
changes are:
(i) A change under section 6 .01 of this
revenue procedure;
(ii) A change under section 6 .12 of this
revenue procedure;
(iii) A change under section 6 .13 of this
revenue procedure; and
(iv) A change under section 6 .14 of this
revenue procedure .
(8) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to the method of ac-
counting under this section 6 .15 is “207 .”
(9) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .
.16 Summary of certain changes in
methods of accounting related to disposi-
tions of MACRS property .
(1) Final regulations . The following
chart summarizes the changes in meth-
ods of accounting under § 1 .167(a)-4,
§ 1 .168(i)-1, § 1 .168(i)-7, and § 1 .168(i)-8
that a taxpayer may make under this reve-
nue procedure .
FINAL REGULATION SECTION
SECTION # in
REV . PROC . 2019-43
DESIGNATED
CHANGE
NUMBER (DCN)
§ 1 .167(a)-4, Depreciation of leasehold improvements6 .11199
General Asset Accounts:
a . § 1 .168(i)-1(c), Change in grouping assets6 .12200
b . § 1 .168(i)-1(e)(2)(viii), Change in determining asset disposed of6 .15207
c . § 1 .168(i)-1(j)(2), Change in method of identifying which assets or portions
of assets have been disposed of from one method to another method specified
in § 1 .168(i)-1(j)(2)
6 .12200
d . § 1 .168(i)-1(j)(2), Change in method of identifying which assets or portions
of assets have been disposed of from a method not specified in § 1.168(i)-1(j)
(2) to a method specified in § 1.168(i)-1(j)(2)
6 .15207
e . § 1 .168(i)-1(j)(3), Change in determining unadjusted depreciable basis of
disposed asset or disposed portion of an asset from one reasonable method to
another reasonable method when it is impracticable from the taxpayer’s records
to determine the unadjusted depreciable basis of disposed asset or disposed
portion of asset
6 .12200
f . § 1 .168(i)-1(j)(3), Change in determining unadjusted depreciable basis of dis-
posed asset or disposed portion of an asset from not using to using the taxpay-
er’s records when it is practicable from the taxpayer’s records to determine the
unadjusted depreciable basis of disposed asset or disposed portion of asset
6 .15207

November 25, 2019 1138 Bulletin No. 2019–48
FINAL REGULATION SECTION
SECTION # in
REV . PROC . 2019-43
DESIGNATED
CHANGE
NUMBER (DCN)
g . § 1 .168(i)-1(j)(3), Change in determining unadjusted depreciable basis of
disposed asset or disposed portion of an asset from an unreasonable method to
a reasonable method when it is impracticable from the taxpayer’s records to de-
termine the unadjusted depreciable basis of disposed asset or disposed portion
of asset
6 .15207
Single Asset Accounts or Multiple Asset Accounts for MACRS Property:
a . § 1 .168(i)-7, Change from single asset accounts to multiple asset accounts, or
vice versa
6 .12200
b . § 1 .168(i)-7(c), Change in grouping assets in multiple asset accounts6 .12200
Dispositions of MACRS Property (not in a general asset account):
a . § 1 .168(i)-8(c)(4), Change in determining asset disposed of6 .13 (Building or
structural component)
6 .14 (Property other
than a building or
structural component)
205
206
b . § 1 .168(i)-8(f)(2) or (3), Change in determining unadjusted depreciable basis
of disposed asset in a multiple asset account or disposed portion of an asset
from one reasonable method to another reasonable method when it is impracti-
cable from the taxpayer’s records to determine the unadjusted depreciable basis
of disposed asset or disposed portion of asset
6 .12200
c . § 1 .168(i)-8(f)(2) or (3), Change in determining unadjusted depreciable basis
of disposed asset in a multiple asset account or disposed portion of an asset
from not using to using the taxpayer’s records when it is practicable from the
taxpayer’s records to determine the unadjusted depreciable basis of disposed
asset or disposed portion of asset
6 .13 (Building or
structural component)
6 .14 (Property other
than a building or
structural component)
205
206
d . § 1 .168(i)-8(f)(2) or (3), Change in determining unadjusted depreciable basis
of disposed asset in a multiple asset account or disposed portion of an asset
from an unreasonable method to a reasonable method when it is impracticable
from the taxpayer’s records to determine the unadjusted depreciable basis of
disposed asset or disposed portion of asset
6 .13 (Building or
structural component)
6 .14 (Property other
than a building or
structural component)
205
206
e . § 1 .168(i)-8(g), Change in method of identifying which assets in a multiple
asset account or portions of assets have been disposed of from one method to
another method specified in § 1.168(i)-8(g)(1) or (2)
6 .12200
f . § 1 .168(i)-8(g), Change in method of identifying which assets in a multiple
asset account or portions of assets have been disposed of from a method not
specified in § 1.168(i)-8(g)(1) or (2) to a method specified in § 1.168(i)-8(g)(1)
or (2)
6 .13 (Building or
structural component)
6 .14 (Property other
than a building or
structural component)
205
206
g . § 1 .168(i)-8(h)(1), Change from depreciating a disposed asset or disposed
portion of an asset to recognizing gain or loss upon disposition when a taxpayer
continues to depreciate the asset or portion that the taxpayer disposed of prior
to the year of change
6 .13 (Building or
structural component)
6 .14 (Property other
than a building or
structural component)
205
206
h . § 1 .168(i)-8(d)(2)(iii), Partial disposition election for the disposition of a
portion of an asset to which the IRS’s adjustment pertains
6 .10198

Bulletin No. 2019–48 1139 November 25, 2019
.17 Depreciation of fiber optic transfer
node and fiber optic cable used by a cable
system operator (§§ 167 and 168) .
(1) Description of change .
(a) Applicability . This change applies
to a cable system operator that is within
the scope of Rev . Proc . 2015-12, 2015-2
I .R .B . 266, and wants to change to the safe
harbor method of accounting provided in
section 8 .03 of Rev . Proc . 2015-12 for de-
termining depreciation under §§ 167 and
168 of a fiber optic transfer node and trunk
line consisting of fiber optic cable used in
a cable distribution network providing
one-way and two-way communication
services . The safe harbor method provided
by section 8 .03 of Rev . Proc . 2015-12 de-
termines the asset for purposes of §§ 167
and 168 .
(b) Inapplicability . This change does
not apply to the following:
(i) any property that is not depreciated
under § 168 under the taxpayer’s present
and proposed methods of accounting; or
(ii) any property that is not owned by
the taxpayer at the beginning of the year
of change .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13 does not apply
to a taxpayer that makes this change .
(3) Concurrent automatic change .
(a) A taxpayer that wants to make this
change for more than one asset for the
same year of change should file a single
Form 3115 for all such assets and provide
a single net § 481(a) adjustment for all
the changes included in that Form 3115 .
If one or more of the changes in that
single Form 3115 generate a negative
§ 481(a) adjustment and other changes
in that same Form 3115 generate a pos-
itive § 481(a) adjustment, the taxpayer
may provide a single negative § 481(a)
adjustment for all the changes that are in-
cluded in that Form 3115 generating such
adjustment and a single positive § 481(a)
adjustment for all the changes that are in-
cluded in that Form 3115 generating such
adjustment .
(b) A taxpayer that wants to make
both this change and a change to a UNI-
CAP method under section 12 .01, 12 .02,
12 .08, or 12 .12 of this revenue procedure,
as applicable, for the same year of change
should file a single Form 3115 for all such
changes and must enter the designated au-
tomatic accounting method change num-
bers for the changes on the appropriate
line on the Form 3115 . See section 6 .03(1)
(b) of Rev . Proc . 2015-13 for information
on making concurrent changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to the method of ac-
counting under this section 6 .17 is “210 .”
(5) Contact information . For further
information regarding a change under this
section, contact Charles Magee at (202)
317-7005 (not a toll-free number) .
.18 Late elections or revocation of
elections under § 168(k)(5), (7), and (10).
(1) Description of Change .
(a) Applicability . This change applies
to a taxpayer within the scope of Rev .
Proc . 2019-33, 2019-34 I .R .B . 662, that
wants to make a late election, or to revoke
an election, provided in sections 4, 5, and
6 of Rev . Proc . 2019-33 under § 168(k)
(5), (7), or (10) .
(b) Inapplicability . The IRS will treat
the making of a late election, or the revoca-
tion of an election, provided in sections 4, 5,
and 6 of Rev . Proc . 2019-33 under § 168(k)
(5), (7), and (10) as a change in method
of accounting with a § 481(a) adjustment
only for the taxable years specified in sec-
tion 6 .18(2) of this revenue procedure . This
treatment does not apply to a taxpayer that
makes these late elections or revocations
before or after the time specified in section
6 .18(2) of this revenue procedure, and any
such late election or revocation is not a
change in method of accounting pursuant
to § 1 .446-1(e)(2)(ii)(d)(3)(iii) .
(2) Time for making the change . The
change under this section 6 .18 must be
made for the taxpayer’s first, second, or
third taxable year succeeding the taxpay-
er’s taxable year beginning in 2016 and
ending on or after September 28, 2017
(2016 taxable year) or beginning in 2017
and ending on or after September 28, 2017
(2017 taxable year) .
(3) Certain eligibility rules inapplica-
ble . The eligibility rules in section 5 .01(1)
(d) and (f) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, do not apply to this change for
the taxpayer’s 2016 taxable year or 2017
taxable year .
(4) Concurrent automatic change .
(a) A taxpayer making this change for
more than one specified plant under sec-
tion 4 of Rev . Proc . 2019-33 for the same
year of change should file a single Form
3115 for all such specified plants. The sin-
gle Form 3115 must provide a single net
§ 481(a) adjustment for all such changes .
(b) A taxpayer making this change for
more than one class of property under
section 5 of Rev . Proc . 2019-33 for the
same year of change should file a single
Form 3115 for all such classes of proper-
ty . The single Form 3115 must provide a
single net § 481(a) adjustment for all such
changes .
(c) A taxpayer making this change for
all qualified property under section 6 of
Rev . Proc . 2019-33 should provide a sin-
gle net § 481(a) adjustment for all assets
that are qualified property.
(d) A taxpayer making a late elec-
tion, or revoking an election, under more
than one section of Rev . Proc . 2019-33
(for example, under sections 4 and 6 of
Rev . Proc . 2019-33) for the same year of
change should file a single Form 3115 for
all such changes . The single Form 3115
must provide a single net § 481(a) adjust-
ment for all such changes .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to the method of ac-
counting under this section 6 .18 is “241 .”
(6) Contact information . For further
information regarding a change under this
section, contact Elizabeth Binder at (202)
317-7005 (not a toll-free number) .
SECTION 7 . RESEARCH AND
EXPERIMENTAL EXPENDITURES
(§ 174)
.01 Changes to a different method or
different amortization period .
(1) Description of change .
(a) This change applies to a taxpay-
er that wants to change the treatment of
expenditures that qualify as research and
experimental expenditures under § 174 .
(b) Section 174 and the regulations
thereunder provide the specific rules for
changing a method of accounting under
§ 174 for research and experimental ex-
penditures . Under § 174, a taxpayer may
treat research and experimental expendi-
tures that are paid or incurred by the tax-
payer during the taxable year in connec-
tion with the taxpayer’s trade or business

November 25, 2019 1140 Bulletin No. 2019–48
as expenses under § 174(a) or as deferred
expenses amortizable ratably over a pe-
riod of not less than 60 months under §
174(b) . Pursuant to § 1 .174-1, research
and experimental expenditures that are not
treated as expenses or deferred expenses
under § 174 must be treated as a charge
to capital account . Further, § 1 .174-1 pro-
vides that the expenditures to which § 174
applies may relate either to a general re-
search program or to a particular project .
Finally, §§ 1 .174-3(a) and 1 .174-4(a)(5)
provide that in no event will a taxpayer be
permitted to apply one method as to part
of the expenditures relative to a particular
project and apply a different method to the
balance of the expenditures relating to the
same project for the same taxable year .
(c) If a taxpayer has not treated re-
search and experimental expenditures
as expenses under § 174(a), § 174(a)(2)
(B) and § 1 .174-3(b)(2) provide that the
taxpayer may, with consent, adopt the ex-
pense method at any time .
(d) If a taxpayer has treated research
and experimental expenditures as ex-
penses under § 174(a), § 174(a)(3) and
§ 1 .174-3(b)(3) provide that the taxpayer
may, with consent, change to a different
method of treating research and experi-
mental expenditures .
(e) If a taxpayer has treated research
and experimental expenditures as deferred
expenses under § 174(b), § 174(b)(2) and
§ 1 .174-4(b)(2) provide that the taxpayer
may, with consent, change to a different
method of treating research or experimen-
tal expenditures or to a different period of
amortization for deferred expenses .
(2) Applicability .
(a) In general . This change applies to
any taxpayer that is changing:
(i) from treating research and exper-
imental expenditures for a particular
project or projects as expenses under
§ 174(a) to treating such expenditures
as deferred expenses under § 174(b), or
vice versa;
(ii) to a different period of amortization
for research and experimental expendi-
tures for a particular project or projects
that are being treated as deferred expenses
under § 174(b);
(iii) from treating research and experi-
mental expenditures for a particular proj-
ect or projects as expenses under § 174(a)
or deferred expenses under § 174(b) to
treating such expenditures as a charge to
capital account, or vice versa; or
(iv) from treating research and experi-
mental expenditures under any provision
of the Code other than § 174 to treating
such expenditures under § 174 and the
regulations thereunder .
(b) Inapplicability . This change does
not apply to:
(i) a change in the treatment of comput-
er software costs under Rev . Proc . 2000-
50, 2000-2 C.B. 601, as modified by Rev.
Proc . 2007-16, 2007-1 C .B . 358 (but see
section 9 of this revenue procedure for
making that change); or
(ii) a change in the treatment of Year
2000 costs under Rev . Proc . 97-50, 1997-2
C .B . 525 .
(3) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, is not applicable to this change .
(4) Manner of making change .
(a) This change is made on a cut-off ba-
sis and applies to all research and experi-
mental expenditures paid or incurred for
a particular project or projects on or after
the beginning of the year of change . See
§ 174(b)(2), and §§ 1 .174-3(a), 1 .174-3(b)
(2), and 1 .174-4(a)(5) for more informa-
tion regarding a cut-off basis . According-
ly, a § 481(a) adjustment is neither permit-
ted nor required .
(b) The requirement under §§ 1 .174-
3(b)(2), 1 .174-3(b)(3), and 1 .174-4(b)(2)
to file an application (that is, a Form 3115)
no later than the end of the first taxable
year in which the different method or dif-
ferent amortization period is to be used is
waived for this change . However, see sec-
tion 6.03 of Rev. Proc. 2015-13 for filing
requirements applicable to a change under
this section 7 .01 .
(c) The consent granted under section 9
of Rev. Proc. 2015-13 satisfies the consent
required under §§ 174(a)(2)(B), 174(a)
(3), and 174(b)(2), and §§ 1 .174-3(b)(2),
1 .174-3(b)(3), and 1 .174-4(b)(2) .
(5) Additional requirement . A taxpay-
er must attach to its Form 3115 a written
statement providing:
(a) the information required in § 1 .174-
3(b)(2) if the taxpayer is changing to treat-
ing research and experimental expendi-
tures as expenses under § 174(a);
(b) the information required in § 1 .174-
3(b)(3) if the taxpayer is changing from
treating research and experimental expen-
ditures as expenses under § 174(a); or
(c) the information required in § 1 .174-
4(b)(2) if the taxpayer is changing from
treating research and experimental ex-
penditures as deferred expenses under
§ 174(b) or is changing to a different pe-
riod of amortization for research and ex-
perimental expenditures being treated as
deferred expenses under § 174(b) .
(6) No audit protection . A taxpayer
does not receive audit protection under
section 8 .01 of Rev . Proc . 2015-13 in
connection with this change . See section
8 .02(2) of Rev . Proc . 2015-13 .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
7 .01 is “17 .”
(8) Contact information . For further
information regarding a change under this
section, contact Elizabeth Binder at (202)
317-7005 (not a toll-free number) .
SECTION 8 . ELECTIVE EXPENSING
PROVISIONS (§ 179D)
.01 Deduction for Energy Efficient
Commercial Buildings (§ 179D) .
(1) Description of change . This change,
as described in Rev . Proc . 2012-39, 2012-
41 I .R .B . 470, applies to a taxpayer that
wants to change its method of account-
ing to deduct under § 179D amounts paid
or incurred for the installation of energy
efficient commercial building proper-
ty, as defined in § 179D(c)(1). The de-
duction for energy efficient commercial
building property is subject to the lim-
its of § 179D(b) and must be claimed in
the taxable year in which the property is
placed in service . The basis of the energy
efficient commercial building property is
reduced by the amount of the § 179D de-
duction taken and the remaining basis of
the energy efficient commercial building
property is depreciated over its recovery
period .
(2) Applicability . This change applies
to a taxpayer that places in service proper-
ty for which a deduction is allowed under
§ 179D(a) .
(3) Inapplicability . This change does
not apply to a designer to whom the own-
er of a government building allocates the
§ 179D deduction .

Bulletin No. 2019–48 1141 November 25, 2019
(4) Manner of making change . A tax-
payer making this change must attach to
its Form 3115 (the original, the copy filed
at Ogden, UT, and any additional copies)
a statement with a detailed description of
the tax treatment of the property under the
taxpayer’s present and proposed methods
of accounting .
(5) Certification requirement . In addi-
tion to the statement required by section
8 .01(4) of this revenue procedure, a tax-
payer making this change must attach to
its Form 3115 a certification as required
by section 4 of Notice 2006-52, 2006-1
C .B . 1175, or section 5 of Notice 2008-
40, 2008-1 C .B . 725, to demonstrate that
the energy efficient commercial build-
ing property has achieved the reduction
in energy and power costs or in lighting
power density necessary to qualify for the
§ 179D deduction .
(6) No ruling on qualification . The con-
sent granted under section 9 of Rev . Proc .
2015-13, 2015-5 I .R .B . 419, for a change
provided in this section 8 .01 is not a de-
termination by the Commissioner that the
taxpayer qualifies for a deduction under
section 179D . The director will ascertain
whether the taxpayer qualifies for a de-
duction under section 179D (including a
review of the required certifications). See
section 12 of Rev . Proc . 2015-13 .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
8 .01 is “152 .”
(8) Contact information . For further
information regarding a change under this
section, contact Jennifer Bernardini at
(202) 317-6853 (not a toll-free number) .
SECTION 9 . COMPUTER SOFTWARE
EXPENDITURES (§§ 162, 167, and 197)
.01 Computer software expenditures .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for the costs of
computer software to a method described
in Rev . Proc . 2000-50, 2000-2 C .B . 601,
as modified by Rev. Proc. 2007-16, 2007-
1 C .B . 358 . Section 5 of Rev . Proc . 2000-
50 describes the methods applicable to the
costs of developing computer software .
Section 6 of Rev . Proc . 2000-50 describes
the method applicable to the costs of ac-
quired computer software . Section 7 of
Rev . Proc . 2000-50 describes the method
applicable to leased or licensed computer
software .
(2) Scope . This change applies to all
costs of computer software as defined in
section 2 of Rev . Proc . 2000-50 . However,
this change does not apply to any comput-
er software that is subject to amortization
as an “amortizable section 197 intangible”
as defined in § 197(c) and the regulations
thereunder, or to costs that a taxpayer has
treated as research and experimentation
expenditures under § 174 .
(3) Statement required . If a taxpayer
is changing to the method described in
section 5 .01(2) of Rev . Proc . 2000-50, the
taxpayer must attach to its Form 3115 a
statement providing the information re-
quired in section 8 .02(2) of Rev . Proc .
2000-50 .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
9 .01 is “18 .”
(5) Contact information . For further
information regarding a change under
this section, contact Bruce Chang at (202)
317-7005 (not a toll-free number) .
SECTION 10 . START-
UP EXPENDITURES AND
ORGANIZATIONAL FEES (§§ 195,
248, AND 709)
.01 Start-up expenditures .
(1) Description of change and scope .
(a) Applicability . This change applies to
a taxpayer that wants to change its method
of accounting under § 195 to change:
(i) the characterization of an item as a
start-up expenditure;
(ii) the determination of the taxable
year in which the taxpayer begins the ac-
tive trade or business to which the start-up
expenditures relate; or
(iii) the amortization period of a start-
up expenditure to 180 months .
(b) Inapplicability . This change does
not apply to:
(i) start-up expenditures paid or in-
curred before October 23, 2004; or
(ii) start-up expenditures paid or in-
curred after October 22, 2004, and before
August 17, 2011, if the period of limita-
tions on assessment of tax for the taxable
year the election under § 1 .195-1(b) is
deemed made has expired .
(2) No rulings .
(a) Characterization of item . The con-
sent granted under section 9 of Rev . Proc .
2015-13 for a change specified in section
10 .01(1)(a)(i) of this revenue procedure is
not a determination by the Commissioner
that the taxpayer has properly character-
ized an item as a start-up expenditure and
does not create any presumption that the
proposed characterization of an item as a
start-up expenditure is permissible under
§ 195(c)(1) . The director will ascertain
whether the taxpayer’s characterization of
an item as a start-up expenditure is per-
missible .
(b) When active trade or business be-
gins . The consent granted under section
9 of Rev . Proc . 2015-13 for a change
specified in section 10.01(1)(a)(ii) of this
revenue procedure is not a determination
by the Commissioner that the taxpayer
has properly determined the taxable year
in which the taxpayer begins the active
trade or business to which the start-up
expenditures relate and does not create
any presumption that the proposed tax-
able year in which the taxpayer begins
the active trade or business to which the
start-up expenditures relate is permissi-
ble under § 195(c)(2) . The director will
ascertain whether the taxpayer’s determi-
nation of the taxable year in which the
taxpayer begins the active trade or busi-
ness to which the start-up expenditures
relate is permissible .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to a method of ac-
counting under this section 10 .01 is “223 .”
(4) Contact information . For further
information regarding a change under this
section, contact Elizabeth Binder at (202)
317-7005 (not a toll-free number) .
.02 Organizational expenditures under
§ 248 .
(1) Description of change and scope .
(a) Applicability . This change applies
to a corporation that wants to change
its method of accounting under § 248 to
change:
(i) the characterization of an item as an
organizational expenditure;
(ii) the determination of the taxable
year in which the corporation begins busi-

November 25, 2019 1142 Bulletin No. 2019–48
ness to which the organizational expendi-
tures relate; or
(iii) the amortization period of an orga-
nizational expenditure to 180 months .
(b) Inapplicability . This change does
not apply to:
(i) organizational expenditures paid or
incurred before October 23, 2004; or
(ii) organizational expenditures paid
or incurred after October 22, 2004, and
before August 17, 2011, if the period of
limitations on assessment of tax for the
taxable year the election under § 1 .248-
1(c) is deemed made has expired .
(2) No rulings .
(a) Characterization of items . The con-
sent granted under section 9 of Rev . Proc .
2015-13 for a change specified in section
10 .02(1)(a)(i) of this revenue procedure
is not a determination by the Commis-
sioner that the corporation has properly
characterized an item as an organizational
expenditure and does not create any pre-
sumption that the proposed characteriza-
tion of an item as an organizational expen-
diture is permissible under § 248(b) and
§ 1 .248-1(b) . The director will ascertain
whether the corporation’s characterization
of an item as an organizational expendi-
ture is permissible .
(b) When the corporation begins busi-
ness . The consent granted under section 9 of
Rev. Proc. 2015-13 for a change specified in
section 10 .02(1)(a)(ii) of this revenue pro-
cedure is not a determination by the Com-
missioner that the corporation has properly
determined the taxable year in which the
corporation begins business to which the
organizational expenditures relate and does
not create any presumption that the pro-
posed taxable year in which the corporation
begins business to which the organization-
al expenditures relate is permissible under
§1 .248-1(d) . The director will ascertain
whether the corporation’s determination of
the taxable year in which the corporation
begins business to which the organizational
expenditures relate is permissible .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
10 .02 is “228 .”
(4) Contact information . For further
information regarding a change under this
section, contact Sharon Horn at (202) 317-
7003 (not a toll-free number) .
.03 Organization fees under § 709 .
(1) Description of change and scope .
(a) Applicability . This change applies
to a partnership that wants to change its
method of accounting under § 709 to
change:
(i) the characterization of an item as an
organizational expense;
(ii) the determination of the taxable
year in which the partnership begins busi-
ness to which the organizational expenses
relate; or
(iii) the amortization period of an orga-
nizational expense to 180 months .
(b) Inapplicability . This change does
not apply to:
(i) organizational expenses paid or in-
curred before October 23, 2004; or
(ii) organizational expenses paid or in-
curred after October 22, 2004, and before
August 17, 2011, if the period of limita-
tions on assessment of tax for the taxable
year the election under § 1 .709-1(b) is
deemed made has expired .
(2) No rulings .
(a) Characterization of items . The con-
sent granted under section 9 of Rev . Proc .
2015-13 for a change specified in section
10 .03(1)(a)(i) of this revenue procedure is
not a determination by the Commissioner
that the partnership has properly character-
ized an item as an organizational expense
and does not create any presumption that
the proposed characterization of an item
as an organizational expense is permissi-
ble under § 709(b)(3) . The director will
ascertain whether the partnership’s char-
acterization of an item as an organization-
al expense is permissible .
(b) When the partnership begins busi-
ness . The consent granted under section 9 of
Rev. Proc. 2015-13 for a change specified in
section 10 .03(1)(a)(ii) of this revenue pro-
cedure is not a determination by the Com-
missioner that the partnership has properly
determined the taxable year in which the
partnership begins business to which the
organizational expenses relate and does not
create any presumption that the proposed
taxable year in which the partnership be-
gins business to which the organizational
expenses relate is permissible under §1 .709-
2(c) . The director will ascertain whether the
partnership’s determination of the taxable
year in which the partnership begins busi-
ness to which the organizational expenses
relate is permissible .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
10 .03 is “229 .”
(4) Contact information . For further
information regarding a change under this
section, contact Meghan Howard at (202)
317-5055 (not a toll-free number) .
SECTION 11 . CAPITAL
EXPENDITURES (§ 263)
.01 Package design costs .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to change its
method of accounting for package design
costs that are within the scope of Rev .
Proc. 97-35, 1997-2 C.B. 448, as modified
by Rev . Proc . 98-39, 1998-1 C .B . 1320,
to one of the three alternative methods of
accounting for package design costs de-
scribed in section 5 of Rev . Proc . 97-35,
which are: (i) the capitalization method,
(ii) the design-by-design capitalization
and 60-month amortization method, and
(iii) the pool-of-cost capitalization and
48-month amortization method .
(b) Inapplicability . This change does
not apply to a taxpayer that wants to
change to the capitalization method for
costs of developing or modifying any
package design that has an ascertainable
useful life .
(2) Additional requirements . If a tax-
payer is changing its method of account-
ing for package design costs to the capi-
talization method or the design-by-design
capitalization and 60-month amortization
method, the taxpayer must attach a state-
ment to its timely filed Form 3115. The
statement must provide a description of
each package design, the date on which
each was placed in service, and the cost
basis of each (as determined under sec-
tions 5 .01(2) or 5 .02(2) of Rev . Proc . 97-
35) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .01 is “19 .”
(4) Contact information . For further
information regarding a change under this
section, contact Alexa Dubert at (202)
317-7003 (not a toll-free number) .

Bulletin No. 2019–48 1143 November 25, 2019
.02 Line pack gas or cushion gas .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for line pack gas
or cushion gas to a method consistent with
the holding in Rev . Rul . 97-54, 1997-2
C .B . 23 . Rev . Rul . 97-54 holds that the
cost of line pack gas or cushion gas is a
capital expenditure under § 263, the cost
of recoverable line pack gas or recover-
able cushion gas is not depreciable, and
the cost of unrecoverable line pack gas or
unrecoverable cushion gas is depreciable
under §§ 167 and 168 .
(2) Additional requirements . A taxpay-
er that changes its method of accounting
for unrecoverable line pack gas or unre-
coverable cushion gas under this section
11 .02 must change to a permissible meth-
od of accounting for depreciation for the
cost of that gas as part of this change .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .02 is “20 .”
(4) Contact information . For further
information regarding a change under this
section, contact Douglas Kim at (202)
317-7003 (not a toll-free number) .
.03 Removal costs .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to change its
method of accounting for certain costs in
the retirement and removal of a deprecia-
ble asset to conform with Rev . Rul . 2000-
7, 2000-1 C.B. 712, as modified by this
revenue procedure, or for removal costs in
disposal of a depreciable asset, including
a partial disposition, as described under
§ 1 .263(a)-3(g)(2)(i) .
(b) Inapplicability . This change does
not apply to a taxpayer that wants to
change its method of accounting for re-
moval costs in the disposal of a compo-
nent of a unit of property where the dis-
posal of the component is not a disposition
for federal tax purposes . To make that
change, see section 11 .08 of this revenue
procedure .
(c) Manner of making change . A qual-
ified small taxpayer, as defined in section
6 .01(4)(b) of this revenue procedure, is
required to complete only the following
information on Form 3115 (Rev . Decem-
ber 2018):
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I, line 1(a);
(iv) Part II, all lines except lines 13, 15,
16, 17, and 19, if the change is not to de-
preciating property;
(v) Part II, all lines except lines 13,
15b, 16, 17, and 19, if the change is to de-
preciating property;
(vi) Part IV, lines 26 and 27; and
(vii) Schedule E, if applicable .
(2) Additional requirements .
(a) Except for assets for which depre-
ciation is determined in accordance with
§ 1 .167(a)-11 (ADR), the taxpayer’s pro-
posed method of treating removal costs
for assets accounted for in a multiple asset
account must be consistent with the tax-
payer’s method of treating salvage pro-
ceeds . See Rev . Rul . 74-455, 1974-2 C .B .
63 . (See section 6 .02 of this revenue pro-
cedure for changing a taxpayer’s present
method of treating salvage proceeds .)
(b) If this change involves assets that
are public utility property within the
meaning of § 168(i)(10) or former § 167(l)
(3)(A), the taxpayer must comply with the
terms and conditions in section 6 .01(3)(b)
(v) of this revenue procedure .
(3) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .03 is “21 .”
(5) Contact information . For further
information regarding a change under this
section, contact Douglas Kim at (202)
317-7003 (not a toll-free number) .
.04 Distributor commissions .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to change from
currently deducting distributor commis-
sions (as defined by section 2 of Rev.
Proc . 2000-38, 2002-2 C .B . 310, as mod-
ified by Rev. Proc. 2007-16, 2007-1 C.B.
358) to a method of capitalizing and amor-
tizing distributor commissions using the
distribution fee period method, the 5-year
method, or the useful life method (all de-
scribed in Rev . Proc . 2000-38) .
(b) Inapplicability . This change does
not apply to an amortizable section 197 in-
tangible (including any property for which
a timely election under § 13261(g)(2) of
the Revenue Reconciliation Act of 1993,
1993-3 C .B . 1, 128, was made) .
(2) Manner of making change . This
change is made on a cut-off basis and ap-
plies only to distributor commissions paid
or incurred on or after the beginning of the
year of change . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .04 is “47 .”
(4) Contact information . For further
information regarding a change under this
section, contact Alexa Dubert at (202)
317-7003 (not a toll-free number) .
.05 Intangibles .
(1) Description of change . This change
applies to a taxpayer that wants to change
its treatment of an item to a method of
accounting permitted by §§ 1 .263(a)-4,
1 .263(a)-5, and 1 .167(a)-3(b) . See Rev .
Proc . 2006-12, 2006-1 C .B . 310, as mod-
ified by Rev. Proc. 2006-37, 2006-2 C.B.
499, for the specific requirements, infor-
mation, and documentation required for
this change .
(2) Section 481(a) adjustment . In com-
puting the § 481(a) adjustment for this
change, the taxpayer takes into account
only amounts paid or incurred in taxable
years ending on or after January 24, 2002 .
See section 5 of Rev . Proc . 2006-12 for
detailed rules for computing the § 481(a)
adjustment and reporting it on Form 3115 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .05 is “78 .”
(4) Contact information . For further
information regarding a change under this
section, contact Joanna Trebat or Alicia
Lee-Won at (202) 317-7003 (not a toll-
free number) .
.06 Rotable spare parts safe harbor
method .
(1) Description of change . This
change applies to a taxpayer that main-
tains a pool or pools of rotable spare
parts that are primarily used to repair

November 25, 2019 1144 Bulletin No. 2019–48
customer-owned (or customer-leased)
equipment under warranty or mainte-
nance agreements, and wants to change
its method of accounting for the rotable
spare parts to the safe harbor method of
accounting provided in Rev . Proc . 2007-
48, 2007-2 C .B . 110 . The taxpayer must
meet the requirements in section 4 .01 of
Rev . Proc . 2007-48 to use this safe harbor
method of accounting .
(2) Change from safe harbor method .
A taxpayer that is required to change its
method of accounting from the safe harbor
method under section 5 .06 of Rev . Proc .
2007-48, must make the change under
section 21 .09 of this revenue procedure .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .06 is “109 .”
(4) Contact information . For further
information regarding a change under this
section, contact Stephen Rothandler at
(202) 317-7003 (not a toll-free number) .
.07 Repairable and reusable spare
parts.
(1) Description of change .
(a) Applicability . This change applies to
a taxpayer that wants to change its method
of accounting to treat repairable and reus-
able spare parts as depreciable property
to conform with the holdings in Rev . Rul .
69-200, 1969-1 C .B . 60, and Rev . Rul . 69-
201, 1969-1 C .B . 60 . This change applies
to repairable and reusable spare parts that:
are owned by the taxpayer at the beginning
of the year of change; are used to repair
equipment owned by the taxpayer; are ac-
quired by the taxpayer for a specific type
of equipment at the time that the related
equipment is acquired; usually have the
same useful life as the related equipment;
and have been placed in service by the
taxpayer after 1986 . A taxpayer making a
change in method of accounting under this
section 11 .07 may treat its repairable and
reusable spare parts as tangible property
for which depreciation is allowable at the
time that the related equipment is placed
in service by the taxpayer . The method of
computing depreciation for the repairable
and reusable spare parts is the same meth-
od of computing depreciation for the relat-
ed equipment .
(b) Inapplicability . This change does
not apply to:
(i) A taxpayer that is currently capital-
izing and depreciating the cost of its re-
pairable and reusable spare parts, or that
is currently capitalizing the cost of its
repairable and reusable spare parts and
treating these parts as nondepreciable
property (but see section 6 .01 of this rev-
enue procedure for making a change from
an impermissible to a permissible method
of accounting for depreciation);
(ii) A taxpayer that is using an imper-
missible method of accounting for de-
preciation for the related equipment for
which the repairable and reusable spare
parts are acquired, unless the taxpayer
concurrently changes its method to use a
permissible method of accounting for de-
preciation under section 6 of this revenue
procedure;
(iii) A repairable and reusable spare
part that meets the definition of rotable
spare parts, temporary spare parts, or
standby emergency spare parts in § 1 .162-
3(c)(2) or (3), for which the cost was paid
or incurred by the taxpayer in a taxable
year beginning on or after January 1, 2014
(or in a taxable year beginning on or after
January 1, 2012, if the taxpayer choos-
es to apply § 1 .162-3 to amounts paid or
incurred in those taxable years), and for
which the taxpayer did not make the elec-
tion under § 1 .162-3(d) to capitalize and
depreciate such repairable and reusable
spare part; or
(iv) a taxpayer that chooses to apply
§ 1 .162-3T to a repairable and reusable
spare part that meets the definition of ro-
table spare parts or temporary spare parts
in § 1 .162-3T(c)(2), for which the cost
was paid or incurred by the taxpayer in a
taxable year beginning on or after January
1, 2012, and before January 1, 2014, and
for which the taxpayer did not make the
election under § 1 .162-3T(d) to capitalize
and depreciate such repairable and reus-
able spare part .
(2) Additional requirements .
(a) To change a method of accounting
under this section 11 .07, a taxpayer (in-
cluding a qualified small taxpayer as de-
fined in section 6.01(4)(b) of this revenue
procedure) must complete Schedule E of
Form 3115 for the repairable and reusable
spare parts and also attach the following
information to the completed Form 3115:
(i) A description of the repairable and
reusable spare parts;
(ii) A list of related equipment for
which the repairable and reusable spare
parts are acquired; and
(iii) A complete description of the
method of computing depreciation (for
example, depreciation method, recovery
period, convention, and applicable asset
class under Rev . Proc . 87-56, 1987-2 C .B .
674, as clarified and modified by Rev.
Proc . 88-22, 1988-1 C .B . 785) that the
taxpayer uses for the related equipment
for which the repairable and reusable
spare parts are acquired .
(b) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018):
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,
15b, 16, 17, and 19; and
(v) Part IV, all lines except line 25 .
(3) Concurrent automatic change .
(a) A taxpayer making both this change
and a change to a UNICAP method under
section 12 .01, 12 .02, 12 .08, or 12 .12 of
this revenue procedure (as applicable) for
the same year of change should file a sin-
gle Form 3115 for both changes, in which
case the taxpayer must enter the designat-
ed automatic accounting method change
numbers for both changes on the appro-
priate line on that Form 3115 . See section
6 .03(1)(b) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, for information on making
concurrent changes . For example, a qual-
ified small taxpayer, as defined in section
6 .01(4)(b) of this revenue procedure, must
include on the single Form 3115 the in-
formation required by section 11 .07(2)
(b) of this revenue procedure and the in-
formation required by the lines on Form
3115, applicable to the UNICAP method
change, including Part II line 14 and 15,
Part IV, and Schedule D, and must include
a separate response to each line on Form
3115 that is applicable to both changes
(such as Part II lines 6b, 7, 8b, 14, and,
as applicable for this change, Part IV) for
which the taxpayer’s response is different
for this change and the change to a UNI-
CAP method .

Bulletin No. 2019–48 1145 November 25, 2019
(b) A taxpayer making both this
change and a change to a permissible
method of accounting for depreciation
for repairable and reusable spare parts,
or for the related equipment for which
the repairable and reusable spare parts
are acquired, under section 6 of this rev-
enue procedure (as applicable) for the
same year of change should file a single
Form 3115 for both changes, in which
case the taxpayer must enter the des-
ignated automatic accounting method
change numbers for both changes on the
appropriate line on that Form 3115 . See
section 6 .03(1)(b) of Rev . Proc . 2015-13
for information on making concurrent
changes. For example, a qualified small
taxpayer must include on the single Form
3115 the information required to be com-
pleted on Form 3115 by a qualified small
taxpayer under this revenue procedure
for each change in method of accounting
included on that Form 3115 .
(c) A taxpayer making this change also
may establish pools for the repairable
and reusable spare parts or may identify
disposed repairable and reusable spare
parts in accordance with section 6 .12 of
this revenue procedure . A taxpayer mak-
ing both this change and the change under
section 6 .12 of this revenue procedure for
the same year of change should file a sin-
gle Form 3115 for both changes, in which
case the taxpayer must enter the designat-
ed automatic accounting method change
numbers for both changes on the appro-
priate line on that Form 3115 . See section
6 .03(1)(b) of Rev . Proc . 2015-13 for in-
formation on making concurrent changes .
For example, a qualified small taxpayer
must include on the single Form 3115 the
information required to be completed on
Form 3115 by a qualified small taxpay-
er under this revenue procedure for each
change in method of accounting included
on that Form 3115 .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .07 is “121” .
(5) Contact information . For further
information regarding a change under this
section, contact Stephen Rothandler at
(202) 317-7003 (not a toll-free number) .
.08 Tangible property .
(1) Description of change .
(a) Applicability . This change, as de-
scribed in Rev . Proc . 2014-16, 2014-9
I .R .B . 606, applies to a taxpayer that
wants to make a change to a method of
accounting specified in section 11.08(2)
of this revenue procedure and permitted
under:
(i) Section 1 .162-3, § 1 .162-4,
§ 1 .263(a)-1, § 1 .263(a)-2, or § 1 .263(a)-
3 (the final tangible property regulations)
for taxable years beginning on or after
January 1, 2012; or
(ii) Section 1 .446-1(e)(2)(ii)(d)(2) if
the property for which the taxpayer is oth-
erwise changing its method of accounting
under this section is depreciable under ei-
ther the present or the proposed method of
accounting .
(b) Inapplicability . This change does
not apply to:
(i) A taxpayer that wants to change its
method of accounting for dispositions of
depreciable property, including a change
in the asset disposed of (but see sections
6 .10, 6 .13, 6 .14, and 6 .15 of this revenue
procedure);
(ii) Amounts paid or incurred for cer-
tain materials and supplies that the tax-
payer has elected to capitalize and depre-
ciate under § 1 .162-3(d);
(iii) Amounts paid or incurred to which
the taxpayer has elected to apply the de
minimis safe harbor under § 1 .263(a)-1(f);
(iv) Amounts paid or incurred for em-
ployee compensation or overhead that the
taxpayer has elected to capitalize under
§ 1 .263(a)-2(f)(2)(iv)(B);
(v) Amounts paid or incurred to which
the taxpayer has elected to apply the
safe harbor for small taxpayers under
§ 1 .263(a)-3(h);
(vi) Amounts paid or incurred for repair
and maintenance costs that the taxpayer
has elected to capitalize under § 1 .263(a)-
3(n);
(vii) Amounts paid or incurred to facili-
tate the acquisition or disposition of assets
that constitute a trade or business (but see
section 10 .05 of this revenue procedure);
or
(viii) Amounts paid or incurred for re-
pair and maintenance costs that the tax-
payer is changing from capitalizing to
deducting and for which the taxpayer has
(A) claimed a federal income tax credit,
(B) elected to apply § 168(k)(4) (as in
effect on the day before the date of en-
actment of Public Law 115-97, 131 Stat .
2054 (Dec . 22, 2017) (the “Act”)), or (C)
received a payment for specified energy
property in lieu of tax credits under sec-
tion 1603 of the American Recovery and
Reinvestment Tax Act of 2009, Div . B of
Pub . L . No . 111-5, 123 Stat . 115 (February
17, 2009), as amended by section 707 of
the Tax Relief, Unemployment Insurance
Reauthorization, and Job Creation Act of
2010, Pub . L . No . 111-312, 124 Stat . 3296
(December 17, 2010) .
(2) Covered changes . This section
11 .08 only applies to the following chang-
es in methods of accounting:
(a) A change to deducting amounts paid
or incurred to acquire or produce non-in-
cidental materials and supplies in the tax-
able year in which they are first used in the
taxpayer’s operations or consumed in the
taxpayer’s operations in accordance with
§§ 1 .162-3(a)(1) and 1 .162-3(c)(1);
(b) A change to deducting amounts
to acquire or produce incidental mate-
rials and supplies in the taxable year in
which paid or incurred in accordance with
§§ 1 .162-3(a)(2) and 1 .162-3(c)(1);
(c) A change to deducting amounts paid
or incurred to acquire or produce non-in-
cidental rotable and temporary spare parts
in the taxable year which the taxpayer
disposes of the parts in accordance with
§§ 1 .162-3(a)(3) and 1 .162-3(c)(2);
(d) A change to the optional method
of accounting for rotable and temporary
spare parts in accordance with § 1 .162-
3(e);
(e) A change to deducting amounts paid
or incurred for repair and maintenance in
accordance with § 1 .162-4, including a
change, if any, in identifying the unit of
property under § 1 .263(a)-3(e) or, in the
case of a building, identifying the build-
ing structure or building systems under
§ 1 .263(a)-3(e)(2) for purposes of making
the change to deducting the amounts;
(f) A change to capitalizing amounts
paid or incurred for improvements to
tangible property in accordance with
§ 1 .263(a)-3 and, if depreciable, to depre-
ciating such property under § 167 or § 168,
including a change, if any, in identifying
the unit of property under § 1 .263(a)-3(e)
or, in the case of a building, identifying
the building structure or building systems
under § 1 .263(a)-3(e)(2) for purposes

November 25, 2019 1146 Bulletin No. 2019–48
of making the change to capitalizing the
amounts;
(g) A change by a dealer in property
to deduct amounts paid or incurred for
commissions and other costs that facilitate
the sale of property in accordance with
§ 1 .263(a)-1(e)(2);
(h) A change by a non-dealer in proper-
ty to capitalizing amounts paid or incurred
for commissions and other costs that fa-
cilitate the sale of property in accordance
with § 1 .263(a)-1(e);
(i) A change to capitalizing amounts
paid or incurred to acquire or produce
property in accordance with § 1 .263(a)-
2, and if depreciable, to depreciating such
property under § 167 or § 168;
(j) A change to deducting amounts paid
or incurred in the process of investigating
or otherwise pursuing the acquisition of
real property if the amounts meet the re-
quirements of § 1 .263(a)-2(f)(2)(iii); and
(k) A change to the optional regulato-
ry accounting method in accordance with
§ 1 .263(a)-3(m) to determine whether
amounts paid or incurred to repair, main-
tain, or improve tangible property are
treated as deductible expenses or capital
expenditures .
(3) Manner of making change .
(a) Form 3115 . In addition to the other in-
formation required on line 14 of Form 3115,
the taxpayer must include the following:
(i) The citation to the paragraph of the
final tangible property regulations that
provides for the proposed method, or
methods, of accounting to which the tax-
payer is changing (for example, § 1 .162-
3(a), § 1 .263(a)-3(i), § 1 .263(a)-3(k)); and
(ii) If the taxpayer is changing any
unit(s) of property under § 1 .263(a)-3(e)
or, in the case of a building, is changing the
identification of any building structure(s)
or building system(s) under § 1 .263-3(e)
(2) for purposes of determining whether
amounts are deducted as repair and main-
tenance costs under section § 1 .162-4 or
capitalized as improvement costs under
§ 1 .263(a)-3, the taxpayer must include a
detailed description of the unit(s) of prop-
erty, building structure(s), or buildings
system(s) used under its present method
of accounting and a detailed description
of the unit(s) of property, building struc-
ture(s), and building system(s) under its
proposed method of accounting, together
with a citation to the paragraph of the final
tangible property regulations under which
the unit of property is permitted .
(iii) A taxpayer changing its method
of accounting under this section 11 .08 to
capitalizing amounts paid or incurred and
to depreciating such property under § 167
or § 168, as applicable, must complete
Schedule E of Form 3115 .
(b) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, is required to
complete only the following information
on Form 3115 (Rev . December 2018):
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I, line 1(a);
(iv) Part II, all lines except lines 13, 15,
16, 17, and 19, if the change is to not de-
preciating property;
(v) Part II, all lines except line 13, line
15b, 16, 17, and 19, if the change is to de-
preciating property;
(vi) Part IV, lines 26 and 27; and
(vii) Schedule E, if applicable .
(4) Concurrent automatic change .
(a) A taxpayer making two or more
changes in method of accounting pursuant
to this section 11.08 should file a single
Form 3115 for all of these changes and
must enter the designated automatic ac-
counting method change numbers for all
of these changes on the appropriate line on
the Form 3115 .
(b) A taxpayer making both one or
more changes in method of accounting
pursuant to this section 11 .08 and a change
to a UNICAP method under section 12 of
this revenue procedure (as applicable) for
the same year of change should file a sin-
gle Form 3115 that includes all of these
changes and must enter the designated
automatic accounting method change
numbers for all of these changes on the
appropriate line on that Form 3115 . See
section 6 .03(1)(b) of Rev . Proc . 2015-13
for information on making concurrent
changes. For example, a qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, must include
on the single Form 3115 the information
required by section 11 .08(3)(b) of this
revenue procedure for this change and the
information required by the lines on Form
3115, applicable to the UNICAP method
change, including Part II lines 14 and 15,
Part IV, and Schedule D, and must include
a separate response to each line on Form
3115 that is applicable to both changes
(such as Part II lines 6b, 7, 8b, 14, and,
as applicable for this change, Part IV) for
which the taxpayer’s response is different
for this change and the change to a UNI-
CAP method .
(5) Section 481(a) adjustment .
(a) In general . Except as provided in
section 11 .08(5)(b) of this revenue proce-
dure, a taxpayer changing to a method of
accounting provided in this section 11 .08
must apply § 481(a) and take into account
any applicable § 481(a) adjustment in the
manner provided in section 7 .03 of Rev .
Proc . 2015-13 .
(b) Limited adjustment for certain
changes .
(i) Final tangible property regulations .
A taxpayer changing to a method of ac-
counting under § 1 .162-3 (except § 1 .162-
3(e)), § 1 .263(a)-2(f)(2)(iii), § 1 .263(a)-
2(f)(3)(ii), § 1 .263(a)-3(m), § 1 .263A-1(e)
(2)(i)(A), and § 1 .263A-1(e)(3)(ii)(E) is
required to calculate a § 481(a) adjustment
as of the first day of the taxpayer’s taxable
year of change that takes into account only
amounts paid or incurred in taxable years
beginning on or after January 1, 2014 . Op-
tionally, a taxpayer may take into account
amounts paid or incurred in taxable years
beginning on or after January 1, 2012 .
(ii) Small business exception . A tax-
payer that met the scope requirements of
section 4 of Rev . Proc . 2015-20, 2015-9
I .R .B . 694, and that changed its method
of accounting under section 10 .11(3)(a) of
Rev . Proc . 2015-14 (which is now section
11 .08(2) of this revenue procedure) by fol-
lowing section 5 of Rev . Proc . 2015-20 is
required to calculate a § 481(a) adjustment
as of the first day of the year of change
that takes into account only amounts paid
or incurred in taxable years beginning on
or after January 1, 2014 .
(c) Itemized listing on Form 3115 . A
taxpayer changing to a method of ac-
counting provided in this section 11 .08
must include on Form 3115 (Rev . De-
cember 2018), Part IV, line 26, the total
§ 481(a) adjustment for each change in
method of accounting being made . If the
taxpayer is making more than one change
in method of accounting under the final
tangible property regulations, the taxpay-

Bulletin No. 2019–48 1147 November 25, 2019
er (including a qualified small taxpayer)
must include on an attachment to Form
3115:
(i) The information required by Part
IV, line 26 of Form 3115 (Rev . Decem-
ber 2018) for each change in method of
accounting (including the amount of the
§ 481(a) adjustment for each change in
method of accounting, which includes the
portion of the § 481(a) adjustment attrib-
utable to UNICAP);
(ii) The information required by Part
II, line 14 of Form 3115 (Rev . December
2018) for each change; and
(iii) The citation to the paragraph of
the final tangible property regulations that
provides for each proposed method of ac-
counting .
(d) Repair allowance property . A tax-
payer changing to a method of accounting
provided by § 1 .263(a)-3 under this sec-
tion 11 .08 must not include in the § 481(a)
adjustment any amount attributable to
property for which the taxpayer elect-
ed to apply the repair allowance under
§ 1 .167(a)-11(d)(2) for any taxable year in
which the repair allowance election was
made .
(e) Statistical Sampling . Except for any
change in accounting method for which a
taxpayer is required to compute a § 481(a)
adjustment under section 11 .08(5)(b) of
this revenue procedure, a taxpayer chang-
ing its method of accounting under this
section 11 .08 may use statistical sampling
in determining the § 481(a) adjustment by
following the guidance provided in Rev .
Proc . 2011-42, 2011-37 I .R .B . 318 .
(6) No audit protection . A taxpayer cal-
culating a § 481(a) adjustment under sec-
tion 11 .08(5)(b)(ii) of this revenue proce-
dure that takes into account only amounts
paid or incurred in taxable years begin-
ning on or after January 1, 2014, does not
receive audit protection under section 8 .01
of Rev . Proc . 2015-13 for amounts subject
to a change under this section 11 .08 that
are paid or incurred in taxable years be-
ginning before January 1, 2014 . See sec-
tion 5 .02 of Rev . Proc . 2015-20 .
(7) Designated automatic accounting
method change number . See the follow-
ing table for the designated automatic ac-
counting method change numbers (DCN)
for the changes in method of accounting
under this section 11 .08 .
(a) Changes under the final tangible
property regulations.
Description of ChangeDCNCitation
A change to deducting amounts paid or incurred for repair and maintenance or a change to
capitalizing amounts paid or incurred for improvements to tangible property and, if depre-
ciable, to depreciating such property under § 167 or § 168 . Includes a change, if any, in the
method of identifying the unit of property, or in the case of a building, identifying the build-
ing structure or building systems for the purpose of making this change .
184§§ 1 .162-4, 1 .263(a)-3
Change to the regulatory accounting method .185§ 1 .263(a)-3(m)
Change to deducting non-incidental materials and supplies when used or consumed .186§ 1 .162-3(a)(1), (c)(1)
Change to deducting incidental materials and supplies when paid or incurred .187§ 1 .162-3(a)(2), (c)(1)
Change to deducting non-incidental rotable and temporary spare parts when disposed of .188§ 1 .162-3(a)(3), (c)(2)
Change to the optional method for rotable and temporary spare parts .189§ 1 .162-3(e)
Change by a dealer in property to deduct commissions and other costs that facilitate the sale
of property .
190§ 1 .263(a)-1(e)(2)
Change by a non-dealer in property to capitalizing commissions and other costs that facilitate
the sale of property .
191§ 1 .263(a)-1(e)(1)
Change to capitalizing acquisition or production costs and, if depreciable, to depreciating
such property under § 167 or § 168 .
192§ 1 .263(a)-2
Change to deducting certain costs for investigating or pursuing the acquisition of real proper-
ty (whether and which) .
193§ 1 .263(a)-2(f)(2)(iii)
(8) Contact information . For further
information regarding a change under this
section, contact Douglas Kim at (202)
317-7003 (not a toll-free number) .
.09 Railroad track structure expendi-
tures .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for railroad track
structures to:
(a) the safe harbor method provided in
Rev . Proc . 2002-65, 2002-2 C .B . 700; or
(b) the safe harbor method provided in
Rev . Proc . 2001-46, 2001-2 C .B . 263 .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
11 .09 is “213 .”
(3) Contact information . For further
information regarding a change under this
section, contact Douglas Kim at (202)
317-7003 (not a toll-free number) .
.10 Remodel-refresh safe harbor method .
(1) Description of change .
(a) Applicability . This change applies
to a qualified taxpayer as defined in sec-
tion 4 .01 of Rev . Proc . 2015-56, 2015-49
I .R .B . 827, and within the scope of Rev .

November 25, 2019 1148 Bulletin No. 2019–48
Proc . 2015-56 that wants to change to the
remodel-refresh safe harbor method of ac-
counting provided in section 5 .02 of Rev .
Proc. 2015-56 for its qualified costs, in-
cluding the making of a late general asset
account election as provided under section
5 .02(6)(d) of Rev . Proc . 2015-56 .
(b) Inapplicability . This change does
not apply to the following:
(i) The revocation of a partial disposi-
tion election that is made pursuant to sec-
tion 5 .02(4)(b)(ii)(B) of Rev . Proc . 2015-
56;
(ii) A change in determination of the as-
set disposed of described in section 5 .02(5)
of Rev . Proc . 2015-56 (which is made un-
der section 6 .13(3)(a) or 6 .15(3)(a) of this
revenue procedure, as applicable) . See
section 11 .10(5)(b) of this revenue proce-
dure for making the change under section
6 .13(3)(a) or 6 .15(3)(a) of this revenue pro-
cedure as a concurrent change;
(iii) The making of a late general asset
account election not provided under sec-
tion 5 .02(6)(d) of Rev . Proc . 2015-56;
(iv) If section 5 .02(4)(c) of Rev . Proc .
2015-56 applies to a qualified building
(partial disposition election made in a pri-
or year and the qualified taxpayer did not
revoke such election within the time and in
the manner provided in section 5 .02(4)(b)
(ii) of Rev. Proc. 2015-56), any qualified
costs paid for that qualified building prior
to the year of change for a Form 3115 filed
to make the change to the remodel-refresh
safe harbor method of accounting under
this section 11 .10; or
(v) If section 5 .02(5)(b) of Rev . Proc .
2015-56 applies to a qualified building
(recognized gain or loss under § 1 .168(i)-
1T or § 1 .168(i)-8T, or in a taxable year
beginning before January 1, 2012, for
disposition of a component of a qualified
building) and the qualified taxpayer did
not make the required change in meth-
od of accounting to be in accord with §
1 .168(i)-1(e)(2)(viii) or § 1 .168-8(c)(4),
as applicable, on or before the first taxable
year that the qualified taxpayer uses the
remodel-refresh safe harbor and takes the
entire amount of the § 481(a) adjustment
into account in computing the qualified
taxpayer’s taxable income for that year of
change, any qualified costs paid for that
qualified building prior to the first taxable
year that the qualified taxpayer or the IRS
makes the change specified in section
6 .13(3)(a) or 6 .15(3)(a) of this revenue
procedure, as applicable, for that qual-
ified building and takes into account the
entire amount of the § 481(a) adjustment
in computing taxable income for the year
of change .
(2) No audit protection . If section
5 .02(4)(c) or 5 .02(5)(b) of Rev . Proc .
2015-56 applies to a qualified building
(and, in the case of section 5 .02(5)(b), the
qualified taxpayer does not make the re-
quired change on or before the first taxable
year that the qualified taxpayer uses the
remodel-refresh safe harbor), the qualified
taxpayer does not receive audit protection
under section 8 .01 of Rev . Proc . 2015-13
in connection with this change for that
qualified building. See section 8 .02(2) of
Rev . Proc . 2015-13 .
(3) Manner of making change .
(a) Reduced filing requirement for qual-
ified small taxpayers. A qualified small
taxpayer, as defined in section 6.01(4)(b)
of this revenue procedure, may complete
only the following information on Form
3115 (Rev . December 2018):
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I, line 1(a);
(iv) Part II, all lines except lines 5, 13,
15, 16, 17, and 19;
(v) Part IV, lines 25, 26, and 27;
(vi) Schedule E; and
(vii) If applicable, the election state-
ment described in section 11 .10(3)(b)(ii) .
(b) Late general asset account election .
(i) In general . If under section 5 .02(6)
(d) of Rev. Proc. 2015-56 the qualified
taxpayer is required to make a late gen-
eral asset account election, the late gener-
al asset account election change is made
using a modified cut-off method under
which the unadjusted depreciable basis
and the depreciation reserve of the asset
as of the beginning of the year of change
are accounted for using the new method of
accounting . The late general asset account
election change requires the general asset
account to include a beginning balance for
both the unadjusted depreciable basis and
the depreciation reserve . The beginning
balance for the unadjusted depreciable ba-
sis of each general asset account is equal
to the sum of the unadjusted depreciable
bases as of the beginning of the year of
change for all assets included in that gen-
eral asset account . The beginning balance
of the depreciation reserve of each general
asset account is equal to the sum of the
greater of the depreciation allowed or al-
lowable as of the beginning of the year of
change for all assets included in that gen-
eral asset account .
(ii) Election statement. The qualified
taxpayer (including a qualified small
taxpayer) must attach to its Form 3115 a
statement providing that the qualified tax-
payer agrees to the following additional
terms and conditions:
(A) The qualified taxpayer consents
to, and agrees to apply, all of the provi-
sions of § 1 .168(i)-1 to the assets that are
subject to the election specified in section
5 .02(6)(d) of Rev . Proc . 2015-56; and
(B) Except as provided in § 1 .168(i)-
1(c)(1)(iii)(A), (e)(3), (g), or (h), the elec-
tion made by the qualified taxpayer under
section 5 .02(6)(d) of Rev . Proc . 2015-56
is irrevocable and will be binding on the
qualified taxpayer for computing taxable
income for the year of change and for all
subsequent taxable years with respect to
the assets that are subject to this election .
(c) Cut-off method required for certain
changes .
(i) If section 5 .02(4)(c) of Rev . Proc .
2015-56 applies to a qualified building,
the change to the remodel-refresh safe
harbor method of accounting for that
qualified building, and any improvements
to that qualified building, is made using a
cut-off method and applies only to qual-
ified costs paid or incurred for that qual-
ified building, and any improvements to
that qualified building, beginning in the
year of change for the change made to the
remodel-refresh safe harbor method of ac-
counting .
(ii) If section 5 .02(5)(b) of Rev . Proc .
2015-56 applies to a qualified building
and the qualified taxpayer does not change
its present method of accounting to be in
accord with § 1 .168(i)-1(e)(2)(viii) or §
1 .168(i)-8(c)(4), as applicable, on or be-
fore the first taxable year that the quali-
fied taxpayer used the remodel-refresh
safe harbor and take the entire amount of
the § 481(a) adjustment into account in
computing the qualified taxpayer’s tax-

Bulletin No. 2019–48 1149 November 25, 2019
able income for that year of change, the
change to the remodel-refresh safe harbor
method of accounting for that qualified
building, and any improvements to that
qualified building, is made using a cut-
off method and applies only to qualified
costs paid or incurred for that qualified
building, and any improvements to that
qualified building, beginning in the year
of change for the change made to comply
with § 1 .168(i)-1(e)(2)(viii) or § 1 .168(i)-
8(c)(4), as applicable . See section 6 .13(3)
(a) and section 6 .15(3)(a) of this revenue
procedure, as applicable .
(4) Section 481(a) adjustment .
(a) In general. A qualified taxpayer
changing its method of accounting under
this section 11 .10 must apply § 481(a)
and take into account any applicable
§ 481(a) adjustment in the manner pro-
vided in section 7 .03 of Rev . Proc . 2015-
13 . However, a § 481(a) adjustment is
neither required nor permitted for the
late general asset account election under
section 5 .02(6)(d) of Rev . Proc . 2015-56
or, if section 5 .02(4)(c) or 5 .02(5)(b) of
Rev. Proc. 2015-56 applies to a qualified
building, and an improvement to a qual-
ified building (and, in the case of section
5 .02(5)(b) of Rev . Proc . 2015-56, the
qualified taxpayer did not make the re-
quired change on or before the first tax-
able year that the qualified taxpayer uses
the remodel-refresh safe harbor), for the
change to the remodel-refresh safe har-
bor method of accounting for that quali-
fied building and an improvement to that
qualified building.
(b) Repair allowance property . A qual-
ified taxpayer changing to the method of
accounting provided under this section
11 .10 must not include in the § 481(a)
adjustment any amount attributable to
property for which the qualified taxpay-
er elected to apply the repair allowance
under § 1 .167(a)-11(d)(2) for any taxable
year in which the repair allowance elec-
tion was made .
(c) Statistical sampling. A qualified tax-
payer changing its method of accounting
under this section 11 .10 may use statistical
sampling in determining the § 481(a) ad-
justment only by following the sampling
procedures provided in Rev . Proc . 2011-
42, 2011-37 I .R .B . 318 .
(5) Concurrent automatic change .
(a) A qualified taxpayer making this
change for more than one asset for the
same year of change should file a single
Form 3115 for all such assets . The sin-
gle Form 3115 must provide a single net
§ 481(a) adjustment for all such changes .
(b) A qualified taxpayer making this
change, a change under section 6 .13(3)
(a) of this revenue procedure, and any
change listed in section 6 .12(3)(b) or sec-
tion 6 .15 of this revenue procedure for the
same year of change should file a single
Form 3115 for all such changes and must
enter the designated automatic accounting
method change numbers for the changes
on the appropriate line on the Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to the method of ac-
counting under this section 11 .10 is “222 .”
(7) Contact information . For further
information regarding a change under this
section, contact Merrill Feldstein at (202)
317-5100 (not a toll-free number) .
SECTION 12 . UNIFORM
CAPITALIZATION (UNICAP)
METHODS (§ 263A)
.01 Certain uniform capitalization
(UNICAP) methods used by resellers and
reseller-producers .
(1) Description of change .
(a) Applicability . This change applies
to:
(i) a small reseller of personal prop-
erty that wants to change from a permis-
sible UNICAP method to a permissible
non-UNICAP inventory capitalization
method in any taxable year that it qualifies
as a small reseller;
(ii) a formerly small reseller that wants
to change from a permissible non-UNI-
CAP inventory capitalization method to a
permissible UNICAP method in the first
taxable year that it does not qualify as a
small reseller;
(iii) a reseller-producer that wants
to change from a permissible UNICAP
method for both its production and resale
activities to a permissible simplified re-
sale method described in § 1 .263A-3(d)
(3) in any taxable year that it qualifies to
use a simplified resale method for both
its production and resale activities under
§ 1 .263A-3(a)(4) (resellers with de mini-
mis production activities);
(iv) a reseller-producer that wants to
change from a permissible simplified re-
sale method described in § 1 .263A-3(d)
(3) for both its production and resale ac-
tivities to a permissible UNICAP method
for both its production and resale activi-
ties in the first taxable year that it does not
qualify to use a simplified resale method
for both its production and resale activi-
ties under § 1 .263A-3(a)(4);
(v) a reseller that wants to change its
permissible UNICAP method to include a
special reseller cost allocation rule;
(vi) a reseller or reseller-producer that
wants to change to a UNICAP method
(or methods) specifically described in the
regulations and includes any necessary
changes in the identification of costs sub-
ject to § 263A that will be accounted for
using the proposed method in any taxable
year, other than the first taxable year, that
it does not qualify as a small reseller; or
(vii) a reseller or reseller-producer that
wants to change from not capitalizing a
cost subject to § 263A to capitalizing that
cost under a UNICAP method (or meth-
ods) specifically described in the regula-
tions that the reseller or reseller-producer
is already using .
(b) Inapplicability .
(i) Self constructed assets . This change
does not apply to a taxpayer that wants
to use either the simplified service cost
method, the simplified production meth-
od, or the modified simplified production
method for self-constructed assets under
§§ 1 .263A-1(h)(2)(i)(D), 1 .263A-2(b)(2)
(i)(D), and 1 .263A-2(c)(2), respectively .
(ii) Historic absorption ratio .
(A) In general . This change does not
apply to a taxpayer that (1) wants to
make a historic absorption ratio election
with the simplified production method,
the modified simplified production meth-
od, or the simplified resale method under
§§ 1 .263A-2(b)(4), 1 .263A-2(c)(4), or
1 .263A-3(d)(4), respectively; (2) wants
to revoke an election to use a historic
absorption ratio with the simplified pro-
duction method, the modified simplified
production method, or the simplified re-

November 25, 2019 1150 Bulletin No. 2019–48
sale method (see §§ 1 .263A-2(b)(4)(iii)
(B), 1 .263A-2(c)(4), or 1 .263A-3(d)(4)
(iii)(B), respectively); or (3) uses a his-
toric absorption ratio election with the
simplified production method, the mod-
ified simplified production method, or
the simplified resale method and wants
to change to a different method for de-
termining the additional section 263A
costs that must be capitalized to ending
inventories or other eligible property
on hand at the end of the taxable year
(that is, to a different simplified method
or a facts-and-circumstances method) .
However, this change applies to a small
reseller that wants to change from the
simplified resale method with a historic
absorption ratio election to a permissible
non-UNICAP inventory capitalization
method under section 12 .01(1)(a)(i) of
this revenue procedure .
(B) Transition rule . Notwithstanding
the inapplicability rule in section 12 .01(1)
(b)(ii)(A) of this revenue procedure, for
the taxpayer’s first, second, or third tax-
able year ending on or after November 20,
2018, this change applies to:
(1) a reseller or reseller-producer that
is using a historic absorption ratio elec-
tion with the simplified resale method that
wants to change to the simplified produc-
tion method without a historic absorption
ratio election, the modified simplified pro-
duction method without a historic absorp-
tion ratio election, a specific identification
method under § 1 .263A-1(f)(2), or a bur-
den rate or standard cost method under
§ 1 .263A-1(f)(3); or
(2) a reseller or reseller-producer that
is using a historic absorption ratio election
with the simplified production method
that wants to change to the simplified re-
sale method without a historic absorption
ratio election, the modified simplified pro-
duction method without a historic absorp-
tion ratio election, a specific identification
method under § 1 .263A-1(f)(2), or a bur-
den rate or standard cost method under §
1 .263A-1(f)(3) .
(iii) Interest capitalization . This change
does not apply to a change in method of
accounting for interest capitalization (but
see section 12 .14 of this revenue proce-
dure) .
(iv) Recharacterizing costs under the
simplified resale method, simplified pro-
duction method, or modified simplified
production method . This change does not
include a change to recharacterize section
471 costs, as defined in § 1.263A-1(d)(2),
as additional section 263A costs, as de-
fined in § 1.263A-1(d)(3) (or vice versa)
for a taxpayer that uses or is changing to
the simplified resale method, the simpli-
fied production method, or the modified
simplified production method. See section
12 .17 of this revenue procedure for cer-
tain changes to recharacterize section 471
costs as additional section 263A costs (or
vice versa) .
(v) Certain change with limited ap-
plicability. A small reseller, as defined in
section 12 .01(3)(b) of this revenue proce-
dure, is not permitted to make a change in
method of accounting described in section
12 .01(1)(a)(i) of this revenue procedure
for a taxable year beginning after Decem-
ber 31, 2017 . See, however, section 12 .16
of this revenue procedure for making a
change in method of accounting not to
apply § 263A, and section 22 .19 of this
revenue procedure for making a change in
method of accounting for inventories, for
taxable years beginning after December
31, 2017 .
(2) Eligibility rules .
(a) Certain eligibility rule inapplicable .
The eligibility rule in section 5 .01(1)(f) of
Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
does not apply to the changes described in
section 12 .01(1)(a)(i) and (ii) of this reve-
nue procedure .
(b) Certain eligibility rule temporarily
inapplicable . The eligibility rule in sec-
tion 5 .01(1)(f) of Rev . Proc . 2015-13 does
not apply to the changes described in sec-
tion 12 .01(1)(a)(iii)-(vii) of this revenue
procedure for the taxpayer’s first, second,
or third taxable year ending on or after
November 20, 2018 .
(3) Definitions .
(a) “Reseller” means a taxpayer that ac-
quires real or personal property described
in § 1221(a)(1) for resale .
(b) “Small reseller” means a reseller
whose average annual gross receipts for
the three immediately preceding taxable
years (or fewer, if the taxpayer has not
been in existence for the three preceding
taxable years) do not exceed $10,000,000 .
See § 263A(b)(2)(B) .
(c) “Formerly small reseller” means a
reseller that no longer qualifies as a small
reseller .
(d) “Producer” means a taxpayer that
produces real or tangible personal proper-
ty .
(e) “Reseller-producer” means a tax-
payer that is both a producer and a reseller .
(f) “Permissible UNICAP method”
means a method of capitalizing costs that
is permissible under § 263A .
(g) “A UNICAP method specifical-
ly described in the regulations” does
not include any other reasonable allo-
cation method within the meaning of §
1 .263A-1(f)(4) . However, a “UNICAP
method specifically described in the reg-
ulations” includes:
(i) the 90-10 de minimis rule to allocate
a mixed service department’s costs to re-
sale activities (§ 1 .263A-1(g)(4)(ii));
(ii) the 1/3 - 2/3 rule to allocate labor
costs of personnel to purchasing activities
(§ 1 .263A-3(c)(3)(ii)(A));
(iii) the 90-10 de minimis rule to al-
locate a dual-function storage facility’s
costs to property acquired for resale (§
1 .263A-3(c)(5)(iii)(C));
(iv) the specific identification method
(§ 1 .263A-1(f)(2));
(v) the burden rate method (§
1 .263A-1(f)(3)(i));
(vi) the standard cost method (§
1 .263A-1(f)(3)(ii));
(vii) the direct reallocation method (§
1 .263A-1(g)(4)(iii)(A));
(viii) the step-allocation method (§
1 .263A-1(g)(4)(iii)(B));
(ix) the simplified service cost method
(§ 1 .263A-1(h)) (with either a labor-based
allocation ratio or a production cost allo-
cation ratio);
(x) the simplified resale method with-
out a historic absorption ratio election (§
1 .263A-3(d));
(xi) the alternative method to deter-
mine amounts of section 471 costs by
using a taxpayer’s financial statement (§
1 .263A-1(d)(2)(iii));
(xii) the method to determine amounts
of section 471 costs by using the amounts
incurred in the taxable year for federal in-
come tax purposes (§ 1 .263A-1(d)(2)(i));
(xiii) the safe harbor method for certain
variances and under- or over- applied bur-
dens (§ 1 .263A-1(d)(2)(v));

Bulletin No. 2019–48 1151 November 25, 2019
(xiv) the removal of one or more costs
from section 471 costs as required in §
1 .263A-1(d)(2)(vi);
(xv) the removal of one or more costs
from section 471 costs using negative ad-
justments to additional section 263A costs
as permitted in § 1 .263A-1(d)(3)(ii)(B);
(xvi) the de minimis rule for certain di-
rect labor costs (§ 1 .263A-1(d)(2)(iv)(B));
(xvii) the de minimis rule for certain di-
rect material costs (§ 1 .263A-1(d)(2)(iv)
(C));
(xviii) the simplified production meth-
od without a historic absorption ratio elec-
tion (§ 1 .263A-2(b));
(xix) the modified simplified produc-
tion method without a historic absorption
ratio election (§ 1 .263A-2(c));
(xx) the direct material costs or pre-pro-
duction labor costs allocation methods for
capitalizable mixed service costs under
the modified simplified production meth-
od (§ 1 .263A-2(c)(3)(iii)(B)); and
(xxi) the 90-10 de minimis rule to al-
locate capitalizable mixed service costs
under the modified simplified production
method (§ 1 .263A-2(c)(3)(iii)(C)) .
(h) “Special reseller cost allocation
rule” means the 90-10 de minimis rule
to allocate a mixed service department’s
costs to property acquired for resale
(§ 1 .263A-1(g)(4)(ii)), the 1/3 – 2/3 rule
to allocate labor costs of personnel to
purchasing activities (§ 1 .263A-3(c)(3)
(ii)(A)), and the 90-10 de minimis rule
to allocate a dual-function storage facili-
ty’s costs to property acquired for resale
(§ 1 .263A-3(c)(5)(iii)(C)) .
(i) “Permissible non-UNICAP invento-
ry capitalization method” means a method
of capitalizing inventory costs that is per-
missible under § 471 .
(4) Section 481(a) adjustment peri-
od . Beginning with the year of change, a
taxpayer changing its method of account-
ing for costs pursuant to section 12 .01(1)
(a)(i), 12 .01(1)(a)(iii), or 12 .01(1)(a)(iv)
of this revenue procedure generally must
take any applicable net positive § 481(a)
adjustment for such change into account
ratably over the same number of taxable
years, not to exceed four, that the taxpay-
er used its former method of accounting . A
taxpayer changing its method of account-
ing for costs pursuant to section 12 .01(1)
(a)(ii), 12 .01(1)(a)(v), or 12 .01(1)(a)(vi) of
this revenue procedure must take any ap-
plicable net positive § 481(a) adjustment
for such change into account as provided in
section 7 .03 of Rev . Proc . 2015-13 .
(5) Multiple changes . A taxpayer mak-
ing both this change and another change
in method of accounting for the same year
of change must comply with the ordering
rules of § 1 .263A-7(b)(2) .
(6) Under examination – certain audit
protection exception temporarily inappli-
cable. For a taxpayer’s first, second, or
third taxable year ending on or after No-
vember 20, 2018, the audit protection rule
in section 8 .02(1) of Rev . Proc . 2015-13
does not apply to a change in method of
accounting made under this section 12 .01 .
However, section 8 .02(1) of Rev . Proc .
2015-13 continues to apply for purposes
of determining the § 481(a) adjustment
period for a positive § 481(a) adjustment
provided in section 7 .03(3)(b) of Rev .
Proc . 2015-13 .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .01 is “22 .”
(8) Example . The following example
illustrates the principles of this section
12 .01 for small resellers and formerly
small resellers .
Assume X, a corporate reseller of per-
sonal property, incorporated January 2,
2005, adopted a taxable year ending De-
cember 31 . In determining whether X is
a small reseller, as provided in section
12 .01(3)(b) of this revenue procedure,
X calculates its average annual gross re-
ceipts for the three taxable years (or fewer,
if applicable) immediately preceding the
taxable year being analyzed . For each of
the taxable years 2005 through 2014, X
calculates the corresponding average an-
nual gross receipts for the three immedi-
ately preceding taxable years (or fewer, if
applicable) . The results are shown in the
table below:
Current
Taxable
Year
Average Annual Gross
Receipts for the Three Taxable
Years Immediately Preceding the
Current Taxable Year
2005$ 0
20065,000,000
20076,000,000
20087,000,000
200911,000,000
201011,000,000
2011 9,000,000
2012 8,000,000
201311,000,000
201412,000,000

November 25, 2019 1152 Bulletin No. 2019–48
Furthermore, X which adopted the dol-
lar-value LIFO inventory method, has the
following LIFO inventory balances deter-mined without considering the effects of
the UNICAP method:
BeginningEnding
2009$1,000,000$1,100,000
20101,100,0001,200,000
20111,200,0001,300,000
20121,300,0001,400,000
20131,400,0001,500,000
20141,500,0001,600,000
X
was required by § 263A to change
to the UNICAP method for 2009 because
its average annual gross receipts for the
three taxable years immediately preceding
2009 were $11,000,000, which exceeded
the $10,000,000 ceiling permitted by the
small reseller exception . Assume that X
was required to capitalize $80,000 of “ad-
ditional § 263A costs” to the cost of its
2009 beginning inventory because of this
change in inventory method . In addition,
X was required to include one-fourth of
the § 481(a) adjustment when computing
taxable income for each of the four tax-
able years beginning with 2009 . Thus, X
was required to include a $20,000 positive
§ 481(a) adjustment in its 2009 taxable
income .
X elected to use the simplified resale
method without an historic absorption
ratio election under § 1 .263A-3(d)(3)
for determining the amount of addition-
al § 263A costs to be capitalized to each
LIFO layer . Assume that X was required to
add $10,000 of additional § 263A costs to
the cost of its 2009 ending inventory be-
cause of the $100,000 increment for 2009 .
X’s 2009 Ending Inventory:
Beginning Inventory (Without UNICAP costs) $1,000,000
2009 Increment 100,000
Additional § 263A Costs in Beginning Inventory 80,000
Additional § 263A Costs in 2009 Increment 10,000
Total 2009 Ending Inventory $1,190,000
X’s Unamortized 2009 § 481(a) Adjustment:
2009 § 481(a) Adjustment $80,000
Amount included in 2009 Taxable Income <20,000>
Unamortized 2009 § 481(a) Adjustment—12/31/09 $60,000
Because X failed to satisfy the small re-
seller exception for 2010, X was required
to continue using the UNICAP method for
its inventory costs . Furthermore, X was re-
quired to include $20,000 of the unamor-
tized 2009 positive § 481(a) adjustment
in 2010 taxable income . Assume that X
was required to add $10,000 of additional
§ 263A costs to the cost of its 2010 ending
inventory because of the $100,000 incre-
ment for 2010 .
X’s 2010 Ending Inventory:
Beginning Inventory (With UNICAP costs) $1,190,000
2010 Increment 100,000
Additional § 263A Costs in 2010 Increment 10,000
Total 2010 Ending Inventory $1,300,000
X
’s Unamortized 2009 § 481(a) Adjustment:
Unamortized 2009 § 481(a) Adjustment—12/31/09 $60,000
Amount Included in 2010 Taxable Income <20,000>
Unamortized 2009 § 481(a) Adjustment—12/31/10 $40,000

Bulletin No. 2019–48 1153 November 25, 2019
Because X satisfied the small reseller
exception for 2011, X may change vol-
untarily from the UNICAP method to a
permissible non-UNICAP inventory cap-
italization method (such a change for a
current taxable year is provided in section
12.01 of this revenue procedure). To reflect
the removal of the additional § 263A costs
from the cost of its 2011 beginning in-
ventory, X must compute a corresponding
§ 481(a) adjustment, which is a negative
$100,000 ($1,200,000 - $1,300,000) . The
entire amount of this negative § 481(a) ad-
justment is included in the computation of
X’s taxable income for 2011 . In addition,
X must include $20,000 of the unamor-
tized 2009 § 481(a) adjustment in 2011
taxable income .
X’s 2011 Ending Inventory:
Beginning Inventory (With UNICAP costs) $1,300,000
2011 Increment 100,000
2011 § 481(a) Adjustment <Negative> <100,000>
Total 2011 Ending Inventory $1,300,000
X’s Unamortized 2009 § 481(a) Adjustment:
Unamortized 2009 § 481(a) Adjustment—12/31/10 $40,000
Amount included in 2011 Taxable Income <20,000>
Unamortized 2009 § 481(a) Adjustment—12/31/11 $20,000
X’s Unamortized 2011 § 481(a) Adjustment:
2011 § 481(a) Adjustment <Negative> $<100,000>
Amount included in 2011 Taxable Income 100,000
Unamortized 2011 § 481(a) Adjustment—12/31/11 $ 0
X
also satisfies the small reseller excep-
tion for 2012 and, therefore, is not required
to return to the UNICAP method for 2012 .
X, however, must include $20,000 of the
unamortized 2009 positive § 481(a) ad-
justment in its 2012 taxable income .
X’s 2012 Ending Inventory:
Beginning Inventory (Without UNICAP costs) $1,300,000
2012 Increment 100,000
Total 2012 Ending Inventory $1,400,000
X’s Unamortized 2009 § 481(a) Adjustment:
Unamortized 2009 § 481(a) Adjustment—12/31/11 $20,000
Amount in 2012 Taxable Income <20,000>
Unamortized 2009 § 481(a) Adjustment—12/31/12 $ 0
In 2013, X fails to satisfy the small
reseller exception and, therefore, must
return to the UNICAP method (such a
change for a current taxable year is pro-
vided in section 12 .01 of this revenue
procedure) . X changes to the simplified
resale method without a historic absorp-
tion ratio election under § 1 .263A-3(d)(3) .
Assume that X must capitalize $120,000
of additional § 263A costs to the cost of
its 2013 beginning inventory because
of this change in inventory method . Be-
cause X used a non-UNICAP method for
two taxable years prior to 2013, the § 481
spread period for the positive § 481(a) ad-
justment is two years . Therefore, X must
include one-half of the § 481(a) adjust-
ment ($60,000) when computing taxable
income for 2013 and 2014 . Assume that
X must add $10,000 of additional § 263A
costs to the cost of its 2013 ending inven-
tory because of the $100,000 increment
for 2013 .

November 25, 2019 1154 Bulletin No. 2019–48
X’s 2013 Ending Inventory:
Beginning Inventory (Without UNICAP costs) $1,400,000
2013 Increment 100,000
Additional § 263A costs in Beginning Inventory 120,000
Additional § 263A costs in 2013 Increment 10,000
Total 2013 Ending Inventory $1,630,000
X’s Unamortized 2013 § 481(a) Adjustment:
2013 § 481 Adjustment $ 120,000
Amount included in 2013 Taxable Income <60,000>
Unamortized 2013 § 481(a) Adjustment—12/31/13 $ 60,000
Because X fails to satisfy the small re-
seller exception for 2014, X must continue
using the UNICAP method for its inven-
tory costs . Furthermore, X is required to
include $60,000 of the unamortized 2013
positive § 481(a) adjustment in 2014 tax-
able income . Assume that X is required to
add $10,000 of additional § 263A costs to
the cost of its 2014 ending inventory be-
cause of the $100,000 increment for 2014 .
X’s 2014 Ending Inventory:
Beginning Inventory (With UNICAP costs) $1,630,000
2014 Increment 100,000
Additional § 263A Costs in 2014 Increment 10,000
Total 2014 Ending Inventory $1,740,000
X’s Unamortized 2013 § 481(a) Adjustment:
Unamortized 2013 § 481(a) Adjustment—12/31/13 $ 60,000
Amount included in 2014 Taxable Income <60,000>
Unamortized 2013 § 481(a) Adjustment—12/31/14 $ 0
(8) Contact information
. For further
information regarding a change under this
section, contact Kari Fisher at (202) 317-
7007 (not a toll-free number) .
.02 Certain uniform capitalization
(UNICAP) methods used by producers
and reseller-producers .
(1) Description of change .
(a) Applicability . This change ap-
plies to a producer (as defined in section
12 .01(3)(d) of this revenue procedure) or
a reseller-producer (as defined in section
12 .01(3)(e) of this revenue procedure) that
wants to change to a UNICAP method (or
methods) specifically described in the reg-
ulations, including any necessary chang-
es in the identification of costs subject to
§ 263A that will be accounted for using
the proposed method . This change also
includes a change from not capitalizing a
cost subject to § 263A to capitalizing that
cost for a producer or a reseller-produc-
er under a UNICAP method (or methods)
specifically described in the regulations
that the producer or reseller-producer is
already using .
(b) Inapplicability .
(i) Self-constructed assets . This change
does not apply to a taxpayer that wants
to use either the simplified service cost
method, the simplified production meth-
od, or the modified simplified production
method for self-constructed assets under
§§ 1 .263A-1(h)(2)(i)(D), 1 .263A-2(b)(2)
(i)(D), and 1 .263A-2(c)(2), respectively .
(ii) Historic absorption ratio .
(A) In general . This change does not
apply to a taxpayer that (1) wants to make
a historic absorption ratio election with
the simplified production method or the
modified simplified production method
under §§ 1 .263A-2(b)(4) or 1 .263A-2(c)
(4), respectively; (2) wants to revoke an
election to use a historic absorption ratio
with the simplified production method
or the modified simplified production
method (see §§ 1 .263A-2(b)(4)(iii)(B)
or 1 .263A-2(c)(4), respectively); or (3)
uses a historic absorption ratio election
with the simplified production method
or the modified simplified production
method and wants to change to a dif-
ferent method for determining the ad-
ditional section 263A costs that must be
capitalized to ending inventories or other
eligible property on hand at the end of
the taxable year (that is, to a different
simplified method or a facts-and-circum-
stances method) .
(B) Transition rule . Notwithstanding
the inapplicability rule in section 12 .02(1)
(b)(ii)(A) of this revenue procedure, for
the taxpayer’s first, second, or third tax-
able year ending on or after November 20,
2018, this change applies to a taxpayer that
is using the simplified production method
with a historic absorption ratio election
that wants to change to the modified sim-
plified production method without a his-
toric absorption ratio election, a specific
identification method under § 1.263A-1(f)
(2), or a burden rate or standard cost meth-
od under § 1 .263A-1(f)(3) .
(iii) Interest capitalization . This change
does not apply to a change in method of
accounting for interest capitalization (but
see section 12 .14 of this revenue proce-
dure) .

Bulletin No. 2019–48 1155 November 25, 2019
(iv) Recharacterizing costs under the
simplified production method or modi-
fied simplified production method . This
change does not include a change to re-
characterize section 471 costs, as defined
in § 1 .263A-1(d)(2), as additional section
263A costs, as defined in § 1.263A-1(d)
(3), (or vice versa) for a taxpayer that uses
or is changing to the simplified produc-
tion method or the modified simplified
production method . See section 12 .17 of
this revenue procedure for certain chang-
es to recharacterize section 471 costs as
additional section 263A costs (or vice
versa) .
(v) Reseller-producer using the simpli-
fied resale method . This change does not
apply to a reseller-producer that uses or
is changing to the simplified resale meth-
od under § 1 .263A-3(d) (but see section
12 .01(1) of this revenue procedure for
certain changes that may be made by a re-
seller-producer) .
(2) Definition . A “UNICAP method
specifically described in the regulations”
does not include the simplified resale
method under § 1 .263A-3(d)(4) or any
other reasonable allocation method within
the meaning of § 1 .263A-1(f)(4) . Howev-
er, a “UNICAP method specifically de-
scribed in the regulations” includes:
(a) the 90-10 de minimis rule to allocate
a mixed service department’s costs to pro-
duction or resale activities (§ 1 .263A-1(g)
(4)(ii));
(b) the 1/3 - 2/3 rule to allocate labor
costs of personnel to purchasing activities
(§ 1 .263A-3(c)(3)(ii)(A));
(c) the 90-10 de minimis rule to al-
locate a dual-function storage facility’s
costs to property acquired for resale (§
1 .263A-3(c)(5)(iii)(C));
(d) the specific identification method (§
1 .263A-1(f)(2));
(e) the burden rate method (§
1 .263A-1(f)(3)(i));
(f) the standard cost method (§
1 .263A-1(f)(3)(ii));
(g) the direct reallocation method (§
1 .263A-1(g)(4)(iii)(A));
(h) the step-allocation method (§
1 .263A-1(g)(4)(iii)(B));
(i) the simplified service cost method
(§ 1 .263A-1(h)) (with either a labor-based
allocation ratio or a production cost allo-
cation ratio);
(j) the simplified production method
without a historic absorption ratio election
(§ 1 .263A-2(b));
(k) the alternative method to deter-
mine amounts of section 471 costs by
using a taxpayer’s financial statement (§
1 .263A-1(d)(2)(iii));
(l) the method to determine amounts
of section 471 costs by using the amounts
incurred in the taxable year for federal in-
come tax purposes (§ 1 .263A-1(d)(2)(i));
(m) the safe harbor method for certain
variances and under- or over-applied bur-
dens (§ 1 .263A-1(d)(2)(v));
(n) the removal of one or more costs
from section 471 costs as required in §
1 .263A-1(d)(2)(vi);
(o) the removal of one or more costs
from section 471 costs using negative ad-
justments to additional section 263A costs
as permitted in § 1 .263A-1(d)(3)(ii)(B);
(p) the de minimis rule for certain di-
rect labor costs (§ 1 .263A-1(d)(2)(iv)(B));
(q) the de minimis rule for certain direct
material costs (§ 1 .263A-1(d)(2)(iv)(C));
(r) the modified simplified production
method without a historic absorption ratio
election (§ 1 .263A-2(c)(3));
(s) the direct material costs or pre-pro-
duction labor costs allocation methods for
capitalizable mixed service costs under
the modified simplified production meth-
od (§ 1 .263A-2(c)(3)(iii)(B)); and
(t) the 90-10 de minimis rule to allocate
capitalizable mixed service costs under
the modified simplified production meth-
od (§ 1 .263A-2(c)(3)(iii)(C)) .
(3) Multiple changes . A taxpayer mak-
ing both this change and another change
in method of accounting in the same year
of change must comply with the ordering
rules of § 1 .263A-7(b)(2) .
(4) Certain eligibility rule temporarily
inapplicable . The eligibility rule in section
5 .01(1)(f) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, does not apply to the changes
described in this section 12 .02 for the tax-
payer’s first, second, or third taxable year
ending on or after November 20, 2018 .
(5) Under examination – certain audit
protection exception temporarily inappli-
cable
. For a taxpayer’s first, second, or
third taxable year ending on or after No-
vember 20, 2018, the audit protection rule
in section 8 .02(1) of Rev . Proc . 2015-13
does not apply to a change in method of
accounting made under this section 12 .02 .
However, section 8 .02(1) of Rev . Proc .
2015-13 continues to apply for purposes
of determining the § 481(a) adjustment
period for a positive § 481(a) adjustment
provided in section 7 .03(3)(b) of Rev .
Proc . 2015-13 .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .02 is “23 .”
(7) Contact information . For further
information regarding a change under this
section, contact Kari Fisher at (202) 317-
7007 (not a toll-free number) .
.03 Impact fees .
(1) Description of change . This change
applies to a taxpayer that incurs impact
fees as defined in Rev. Rul. 2002-9, 2002-
1 C .B . 614, in connection with the con-
struction of a new residential rental build-
ing that wants to capitalize the costs to the
building under §§ 263(a) and 263A . See
Rev . Rul . 2002-9 for further information .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .03 is “25 .”
(3) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.04 Change to capitalizing environ-
mental remediation costs under § 263A .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for environmen-
tal remediation costs from a method that
does not comply with the holding in Rev .
Rul . 2004-18, 2004-1 C .B . 509, to capi-
talizing them to inventory under § 263A .
(2) Concurrent automatic changes . A
taxpayer making both this change and an-
other automatic change under § 263A for
the same year of change may file a single
Form 3115 for both changes, provided the
taxpayer enters the designated automat-
ic change numbers for both changes on
the appropriate line on that Form 3115,
and complies with the ordering rules of
§ 1 .263A-7(b)(2) . See section 6 .03(1)(b)
of Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
for information on making concurrent
changes .
(3) Designated automatic accounting
method change number . The designat-

November 25, 2019 1156 Bulletin No. 2019–48
ed automatic accounting method change
number for a change under this section
12 .04 is “77 .”
(4) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.05 Change in allocating environmen-
tal remediation costs under § 263A .
(1) Description of change . This change
applies to a taxpayer that capitalizes envi-
ronmental remediation costs to inventory
under § 263A, but allocates these costs to
inventory using a method of accounting
that does not comply with the holding in
Rev . Rul . 2005-42, 2005-2 C .B . 67, and
wants to change to allocating these costs
to inventory produced during the taxable
year in which the costs are incurred under
§ 263A . See Rev . Rul . 2005-42 for further
information .
(2) Concurrent automatic changes . A
taxpayer making both this change and an-
other automatic change under § 263A for
the same year of change may file a single
Form 3115 for both changes, provided the
taxpayer enters the designated automatic
accounting method change numbers for
both changes on the appropriate line on
that Form 3115, and complies with the
ordering rules of § 1 .263A-7(b)(2) . See
section 6 .03(1)(b) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, for information on
making concurrent changes .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .05 is “92 .”
(4) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.06 Safe harbor methods under § 263A
for certain dealerships of motor vehicles .
(1) Description of change . This change
applies to a motor vehicle dealership, as
defined in section 4 of Rev. Proc. 2010-
44, 2010-49 I .R .B . 811, that is within the
scope of section 3 of Rev . Proc . 2010-44
and wants to change its method of ac-
counting to (1) treat its sales facility as a
retail sales facility or (2) be treated as a
reseller without production activities, as
described in section 5 of Rev . Proc . 2010-
44 . A motor vehicle dealership that wants
to make an automatic change in method
of accounting to use one or both safe har-
bor methods described in section 5 of Rev .
Proc . 2010-44 may make any correspond-
ing changes in the identification of costs
subject to § 263A that will be accounted
for using the proposed method (for exam-
ple, to remove internal profit from inven-
tory costs) or to no longer include nega-
tive amounts as additional § 263A costs
in the numerator of the simplified resale
method formula or the simplified produc-
tion method formula . However, except
as provided in the preceding sentence, a
change under this section does not include
a change for purposes of recharacterizing
“§ 471 costs” as “additional § 263A costs”
(or vice versa) under the simplified resale
method or the simplified production meth-
od .
(2) Concurrent automatic changes . A
motor vehicle dealership making an auto-
matic change to one or both safe harbor
methods described in section 5 of Rev .
Proc . 2010-44 and another automatic
change under § 263A for the same taxable
year may file one Form 3115 to make both
changes, provided the dealership enters
the designated automatic change numbers
for all such changes in Part I on that Form
3115, and complies with the ordering rules
of § 1 .263A-7(b)(2) . See section 6 .03(1)
(b) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, for information on making concur-
rent changes .
(3) Multiple adjustments . In the event
that a motor vehicle dealership is taking
into account a § 481(a) adjustment from
another accounting method change in ad-
dition to the § 481(a) adjustment required
by a change to a safe harbor method de-
scribed in section 5 of Rev . Proc . 2010-44,
the § 481(a) adjustments must be taken
into account separately . For example, a
motor vehicle dealership that changed to
comply with § 263A in 2009 and was re-
quired to take its § 481(a) adjustment into
account over four years must continue
to take into account that adjustment over
the remainder of that four year § 481(a)
adjustment period even though the deal-
ership changed to a safe harbor method
described in section 5 of Rev . Proc . 2010-
44 in 2010 and has an additional § 481(a)
adjustment required by that change .
(4) Designated automatic accounting
method change numbers . The designat-
ed automatic accounting method change
number for a change to treat certain sales
facilities as retail sales facilities as de-
scribed in section 5 .01 of Rev . Proc . 2010-
44 is “150 .” The designated automatic
accounting method change number for a
change to be treated as a reseller without
production activities as described in sec-
tion 5 .02 of Rev . Proc . 2010-44 is “151 .”
(5) Contact information . For further
information regarding a change under this
section, contact Kari Fisher at (202) 317-
7007 (not a toll-free number) .
.07 Change to not apply § 263A to one
or more plants removed from the list of
plants that have a preproductive period in
excess of 2 years .
(1) Description of change . This change,
as described in Rev . Proc . 2013-20, 2013-
14 I .R .B . 744, applies to a taxpayer that is
not a corporation, partnership, or tax shel-
ter required to use an accrual method of
accounting under § 447 or § 448(a)(3), and
either (a) wants to not apply § 263A, pur-
suant to § 263A(d)(1) and § 1 .263A-4(a)
(2), to the production of one or more
plants that the IRS and the Treasury De-
partment have removed from the list of
plants that have a nationwide weighted
average preproductive period in excess of
2 years, or (b) properly elected, pursuant
to § 263A(d)(3) and § 1 .263A-4(d), to not
apply § 263A to the production of a plant
or plants that have been removed from
the list of plants that have a nationwide
weighted average preproductive period
in excess of 2 years, and wishes to revoke
its § 263A(d)(3) election with respect to
those plants . See Notice 2013-18, 2013-14
I .R .B . 742, or its successor .
(2) Audit protection . If a taxpayer
currently does not apply § 263A to its
blackberry, raspberry, or papaya plants in
a manner that complies with the require-
ments of § 263A(d)(1) and § 1 .263A-4(a)
(2), the IRS will not raise such method of
accounting for a taxable year that ends on
or before February 15, 2013 . Also, if the
use of such a method of accounting by a
taxpayer is an issue under consideration
(within the meaning of section 3 .08 of
Rev . Proc . 2015-13) for taxable years in
examination, before an Appeals office, or
before the U .S . Tax Court in a taxable year
that ends on or before February 15, 2013,
the IRS will not further pursue that issue .
(3) Manner of making change . A
change under this section 12 .07 is made

Bulletin No. 2019–48 1157 November 25, 2019
with any necessary adjustments under
§ 481(a) . For example, the revocation of
an election under § 263A(d)(3) results in a
§ 481(a) adjustment that must take into ac-
count the change in depreciation from the
alternative depreciation system to the gen-
eral depreciation system included within
such revocation .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .07 is “181 .”
(5) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .
.08 Change to a reasonable allocation
method described in § 1.263A-1(f)(4) for
self-constructed assets .
(1) Description of change .
(a) Applicability . This change, as de-
scribed in Rev . Proc . 2014-16, 2014-9
I .R .B . 606, applies to a producer (as de-
fined in section 12.01(3)(d) of this rev-
enue procedure) or a reseller-producer
(as defined in section 12.01(3)(e) of this
revenue procedure) that wants to change
to a reasonable allocation method within
the meaning of § 1 .263A-1(f)(4), other
than the methods specifically described
in § 1 .263A-1(f)(2) or (3), for self-con-
structed assets produced during the tax-
able year, including any necessary chang-
es in the identification of costs subject to
§ 263A that will be accounted for using
the proposed method . This section 12 .08
also includes a change from not capitaliz-
ing a cost subject to § 263A to capitalizing
that cost for a producer or reseller-produc-
er under a reasonable allocation method
within the meaning of § 1 .263A-1(f)(4)
that the producer or reseller-producer is
already using for self-constructed assets,
other than the methods specifically de-
scribed in § 1 .263A-1(f)(2) or (3) . See
section 12 .02 of this revenue procedure
for a producer or reseller-producer that
wants to change to a method described in
§ 1 .263A-1(f)(2) or (3) .
(b) Inapplicability . This change does
not apply to an allocation method based
on the number of units produced or an
allocation method that does not allocate
costs to the units of property produced .
This change does not apply to a change
described in another section of this reve-
nue procedure or in other guidance pub-
lished in the Internal Revenue Bulletin .
For example, this change does not apply
to a change described in section 12 .01 or
12 .02 of this revenue procedure .
(2) No ruling on reasonableness of
method . The consent granted in section
9 of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, for this change is not a determination
by the Commissioner that the taxpayer is
using a reasonable allocation method for
costs subject to § 263A and does not cre-
ate any presumption that the proposed al-
location method is permissible . The direc-
tor will ascertain whether the taxpayer’s
allocation method is reasonable within the
meaning of § 1 .263A-1(f)(4) .
(3) Multiple changes . A taxpayer mak-
ing both this change and another change in
method of accounting under section 11 .08
of this revenue procedure for the same
year of change must comply with the or-
dering rules of § 1 .263A-7(b)(2) .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .08 is “194 .”
(5) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.09 Real property acquired through
foreclosure .
(1) Applicability . This change, as de-
scribed in Rev . Proc . 2014-16, 2014-9
I .R .B . 606, applies to a taxpayer that
capitalizes costs under § 263A(b)(2) and
§ 1 .263A-3(a)(1) to real property acquired
through foreclosure, or similar transac-
tion, where the taxpayer wants to change
its method of accounting to an otherwise
permissible method of accounting un-
der which the acquisition and holding
costs for real property acquired through
foreclosure, or similar transaction, are
not capitalized under § 263A(b)(2) and
§ 1 .263A-3(a)(1) . To qualify for this
change in method of accounting, a taxpay-
er must:
(a) originate, or acquire and hold for
investment, loans that are secured by real
property; and
(b) acquire the real property that se-
cures the loans at a foreclosure sale, by
deed in lieu of foreclosure, or in another
similar transaction .
(2) Inapplicability . This change does
not apply to costs capitalized under
§ 263A(b)(1) and § 1 .263A-2(a)(1) by the
taxpayer to the acquired real property as a
result of production activities .
(3) Designated automatic accounting
method change numbers . The designat-
ed automatic accounting method change
number for a change under this section
12 .09 is “195 .”
(4) Contact information . For further
information regarding a change under this
section, contact Roy Hirschhorn at (202)
317-7007 (not a toll-free number) .
.10 Sales-Based Royalties.
(1) Description of change. This change,
as described in Rev . Proc . 2014-33, 2014-
22 I .R .B . 1060, applies to a taxpayer that
wants to change its method of accounting
for sales-based royalties (as described in
§ 1 .263A-1(e)(3)(ii)(U)(2)) that are prop-
erly allocable to inventory property:
(a) From not capitalizing sales-based
royalties to capitalizing these costs and
allocating them entirely to cost of goods
sold under a taxpayer’s method of ac-
counting;
(b) From not capitalizing sales-based
royalties to capitalizing these costs and al-
locating them to inventory property under
a taxpayer’s method of accounting;
(c) From capitalizing sales-based roy-
alties and allocating these costs to inven-
tory property to allocating them entirely to
cost of goods sold; or
(d) From capitalizing sales-based roy-
alties and allocating these costs entirely
to cost of goods sold to allocating them to
inventory property .
(2) Limitations.
(a) A taxpayer may not make a change
in method of accounting under this sec-
tion 12 .10 if the taxpayer wants to change
to capitalizing sales-based royalties and
allocating them to inventory property us-
ing another reasonable allocation method
within the meaning of § 1 .263A-1(f)(4) .
(b) A taxpayer making the changes de-
scribed in section 12 .10(1)(a) or 12 .10(1)
(c) of this revenue procedure that uses a
simplified method to determine the addi-
tional § 263A costs allocable to inventory
property on hand at year end must remove
sales-based royalties allocated to cost of
goods sold from the formulas used to al-
locate additional § 263A costs to ending
inventory in the same manner that the tax-

November 25, 2019 1158 Bulletin No. 2019–48
payer included these amounts in the for-
mulas .
(c) A taxpayer making a change in
method of accounting under this section
12.10 that uses a simplified method with
an historic absorption ratio election (see
§§ 1 .263A-2(b)(4) and 1 .263A-3(d)(4))
and currently includes, or is changing its
method to include, sales-based royalties
in any part of its historic absorption ratio
must revise its previous and current histor-
ic absorption ratios . To revise its historic
absorption ratios, the taxpayer must apply
its proposed method of accounting during
the test period, during all recomputation
years, and during all updated test periods
to determine the § 471 costs and addition-
al § 263A costs that were incurred . The
revised historic absorption ratios must be
used to revalue beginning inventory and
must be accounted for in the taxpayer’s
§ 481(a) adjustment . The taxpayer must
use a method described in § 1 .263A-7(c)
to revalue beginning inventory .
(3) Concurrent automatic changes .
A taxpayer making a change under this
section 12 .10 and one or more automatic
changes in method of accounting under
§ 263A for the same year of change may
file a single Form 3115 for all changes,
provided the taxpayer enters the desig-
nated automatic change numbers for all
changes on the appropriate line on the
Form 3115 and complies with the order-
ing rules of § 1 .263A–7(b)(2) . See section
6 .03(1)(b) of Rev . Proc . 2015-13 for in-
formation on making concurrent changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for changes in method of account-
ing under this section 12 .10 is “201 .”
(5) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.11 Treatment of Sales-Based Vendor
Chargebacks under a Simplified Method .
(1) Description of change. This change,
as described in Rev . Proc . 2014-33, 2014-
22 I .R .B . 1060, applies to a taxpayer that
wants to change its method of accounting
to no longer include cost adjustments for
sales-based vendor chargebacks described
in § 1 .471-3(e)(1) in the formulas used to
allocate additional § 263A costs to ending
inventory under a simplified method.
(2) Limitations .
(a) A taxpayer making this change that
uses a simplified method to determine the
additional § 263A costs allocable to in-
ventory property on hand at year end must
remove sales-based vendor chargebacks
from the formulas used to allocate addi-
tional § 263A costs to ending inventory in
the same manner that the taxpayer includ-
ed these amounts in the formulas .
(b) A taxpayer making a change in
method of accounting under this section
12.11 that uses a simplified method with
an historic absorption ratio election (see
§§ 1 .263A-2(b)(4) and 1 .263A-3(d)(4))
and currently includes sales-based vendor
chargebacks in any part of its historic ab-
sorption ratio must revise its previous and
current historic absorption ratio(s) . To re-
vise its historic absorption ratios, the tax-
payer must apply its proposed method of
accounting during the test period, during
all recomputation years, and during all up-
dated test periods to determine the § 471
costs and additional § 263A costs that
were incurred . The revised historic ab-
sorption ratios must be used to revalue be-
ginning inventory and must be accounted
for in the taxpayer’s § 481(a) adjustment .
The taxpayer must use a method described
in § 1 .263A-7(c) to revalue beginning in-
ventory .
(3) Concurrent automatic changes . A
taxpayer making both this change and one
or more automatic changes under § 263A,
or both this change and the change de-
scribed in section 21 .15 of this revenue
procedure for the same taxable year of
change may file a single Form 3115 for
both changes, provided the taxpayer en-
ters the designated automatic change
numbers for all changes on the appropri-
ate line on the Form 3115 and complies
with the ordering rules of § 1 .263A-7(b)
(2) . See section 6 .03(1)(b) of Rev . Proc .
2015-13 for information on making con-
current changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for changes in method of account-
ing under this section 12 .11 is “202 .”
(5) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.12 U.S. ratio method .
(1) Change to the U.S. ratio method .
(a) Description of change . This change
applies to a foreign person, as defined in
Notice 88-104, 1988-2 C .B . 443, as mod-
ified by Notice 89-67, 1989-1 C.B. 723,
that is required to capitalize costs under
§ 263A and wants to change its method
of accounting to the U .S . ratio method, as
described in Notice 88-104 .
(b) Manner of making change . A tax-
payer requesting a change on behalf of a
foreign person under section 12 .12(1) of
this revenue procedure must attach a state-
ment to the Form 3115 providing the fol-
lowing information:
(i) Foreign person requirement . A rep-
resentation that the foreign person is a
qualified business unit (QBU), as defined
in § 1 .989(a)-1(b), of a foreign person, or
the foreign branch of a U .S . person that
constitutes a separate QBU, within the
meaning of Notice 88-104 . If the taxpay-
er is requesting a change in method of
accounting on behalf of multiple foreign
persons, please provide a representation
that each foreign person is a QBU, as de-
fined in § 1.989(a)-1(b), of a foreign per-
son or the foreign branch of a U .S . person
that constitutes a separate QBU, within
the meaning of Notice 88-104;
(ii) Description of trade or business .
The name and employer identification
number (if applicable) for each foreign
person and an explanation of each trade
or business, as defined in § 1.446-1(d), for
which a request to change to the U .S . ratio
method is being made under this section
12 .12(1);
(iii) Applicable U.S. trade or business
requirement . The identity of the “appli-
cable U.S. trade or business,” as defined
in Notice 88-104, that the foreign person
wishes to use and an explanation of how
this U .S . trade or business is “the same as,
or most similar to” the trade or business
conducted by the foreign person . If the
taxpayer is requesting a change in method
of accounting for multiple foreign persons,
the taxpayer must identify the “applicable
U .S . trade or business” for each foreign
person, and explain how the respective
U .S . trade or business is “the same as, or
most similar to” the trade or business con-
ducted by the foreign person; and
(iv) Relationship requirement . An ex-
planation of how the “applicable U .S .
trade or business” identified in section

Bulletin No. 2019–48 1159 November 25, 2019
12 .12(1)(b)(iii) of this revenue procedure
is a trade or business conducted in the
United States by a “related person,” as de-
fined in Notice 88-104, with respect to the
foreign person requesting a change under
this section . If the taxpayer is requesting a
change in method of accounting for mul-
tiple foreign persons, the taxpayer must
explain how the “applicable U .S . trade or
business” identified in section 12.12(1)(b)
(iii) of this revenue procedure is a trade or
business conducted in the United States by
a “related person” for purposes of Notice
88-104 for each foreign person requesting
a change in method of accounting . Use
§§ 267(b) or 707(b), as applicable, to ex-
plain the relationship .
(c) Additional requirements .
(i) A foreign person must continue to
use the U .S . ratio of the applicable U .S .
trade or business identified in section
12 .12(1)(b)(iii) of this revenue procedure
unless consent of the Commissioner is ob-
tained to use the U .S . ratio of a different
applicable U .S . trade or business under
§ 446(e) (see section 12 .12(2) of this rev-
enue procedure);
(ii) In the case of a controlled foreign
corporation, the controlling U .S . share-
holder, or in the case of a foreign branch
of a U .S . person, the U .S . person, must
maintain records of the U .S . ratio used by
each foreign person to calculate the addi-
tional § 263A costs capitalized to property
produced and property acquired for resale
for the year of change and for subsequent
taxable years for each foreign person re-
questing a change in method of account-
ing under this section 12 .12 . In the case
of a controlled foreign partnership, the
U .S . partner must maintain records of the
U .S . ratio used by each foreign person to
calculate the additional § 263A costs cap-
italized to property produced and property
acquired for resale for the year of change
and for subsequent taxable years for each
foreign person requesting a change in
method of accounting under this section
12 .12 .
(iii) The § 481(a) adjustment is com-
puted in the manner provided in Notice
88-104;
(iv) The U .S . ratio is determined, and
the ratio is applied to the costs of property
produced or property acquired for resale
incurred by the foreign person, in accor-
dance with Notice 88-104; and
(v) If any foreign person is unable to
obtain a U .S . ratio from the applicable
U.S. trade or business identified in section
12 .12(2)(b)(iii) of this revenue procedure,
or is otherwise no longer eligible to use
the U .S . ratio method, the foreign person
is no longer permitted to use the U .S . ratio
method . However, the foreign person is
not ineligible to use the U .S . ratio meth-
od if the foreign person is able to obtain
a U .S . ratio from a different applicable
U .S . trade or business, and changes the
applicable U .S . trade or business pursuant
to section 12 .12(2) of this revenue proce-
dure or under the non-automatic change
procedures of this revenue procedure, as
applicable . If a foreign person is no lon-
ger eligible to use the U .S . ratio method,
it is required to change its method of ac-
counting to a method that complies with
§§ 263A and 471 using either the automat-
ic change procedures of Rev . Proc . 2015-
13, 2015-5 I .R .B . 419, and sections 12 .01,
12 .02, or 12 .08, as applicable, of this
revenue procedure or the non-automatic
change procedures of Rev . Proc . 2015-13 .
(2) Change within U.S. ratio method .
This change applies to a foreign person
currently using the U .S . ratio method that
wants to use the U .S . ratio of a different
applicable U .S . trade or business for pur-
poses of applying the U .S . ratio method
as described in section 12 .12(2)(a) or
12 .12(2)(b) of this revenue procedure .
(a) Required change in the applicable
U.S. trade or business .
(i) In general . A foreign person is per-
mitted to change its method of accounting
under this section 12 .12(2)(a) to use the
U .S . ratio of a different applicable U .S .
trade or business, as defined in Notice 88-
104, if the foreign person is no longer able
to obtain the U .S . ratio from the applicable
U .S . trade or business previously identi-
fied and if: (A) the U.S. person or related
person in which the applicable U .S . trade
or business is conducted terminates its ex-
istence; (B) the foreign person is no longer
related, within the meaning of § 267(b) or
§ 707(b), to the U .S . person or related per-
son in which the applicable U .S . trade or
business is conducted; or (C) the U .S . per-
son or related person ceases to conduct the
applicable U .S . trade or business .
(ii) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13 does not apply to
the change described in section 12 .12(2)
(a) of this revenue procedure .
(iii) Manner of making change . A for-
eign person making a change in method
of accounting under this section 12 .12(2)
(a) must make the change in accordance
with the requirement set forth in section
12 .12(2)(c) of this revenue procedure .
(b) Other changes in the applicable
U.S. trade or business .
(i) In general . If the foreign person
cannot make the change in method of ac-
counting described in section 12 .12(2)(a)
of this revenue procedure, or there is more
than one U .S . trade or business that can
reasonably be considered the “same as, or
most similar to” the foreign person’s trade
or business, the foreign person is permit-
ted to change its method of accounting un-
der this section 12 .12(2)(b) to use the U .S .
ratio of a different applicable U .S . trade
or business .
(ii) Manner of making change . A for-
eign person making a change in method
of accounting under this section 12 .12(2)
(b) must make the change in accordance
with the requirement set forth in section
12 .12(2)(c) of this revenue procedure .
(c) Short Form 3115 in lieu of a Form
3115 . In accordance with § 1 .446-1(e)(3)
(ii), the requirement of § 1 .446-1(e)(3)(i)
to file a Form 3115 is waived and pursu-
ant to section 6 .02(2) of Rev . Proc . 2015-
13, a short Form 3115 is authorized for a
change described in section 12 .12(2)(a) or
12 .12(2)(b) of this revenue procedure . The
short Form 3115 (Rev . December 2018)
must include the following information:
(i) the identification section of page 1
(above Part I);
(ii) the signature section at the bottom
of page 1;
(iii) Part I, line 1(a);
(iv) the information required under
section 12 .12(1)(b) of this revenue proce-
dure; and
(v) a statement that the change in meth-
od of accounting is made under section
12 .12(2)(a) or 12 .12(2)(b) of Rev . Proc .
2019-43, as applicable .
(3) Designated automatic accounting
method change numbers . The designat-
ed automatic accounting method change
number for a change under this section
12 .12 is “214 .”
(4) Contact information . For further
information regarding a change under this

November 25, 2019 1160 Bulletin No. 2019–48
section, contact Evan Hewitt at (202) 317-
7007 (not a toll-free number) .
.13 Depletion .
(1) Description of change. This change
applies to a taxpayer that wants to change
its method of accounting for depletion to
treat these amounts as an indirect cost that
is only properly allocable to property that
has been sold (that is, for purposes of de-
termining gain or loss on the sale of the
property) under § 1 .263A-1(e)(3)(ii)(J) .
(2) Limitation.
(a) A taxpayer making this change in
method of accounting that uses a simpli-
fied method to determine the additional
§ 263A costs allocable to inventory prop-
erty on hand at year end must remove
depletion allocated to cost of goods sold
from the formulas used to allocate addi-
tional § 263A costs to ending inventory in
the same manner that the taxpayer includ-
ed these amounts in the formulas .
(b) A taxpayer making this change in
method of accounting that uses a simpli-
fied method with an historic absorption
ratio election (see §§ 1 .263A-2(b)(4) and
1 .263A-3(d)(4)) and currently includes
depletion in any part of its historic ab-
sorption ratio must revise its previous and
current historic absorption ratios . To re-
vise its historic absorption ratios, the tax-
payer must apply its proposed method of
accounting during the test period, during
all recomputation years, and during all up-
dated test periods to determine the § 471
costs and additional § 263A costs that
were incurred . The revised historic ab-
sorption ratios must be used to revalue be-
ginning inventory and must be accounted
for in the taxpayer’s § 481(a) adjustment .
The taxpayer must use a method described
in § 1 .263A-7(c) to revalue beginning in-
ventory
(3) Certain eligibility rule inapplica-
ble. The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(4) Concurrent automatic changes . A
taxpayer making both this change and an-
other automatic change under § 263A for
the same year of change may file a single
Form 3115 for both changes, provided the
taxpayer enters the designated automat-
ic change numbers for both changes on
the appropriate line on that Form 3115
and complies with the ordering rules of
§ 1 .263A–7(b)(2) . See section 6 .03(1)(b)
of Rev . Proc . 2015-13 for information on
making concurrent changes .
(5) Designated automatic accounting
method change number. The designat-
ed automatic accounting method change
number for a change in method of ac-
counting under this section 12 .13 is “215 .”
(6) Contact information. For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.14 Interest capitalization .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for interest from
not capitalizing any interest, capitalizing
interest in accordance with its method of
accounting for financial reporting purpos-
es, or applying an improper method of
capitalizing interest under §§ 1 .263A-8
through 14, with respect to the produc-
tion of designated property, to capitalizing
interest with respect to the production of
designated property in accordance with §§
1 .263A-8 through 14 .
(2) Manner of making change . A tax-
payer requesting a change under this sec-
tion 12 .14 must attach a statement to the
Form 3115 with the following informa-
tion:
(a) Representations as to the following:
(i) The taxpayer’s method is in accor-
dance with the avoided cost method under
§ 1 .263A-9; and
(ii) The taxpayer will comply with §
1 .263A-14 and Notice 88-89, 1988-2 C .B .
422, should the taxpayer incur average
excess expenditures allocable to related
persons; and
(b) Details with respect to the taxpay-
er’s sub-methods of accounting for de-
termining capitalizable interest in accor-
dance with §§ 1 .263A-8 through 14 (for
example, whether the taxpayer elects to
not trace debt under § 1 .263A-9(d); the
computation period(s) used under the new
method; and whether the taxpayer will
suspend the capitalization of interest for
units of property for which production has
ceased for at least 120 consecutive days as
determined under § 1 .263A-12(g)) .
(3) Concurrent automatic changes .
A taxpayer making a change under this
section 12 .14 and one or more automatic
changes in method of accounting under §
263A for the same year of change may file
a single Form 3115 for all changes, pro-
vided the taxpayer enters the designated
automatic change numbers for all changes
on the appropriate line on the Form 3115
and complies with the ordering rules of
§ 1 .263A-7(b)(2) . See section 6 .03(1)(b)
of Rev . Proc . 2015-13 for information on
making concurrent changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change in method of ac-
counting under this section 12 .14 is “224 .”
(5) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.15 Change to not apply § 263A to re-
planting costs for lost or damaged citrus
plants pursuant to § 263A(d)(2)(C) .
(1) Description of change .
(a) In general . This change, as de-
scribed in Rev . Proc . 2018-35, 2018-28
I .R .B . 204, applies to a taxpayer, other
than the owner described in § 263A(d)(2)
(A), that: (i) paid or incurred replanting
costs of citrus plants after the loss or dam-
age of citrus plants by reason of freezing
temperatures, disease, drought, pests, or
casualty, as described in § 263A(d)(2)(A);
(ii) paid or incurred the replanting costs
after December 22, 2017, and on or before
December 22, 2027; (iii) satisfies the own-
ership test provided in section 12 .15(1)(b)
of this revenue procedure; and (iv) wants
to change its method of accounting from
applying § 263A to citrus plant replant-
ing costs to not applying § 263A to those
costs, pursuant to § 263A(d)(2)(C) .
(b) Ownership test . The taxpayer sat-
isfies the ownership test if either: (i) the
owner described in § 263A(d)(2)(A) has
an equity interest of not less than 50 per-
cent in the replanted citrus plants at all
times during the taxable year in which the
taxpayer paid or incurred amounts for re-
planting costs, and the taxpayer holds any
part of the remaining equity interest; or
(ii) the taxpayer acquired the entirety of
the equity interest of the owner described
in § 263A(d)(2)(A) in the land on which
the lost or damaged citrus plants were lo-
cated at the time of the loss or damage,
and the replanting is on such land .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .

Bulletin No. 2019–48 1161 November 25, 2019
(3) Section 481(a) adjustment . A tax-
payer making a change under this section
12 .15 calculates a § 481(a) adjustment by
taking into account only amounts paid or
incurred after December 22, 2017, and on
or before December 22, 2027 .
(4) Multiple changes . A taxpayer mak-
ing both this change and another change
in method of accounting in the same year
of change must comply with the ordering
rules of § 1 .263A-7(b)(2) .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .15 is “232 .”
(6) Contact information . For further
information regarding a change under this
section, contact Megan McLaughlin at
(202) 317-7007 (not a toll-free number) .
.16 Small business taxpayer exception
from requirement to capitalize costs under
§ 263A .
(1) Description of change . This change
applies to a small business taxpayer, as de-
fined in section 15.18(5)(a) of this revenue
procedure, that capitalizes costs under §
263A and wants to change to a method of
accounting that no longer capitalizes costs
under § 263A, including to self-construct-
ed assets, pursuant to § 263A(i) .
(2) Applicability . This change is effec-
tive for taxable years beginning after De-
cember 31, 2017 .
(3) Inapplicability . This change does
not apply to a small business taxpayer, as
defined in section 15.18(5)(a) of this rev-
enue procedure, that chooses to no longer
capitalize costs under § 263A for home
construction contracts, as defined in §
460(e)(1)(A) (but see section 19 .01 of this
revenue procedure) .
(4) Certain eligibility rule temporar-
ily inapplicable . The eligibility rule in
section 5 .01(1)(f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, does not apply to this
change for the taxpayer’s first, second, or
third taxable year beginning after Decem-
ber 31, 2017 .
(5) Reduced filing requirement . A tax-
payer is required to complete only the fol-
lowing information on Form 3115 (Rev .
December 2018) to make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except line 16; and
(e) Part IV, all lines except line 25 .
(6) Concurrent automatic changes . A
taxpayer making a change under this sec-
tion 12 .16 and a change under sections
15 .18 and/or 22 .19 of this revenue pro-
cedure for the same year of change may
file a single Form 3115 for all changes,
provided the taxpayer enters the designat-
ed automatic accounting method change
numbers for the changes on the appropri-
ate line of Form 3115 . See section 6 .03(1)
(b) of Rev . Proc . 2015-13 for information
on making concurrent changes .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .16 is “234 .”
(8) Contact information . For further
information regarding a change under this
section, contact Anna Gleysteen at (202)
317-7007 (not a toll-free number) .
.17 Recharacterizing costs under the
simplified resale method, simplified pro-
duction method, or the modified simplified
production method .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that uses or is changing to
the simplified production method, the
modified simplified production meth-
od, or the simplified resale method un-
der §§ 1 .263A-2(b), 1 .263A-2(c), and
1 .263A-3(d), respectively, and that wants
to recharacterize a section 471 cost, as
defined in § 1.263A-1(d)(2), as an addi-
tional section 263A cost, as defined in §
1 .263A-1(d)(3), or vice versa, in accor-
dance with the characterization require-
ments of § 1 .263A-1(d)(2) and (d)(3) . For
example, this change applies to a taxpayer
using the modified simplified production
method that treats a direct cost of property
produced or property acquired for resale
as an additional section 263A cost and that
wants to change to characterize the direct
cost as a section 471 cost, as required by §
1 .263A-1(d)(2)(ii) .
(b) Inapplicability . This change does
not apply to a change in method of account-
ing that is described in another section of
this revenue procedure or in other guid-
ance published in the IRB . For example,
this change does not apply to a taxpayer
that wants to make a change described in
section 12 .01 or 12 .02 of this revenue pro-
cedure, such as a change to use the meth-
ods described in § 1 .263A-1(d)(2)(iv), (v),
or (vi), § 1 .263A-2(b), § 1 .263A-2(c), or §
1 .263A-3(d) .
(2) Restatement of financial statement .
A taxpayer’s restatement of its financial
statement does not invalidate the taxpay-
er’s method of accounting or change its
determination of section 471 costs in ear-
lier taxable years .
(3) Certain eligibility rule temporar-
ily inapplicable . The eligibility rule in
section 5 .01(1)(f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, does not apply to this
change for the taxpayer’s first, second, or
third taxable year ending on or after No-
vember 20, 2018 .
(4) Reduced filing requirement . A tax-
payer is required to complete only the fol-
lowing information on Form 3115 (Rev .
December 2018) to make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except lines 13,
15b, 16c, and 19;
(e) Part IV, all lines except line 25; and
(f) Schedule D, all Parts except Part I .
(5) Limitation . If a taxpayer making
this change in method of accounting uses
a historic absorption ratio election under
§§ 1 .263A-2(b)(4), 1 .263A-2(c)(4), or
1 .263A-3(d)(4)), and the change in the
characterization of cost(s) under this sec-
tion 12 .17 affects any part of the taxpay-
er’s historic absorption ratio, the taxpayer
must revise its previous and current his-
toric absorption ratios . To revise its his-
toric absorption ratios, the taxpayer must
apply its proposed method of accounting
during the test period, during all recom-
putation years, and during all updated test
periods to determine the section 471 costs
and additional section 263A costs that
were incurred . The revised historic ab-
sorption ratios must be used to revalue be-
ginning inventory and must be accounted
for in the taxpayer’s § 481(a) adjustment .
The taxpayer must use a method described
in § 1 .263A-7(c) to revalue beginning in-
ventory .
(6) Concurrent automatic changes . A
taxpayer making both this change and an-
other automatic change under § 263A for

November 25, 2019 1162 Bulletin No. 2019–48
the same year of change may file a single
Form 3115 for both changes, provided the
taxpayer enters the designated automat-
ic change numbers for both changes on
the appropriate line of that Form 3115
and complies with the ordering rules of
§ 1 .263A-7(b)(2) . See section 6 .03(1)(b)
of Rev . Proc . 2015-13 for information on
making concurrent changes .
(7) Under examination – certain audit
protection exception temporarily inappli-
cable. For a taxpayer’s first, second, or
third taxable year ending on or after No-
vember 20, 2018, the audit protection rule
in section 8 .02(1) of Rev . Proc . 2015-13
does not apply to a change in method of
accounting made under this section 12 .17 .
However, section 8 .02(1) of Rev . Proc .
2015-13 continues to apply for purposes
of determining the § 481(a) adjustment
period for a positive § 481(a) adjustment
provided in section 7 .03(3)(b) of Rev .
Proc . 2015-13 .
(8) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .17 is “237 .”
(9) Contact information . For further
information regarding a change under this
section, contact Evan Hewitt at (202) 317-
7007 (not a toll-free number) .
.18 Revocation of a historic absorption
ratio election .
(1) Description of change . This
change applies to a taxpayer that uses the
simplified resale method with a historic
absorption ratio election that wants to
revoke its historic absorption ratio elec-
tion and change to the simplified resale
method without a historic absorption
ratio . This change also applies to a tax-
payer that uses the simplified production
method with a historic absorption ratio
election that wants to revoke its historic
absorption ratio election and change to
the simplified production method without
a historic absorption ratio . This change
applies to a revocation of the simplified
resale method with a historic absorption
ratio election or the simplified production
method with a historic absorption ratio
election regardless of whether the year of
change is during the taxpayer’s qualify-
ing period .
(2) Limited applicability . This change
is the exclusive procedure for a taxpayer
on the simplified production method with
a historic absorption ratio election or the
simplified resale method with a historic
absorption ratio election that wants to re-
voke its historic absorption election under
the transition rules of §§ 1 .263A-2(b)(4)
(v)(B) and 1 .263A-3(d)(4)(v)(B) . This
change is applicable only for the taxpay-
er’s first, second, or third taxable year
ending on or after November 20, 2018 .
A taxpayer that complies with the re-
quirements of this section 12 .18 will be
deemed to have obtained the consent of
the Commissioner to make a revocation of
its historic absorption ratio election under
§ 446(e) .
(3) Certain eligibility rule temporar-
ily inapplicable . The eligibility rule in
section 5 .01(1)(f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, does not apply to this
change for the taxpayer’s first, second or
third taxable year ending on or after No-
vember 20, 2018 .
(4) Manner of making change .
(a) Cut-off basis . This change is made
on a cut-off basis . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired .
(b) Audit protection .
(i) No audit protection . A taxpayer does
not receive audit protection under section
8 .01 of Rev . Proc . 2015-13 in connection
with this change if the taxpayer’s revoca-
tion of a historic absorption ratio election
is during a qualifying period or extended
qualifying period . See section 8 .02(2) of
Rev . Proc . 2015-13 .
(ii) Under examination – certain audit
protection exception temporarily inappli-
cable. For a taxpayer’s first, second, or
third taxable year ending on or after No-
vember 20, 2018, the audit protection rule
in section 8 .02(1) of Rev . Proc . 2015-13
does not apply to a taxpayer’s revocation
of its historic absorption ratio election as
described in this section 12 .18 if such re-
vocation is not during a qualifying period
or extended qualifying period . However,
section 8 .02(1) of Rev . Proc . 2015-13 con-
tinues to apply for purposes of determin-
ing the § 481(a) adjustment period for a
positive § 481(a) adjustment provided in
section 7 .03(3)(b) of Rev . Proc . 2015-13 .
(5) Concurrent automatic changes . A
taxpayer making both this change and an-
other automatic change under § 263A for
the same year of change may file a single
Form 3115 for both changes, provided the
taxpayer enters the designated automat-
ic change numbers for both changes on
the appropriate line of that Form 3115
and complies with the ordering rules of
§ 1 .263A-7(b)(2) . See section 6 .03(1)(b)
of Rev . Proc . 2015-13 for information on
making concurrent changes .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
12 .18 is “238 .”
(7) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
SECTION 13 . LOSSES, EXPENSES
AND INTEREST WITH RESPECT
TO TRANSACTIONS BETWEEN
RELATED TAXPAYERS (§ 267)
.01 Change to comply with § 267 .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method or methods of accounting to
comply with the requirements of § 267,
which disallows or defers certain deduc-
tions attributable to transactions between
related taxpayers . However, this change
does not apply to a change for original
issue discount (OID), including stated in-
terest that is OID because it is not quali-
fied stated interest (as defined in § 1.1273-
1(c)) . See section 5 .02 of this revenue
procedure for a change to comply with
§ 163(e)(3) for OID on an obligation held
by a related foreign person .
(2) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(e) and (f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, do not apply to this
change to comply with § 267(a)(3) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
13 .01 is “26 .”
(4) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) . For further
information regarding a change to comply
with § 267(a)(3), contact Michael Kaerch-
er at (202) 317-6934 (not a toll-free num-
ber) .

Bulletin No. 2019–48 1163 November 25, 2019
SECTION 14 . DEFERRED
COMPENSATION (§ 404)
.01 Deferred compensation .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that wants to
change its method of accounting to treat
bonuses or vacation pay as follows (see
§ 404(a)(5) and § 1 .404(b)-1T, Q&A 2):
(a) Applicability .
(i) Bonuses .
(A) Bonuses not subject to capitaliza-
tion under § 263A . If by the end of the tax-
able year all the events have occurred that
establish the fact of the liability to pay a
bonus and the amount of the liability can
be determined with reasonable accuracy
(see § 1 .446-1(c)(1)(ii)), and the bonus is
otherwise deductible, but the bonus is re-
ceived by the employee after the 15
th
day
of the 3
rd
calendar month after the end of
that taxable year, to treat the bonus as de-
ductible in the taxable year of the employ-
er in which or with which ends the taxable
year of the employee in which the bonus is
includible in the gross income of the em-
ployee; or
(B) Bonuses that are subject to capital-
ization under § 263A . If by the end of the
taxable year all the events have occurred
that establish the fact of the liability to pay
a bonus and the amount of the liability can
be determined with reasonable accuracy
(see § 1 .446-1(c)(1)(ii)), and the bonus
is otherwise deductible (without regard
to § 263A), but the bonus is received by
the employee after the 15
th
day of the 3
rd

calendar month after the end of that tax-
able year, to treat the bonus as capitaliz-
able (within the meaning of § 1 .263A-1(c)
(3)) in the taxable year of the employer
in which or with which ends the taxable
year of the employee in which the bonus
is includible in the gross income of the
employee .
(ii) Vacation pay .
(A) Vacation pay not subject to capital-
ization under § 263A . If by the end of the
taxable year all the events have occurred
that establish the fact of the liability to
pay vacation pay and the amount of the li-
ability can be determined with reasonable
accuracy (see § 1 .446-1(c)(1)(ii)), and the
vacation pay is otherwise deductible but
the vacation pay is received by the em-
ployee after the 15
th
day of the 3
rd
calendar
month after the end of that taxable year, to
treat the vacation pay as deductible in the
taxable year of the employer in which the
vacation pay is paid to the employee; or
(B) Vacation pay that is subject to cap-
italization under § 263A . If by the end of
the taxable year all the events have oc-
curred that establish the fact of the liabil-
ity to pay vacation pay and the amount of
the liability can be determined with rea-
sonable accuracy (see § 1 .446-1(c)(1)(ii)),
and the vacation pay is otherwise deduct-
ible (without regard to § 263A), but the
vacation pay is received by the employee
after the 15
th
day of the 3
rd
calendar month
after the end of that taxable year, to treat
the vacation pay as capitalizable (within
the meaning of § 1 .263A-1(c)(3)) in the
taxable year of the employer in which the
vacation pay is paid to the employee .
(b) Inapplicability . This change does
not apply to a taxpayer that is required
under § 263A and the regulations there-
under to capitalize the costs with respect
to which the taxpayer wants to change its
method of accounting under this section
14 .01 if the taxpayer is not capitalizing
these costs, unless the taxpayer concur-
rently changes its method to capitalize
these costs in conjunction with a change
to a UNICAP method under section 12 .01,
12 .02, 12 .08, or 12 .12 of this revenue pro-
cedure (as applicable) .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
14 .01 is “28 .”
(3) Contact information . For further
information regarding a change under this
section, contact Thomas Scholz at (202)
317-5600 (not a toll-free number) .
.02 Grace period contributions .
(1) Description of change . This change
applies to a taxpayer that wants to cease
deducting contributions made during the
§ 404(a)(6) grace period to a qualified
cash or deferred arrangement within the
meaning of § 401(k) or to a defined con-
tribution plan as matching contributions
with the meaning of § 401(m) when the
contributions are attributable to compen-
sation earned by plan participants after the
end of a taxable year as required by Rev .
Rul . 2002-46, 2002-2 C .B . 117, as mod-
ified by Rev. Rul. 2002-73, 2002-2 C.B.
805 .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
14 .02 is “29 .”
(3) Contact information . For further
information regarding a change under this
section, contact John Ricotta at 202-317-
4102 or Joyce Kahn at 202-317-4148 (not
toll-free number) .
SECTION 15 . METHODS OF
ACCOUNTING (§ 446)
.01 Change in overall method from the
cash method to an accrual method .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to change its over-
all method of accounting from the cash
receipts and disbursements method (cash
method) (as defined in section 15.01(2)(a)
of this revenue procedure) to an accrual
method (as defined in section 15.01(2)(b)
of this revenue procedure) . A change under
this section 15 .01 applies to (1) a taxpayer
required to make this change by § 448, any
other section of the Code or regulations, or
in other guidance published in the Internal
Revenue Bulletin (IRB), as well as (2) a
taxpayer that wants to make this change
but is not required to do so by § 448, any
other section of the Code or regulations,
or in other guidance published in the IRB .
A taxpayer changing to an overall accrual
method because it is prohibited from using
the overall cash method under § 448 may
use this section 15 .01 regardless of wheth-
er the year of change is the first taxable
year that the taxpayer is required by § 448
to change from the cash method (“the first
§ 448 year”), or is a taxable year other than
the taxpayer’s first § 448 year.
Additionally, a taxpayer qualifies to
change its overall method of accounting
from the cash method to an accrual meth-
od using this section 15 .01 even if the tax-
payer is also making one or more of the
following changes in method of account-
ing for the same year of change:
(i) adopting the recurring item excep-
tion (as defined in section 15.01(2)(c) of
this revenue procedure) for one or more
types of recurring items (see § 1 .461-
5(d));
(ii) adopting or changing to a permissi-
ble inventory method of accounting and is

November 25, 2019 1164 Bulletin No. 2019–48
either adopting this inventory method or
qualifies to change to this inventory meth-
od using the automatic change procedures
of Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
and a section of this revenue procedure,
or the change can be made automatically
under any section of the Code or regula-
tions, or other guidance published in the
IRB (see Rev . Rul . 90-38, 1990-1 C .B . 57
(regarding when a taxpayer may adopt a
method of accounting));
(iii) adopting or changing to a permis-
sible § 263A method of accounting and
is either adopting this § 263A method or
qualifies to change to this § 263A method
using the automatic change procedures of
Rev . Proc . 2015-13 and a section of this
revenue procedure, or the change can be
made automatically under any section of
the Code or regulations, or other guidance
published in the IRB (see Rev . Rul . 90-38
(regarding when a taxpayer may adopt a
method of accounting)); or
(iv) adopting or changing to any other
special method of accounting (as defined
in section 15 .01(2)(d) of this revenue
procedure) and is either adopting this
special method or qualifies to change to
this special method using the automatic
change procedures of Rev . Proc . 2015-13
and a section of this revenue procedure,
or the change can be made automatically
under any section of the Code or regu-
lations, or other guidance published in
the IRB (see Rev . Rul . 90-38 (regarding
when a taxpayer may adopt a method of
accounting));
Also, a taxpayer qualifies to use this
section 15 .01 when that taxpayer, in the
taxable year immediately preceding the
year of change, has used a permissible in-
ventory method for that year, and, if that
taxpayer was subject to § 263A for that
year, has also used a permissible § 263A
method for that year, and the method(s)
continue to be used for the year of change .
Lastly, a taxpayer with an applicable fi-
nancial statement (AFS) qualifies to use this
section 15 .01 for a taxable year beginning
after December 31, 2017, to comply with §
451(b)(1)(A), and, if applicable, § 451(b)
(4) . However, a taxpayer that wants to make
a change for the recognition of income for
federal income tax purposes to a method
under the New Standards, as defined in sec-
tion 16 .11(1) of this revenue procedure, for
allocating transaction price to performance
obligations for the same year of change
must use section 16 .11 of this revenue pro-
cedure to make the change for purposes of
complying with § 451(b)(4) .
(b) Inapplicability . This change does
not apply to:
(i) a taxpayer that is making a change
from a hybrid method of accounting (as
defined in section 15.01(2)(e) of this reve-
nue procedure);
(ii) a taxpayer that is changing its meth-
od of accounting for one or more items
of income or expense, but not its overall
method of accounting . See section 15 .09
of this revenue procedure for a descrip-
tion of accounting method changes from
the cash method to an accrual method for
specific items that are to be made using
the automatic change procedures of Rev .
Proc . 2015-13 and that section 15 .09;
(iii) a taxpayer that is required by the
Code, regulations, or other guidance pub-
lished in the IRB to use a special meth-
od (for example, an inventory method, a
§ 263A method, or a long-term contract
method) in the year of change and fails to
adopt or change to that method;
(iv) a taxpayer that has included in its §
481(a) adjustment any amount of deferred
compensation that is described under §
457A(d)(3) that is attributable to services
performed before January 1, 2009;
(v) a taxpayer that is engaged in two
or more trades or businesses, unless that
taxpayer makes this change for each trade
or business so that the identical accrual
method is used for each trade or business
beginning with the year of change;
(vi) a taxpayer that is required by § 447
to change to an accrual method when the
year of change is the first taxable year that
taxpayer is required by § 447 to change to
that method;
(vii) a cooperative organization de-
scribed in §§ 501(c)(12), 521, or 1381;
(viii) an individual taxpayer, except for
activities conducted as a sole proprietor-
ship; or
(ix) a taxpayer with an AFS that wants
to make a change for the recognition of
income for federal income tax purposes
to a method under the New Standards, as
defined in section 16.11(1) of this revenue
procedure, for allocating transaction price
to performance obligations for the same
year of change that it wants to change to
an accrual method .
(2) Definitions .
(a) Cash method of accounting is the
method identified by § 446(c)(1) and
§§ 1 .446-1(c)(1)(i), 1 .451-1(a), and
1 .461-1(a)(1) . For purposes of this section
15 .01, the cash method also includes the
overall cash method with inventoriable
items treated as either inventory or as
non-incidental materials and supplies un-
der § 1 .162-3 as permitted by Rev . Proc .
2001-10, 2001-1 C.B. 272, as modified by
Rev . Proc . 2011-14, 2011-4 I .R .B . 330, or
Rev . Proc . 2002-28, 2002-1 C .B . 815, as
modified by Rev. Proc. 2011-14.
(b) Accrual method of accounting is a
method identified by § 446(c)(2) and §§
1 .446-1(c)(1)(ii), 1 .451-1(a), and 1 .461-
1(a)(2) . For a taxable year beginning after
December 31, 2017, a taxpayer with an
AFS treats the all events test with respect
to an item of income, or portion of an item
of income, as met no later than when the
item, or portion of that item, is taken into
account as revenue in its AFS .
(c) Recurring item exception is the
method described in § 461(h)(3) and
§ 1 .461-5 .
(d) Special method of accounting with-
in the meaning of this section 15 .01 is a
method of accounting, other than the cash
method, expressly permitted or required
by the Code, regulations, or in other guid-
ance published in the IRB that deviates
from the tax accrual accounting rules of
§§ 446, 451 and 461 and the regulations
thereunder . For example, the installment
method of accounting under § 453, the
mark-to-market method under § 475, a
long-term contract method, and the defer-
ral method of Rev . Proc . 2004-34, 2004-
1 C.B. 991, as clarified and modified by
Rev . Proc . 2011-18, 2011-5 I .R .B . 443,
and Rev . Proc . 2013-29, 2013-33 I .R .B .
141, and as modified by Rev. Proc. 2011-
14, are special methods of accounting . In
contrast, application of the all-events test
under a specific set of facts is not a special
method of accounting . See, for example,
Rev . Rul . 69-314, 1969-1 C .B . 139 (con-
cerning the treatment of retainages) .
(e) Hybrid method of accounting is
a combination of the cash and accrual
methods under which one or more items
of income or expense are reported on the
cash method and one or more items of
income or expense are reported on an ac-
crual method . For purposes of this section

Bulletin No. 2019–48 1165 November 25, 2019
15 .01, a hybrid method of accounting in-
cludes, for example, a taxpayer that uses
an accrual method with respect to pur-
chases and sales of inventories and uses
the cash method in computing all other
items of income and expense .
(3) Manner of making change .
(a) Section 481(a) adjustment .
(i) In general . A taxpayer changing its
method of accounting under this section
15 .01 must compute a § 481(a) adjust-
ment. This adjustment must reflect the
account receivables, account payables,
inventory, and any other item determined
to be necessary in order to prevent items
from being duplicated or omitted . How-
ever, the adjustment does not include any
item of income accrued but not received
that was worthless or partially worthless
(within the meaning of § 166(a)) on the
last day of the year immediately prior to
the year of change .
(ii) Temporary rule for certain S cor-
poration revocations . The rules in this
section 15 .01(3)(a)(ii) apply to an eligi-
ble terminated S corporation, as defined
in § 481(d)(2), that changes to an overall
accrual method of accounting in the C
corporation’s first taxable year after its
revocation of its election under § 1362(a),
and such revocation occurs during the
two-year period beginning on December
22, 2017 .
(A) Required spread period . Pursuant
to § 481(d)(1), an eligible terminated S
corporation required to change to an over-
all accrual method as a result of a revo-
cation of its S corporation election that
changes its method of accounting under
this section 15 .01 in the C corporation’s
first taxable year after such revocation,
takes into account the resulting positive or
negative adjustment required by § 481(a)
(2) ratably during the six-year period be-
ginning with the year of change .
(B) Optional six-year spread period .
An eligible terminated S corporation that
is permitted to continue to use the over-
all cash method after the revocation of its
S corporation election, and that changes
to an overall accrual method under this
section 15.01 in the C corporation’s first
taxable year after such revocation, may
take into account the resulting positive or
negative adjustment required by § 481(a)
(2) ratably during the six-year period be-
ginning with the year of change instead
of using the adjustment periods provided
in section 7 .03(1) of Rev . Proc . 2015-13 .
An eligible terminated S corporation that
wants to use this six-year spread period
must indicate in the statement required
by Line 26 of Form 3115 (Rev . Decem-
ber 2018) that it is making the change in
method of accounting with the spread pe-
riod permitted under this section 15 .01(3)
(a)(ii)(B) on its timely filed Form 3115.
(b) Certain eligibility rules inapplica-
ble .
(i) Prior change eligibility rule inap-
plicable . Any prior change to the overall
cash method that the taxpayer imple-
mented using the provisions of Rev . Proc .
2001-10, as modified by Rev. Proc. 2011-
14, or Rev. Proc. 2002-28, as modified by
Rev . Proc . 2011-14, is disregarded for pur-
poses of section 5 .01(1)(e) of Rev . Proc .
2015-13 .
(ii) Certain eligibility rule temporarily
inapplicable . For a taxpayer with an AFS
that changes to an overall accrual method
that complies with § 451(b)(1)(A), and,
if applicable, § 451(b)(4) under this sec-
tion 15 .01, the eligibility rule in section
5 .01(1)(e) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, does not apply to this change
for the taxpayer’s first, second, or third
taxable year ending beginning after De-
cember 31, 2017 .
(c) Adoption of recurring item excep-
tion . The taxpayer must attach to its Form
3115 a statement describing the types of
liabilities for which the recurring item ex-
ception will be used .
(d) Concurrent automatic change to a
special method .
(i) Generally only one Form 3115 re-
quired . Except as provided in section
15 .01(3)(d)(ii) of this revenue procedure,
a taxpayer that is changing from the over-
all cash method to an overall accrual meth-
od under this section 15 .01 and changing
to a special method, as permitted under
section 15 .01(1)(a)(ii), (iii), or (iv) of this
revenue procedure, must timely file a sin-
gle Form 3115 for both changes and must
enter the designated automatic accounting
method change numbers for both changes
on the appropriate line of that Form 3115 .
For example, a taxpayer making both a
change from the overall cash method to an
overall accrual method under this section
15 .01 and an automatic change to the de-
ferral method for advance payments under
Rev . Proc . 2004-34 (see section 16 .07 of
this revenue procedure) must timely file
a single Form 3115 for both changes and
enter the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes .
(ii) Two Forms 3115 required when a
concurrent change is being implemented
under section 32.01 of this revenue pro-
cedure for short-term obligations . When a
taxpayer subject to § 1281 is changing its
method of accounting for interest income
on short-term obligations as part of the
change to an overall accrual method un-
der this section 15 .01, that taxpayer must
request the change for the interest income
under section 32 .01 of this revenue pro-
cedure. The taxpayer must timely file
individual Forms 3115 for each change
requested . This section 15 .01 will govern
the change to an overall accrual method .
(e) Concurrent change in accounting
method not permitted to be implemented
using the automatic change procedures
of Rev. Proc. 2015-13 and a section of
this revenue procedure, any section of
the Code or regulations, or other guid-
ance published in the IRB . A taxpayer
that does not qualify to change from the
overall cash method to an overall accrual
method under this section 15 .01 because
that taxpayer is concurrently changing to
a method of accounting that may not be
implemented using the automatic change
procedures of Rev . Proc . 2015-13 and a
section of this revenue procedure, any sec-
tion of the Code or regulations, or other
guidance published in the IRB, must time-
ly request both changes using the non-au-
tomatic change procedures in Rev . Proc .
2015-13 . See Rev . Proc . 2019-1, 2019-1
I .R .B . 1 (or successor), for more informa-
tion on whether one Form 3115 is required
to implement the changes, and for infor-
mation on the appropriate user fee .
(f) Concurrent automatic changes for a
taxpayer with an AFS that complies with
§ 451(b) . A taxpayer with an AFS that
changes to an overall accrual method that
complies with § 451(b)(1)(A) under this
section 15 .01 that also wants to make a
change under this section 15 .01 to comply
with § 451(b)(4) must file a single Form
3115 . The taxpayer must separately state

November 25, 2019 1166 Bulletin No. 2019–48
the § 481(a) adjustment for each change
and may not net these § 481(a) adjust-
ments . A taxpayer must make the change
for § 451(b)(4) before making the change
for § 451(b)(1)(A) . See section 6 .03(1)(b)
of Rev . Proc . 2015-13 for information on
making concurrent changes .
(g) Concurrent change in the timing
of recognition of income due to the New
Standards . A taxpayer that wants to make
a change under this section 15 .01 and a
change under section 16 .11 of this reve-
nue procedure for the same year of change
must file a single Form 3115 for both
changes and enter the designated auto-
matic accounting method change number
for both changes on the appropriate line
of Form 3115 . A taxpayer that makes both
changes is required to make the change
under section 16 .11 of this revenue proce-
dure before making the change under this
section 15 .01 .
(4) Change made in the first § 448 year.
(a) In general . If the year of change is
the first § 448 year for a taxpayer and such
taxpayer qualifies to make the change
from the cash method under the provisions
of §§ 1 .448-1(g) and (h) as well as this
section 15 .01, the taxpayer may choose to
make the change using this section 15 .01 .
However, the taxpayer must still comply
with the requirements and provisions of
§§ 1 .448-1(g) and (h) in addition to the
requirements and provisions of this sec-
tion 15 .01 . For example, if the taxpayer
is a hospital, defined in § 1.448-1(g)(2)(ii)
(B), and the taxpayer chooses to make its
change from the cash method for the first
§ 448 year using this section 15 .01, the ap-
plicable § 481(a) adjustment period is pro-
vided by § 1 .448-1(g)(2)(ii) . If a taxpayer
chooses not to implement its change from
the cash method using this section 15 .01,
the taxpayer must make the change under
the provisions of §§ 1 .448-1(g) and (h) .
(b) Certain eligibility rules inapplica-
ble .
(i) Prior change eligibility rule inap-
plicable . For a taxpayer making a change
from the cash method in the first § 448
year, any prior change to the overall cash
method is disregarded for purposes of sec-
tion 5 .01(1)(e) of Rev . Proc . 2015-13 .
(ii) Certain eligibility rule temporarily
inapplicable . For a taxpayer with an AFS
that changes to an overall accrual method
that complies with § 451(b)(1)(A), and, if
applicable, § 451(b)(4) under this section,
the eligibility rule in section 5 .01(1)(e) of
Rev . Proc . 2015-13 does not apply to this
change for the taxpayer’s first, second, or
third taxable year beginning after Decem-
ber 31, 2017 .
(5) No ruling on method used . The
consent granted under section 9 of Rev .
Proc . 2015-13 for a change made under
this section 15 .01 is not a determination
by the Commissioner that the new meth-
od of accounting is a permissible method
of accounting under § 451 and does not
create a presumption that the allocation
method used under § 451(b)(4) is a per-
missible method of accounting . The direc-
tor may ascertain whether the new method
of accounting is a permissible method of
accounting under § 451 and whether the
allocation method is permissible under §
451(b)(4) . This section 15 .01(5) does not
apply to a taxpayer with an AFS that is
making a change to comply with the pro-
posed regulations under § 1 .451-3 .
(6) Designated automatic accounting
method change number .
(a) Change made in the first § 448 year .
The designated automatic accounting
method change number for a change from
the cash method in the first § 448 year is
“123 .” Entering designated automatic ac-
counting method change number “123”
on the appropriate line on the Form 3115
fulfills the requirement of § 1.448-1(h)(2)
(i) to type or print “Automatic Change to
Accrual Method – Section 448” at the top
of page 1 of the Form 3115 .
(b) All other changes from the cash
method to an overall accrual method . The
designated automatic accounting method
change number for all other changes from
the cash method under this section 15 .01
is “122 .”
(7) Contact information . For further
information regarding a change under this
section, contact Evan Hewitt at (202) 317-
7007 (not a toll-free number) .
.02 Multi-year insurance policies for
multi-year service warranty contracts .
(1) Description of change .
(a) Applicability . This change applies to
a manufacturer, wholesaler, or retailer of
motor vehicles or other durable consumer
goods that wants to change its method of
accounting for insurance costs paid or in-
curred to insure its risks under multi-year
service warranty contracts to the method
described in section 15 .02(2) of this reve-
nue procedure . Multi-year service warran-
ty contracts to which this change applies
include only those separately priced con-
tracts sold by a manufacturer, wholesaler,
or retailer also selling the motor vehicles
or other durable consumer goods underly-
ing the contracts (to the ultimate customer
or to an intermediary). The classification
of goods as “durable consumer goods” for
purposes of this change depends on the
common usage of the goods, rather than
the purchaser’s actual intended use of the
goods .
(b) Inapplicability . This change does
not apply to a taxpayer that covers its risks
under its multi-year service warranty con-
tracts through arrangements not constitut-
ing insurance .
(2) Description of method . If a tax-
payer purchases a multi-year service
warranty insurance policy (in connection
with its sale of multi-year service war-
ranty contracts to customers) by paying a
lump-sum premium in advance, the tax-
payer must capitalize the amount paid or
incurred and may only obtain deductions
for that amount by prorating (or amortiz-
ing) it over the life of the insurance policy
(whether the cash method or an accrual
method of accounting is used to account
for service warranty transactions) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .02 is “31 .”
(4) Contact information . For further
information regarding a change under this
section, contact Adam Kobler at (202)
317-7011 (not a toll-free number) .
.03 Taxpayers changing to overall cash
method .
(1) Description of change .
(a) Applicability . This change applies
to either:
(i) a “qualifying taxpayer” that quali-
fies to make the change to the overall cash
receipts and disbursements (cash) method
under Rev . Proc . 2001-10, 2001-1 C .B .
272, (other than a taxpayer described in
§ 448(a)(3) or a bank described in section
14 .12(2)(a) of this revenue procedure)
with “average annual gross receipts” (as
defined in section 5.01 of Rev. Proc. 2001-
10) of $1,000,000 or less that wants to
change to the overall cash method of ac-

Bulletin No. 2019–48 1167 November 25, 2019
counting as provided in Rev . Proc . 2001-
10, as modified by Announcement 2004-
16, 2004-1 C .B . 668 (regarding placement
of § 481(a) adjustment on the Form 3115),
and Rev . Proc . 2011-14, 2011-4 I .R .B .
330 (removing § 6 .02(1)(a) of Rev . Proc .
2001-10); or
(ii) a “qualifying small business tax-
payer” that qualifies to make a change
to the overall cash receipts and disburse-
ments (cash) method under Rev . Proc .
2002-28, 2002-1 C .B . 815, (other than a
taxpayer prohibited from using the cash
method under § 448 or a bank described
in section 15 .12(2)(a) of this revenue pro-
cedure) with “average annual gross re-
ceipts” (as defined in section 5.02 of Rev.
Proc . 2002-28) of $10,000,000 or less that
wants to change the overall method of
accounting for an “eligible trade or busi-
ness” (as defined in section 4.01 of Rev.
Proc . 2002-28) to the overall cash method
of accounting as provided in Rev . Proc .
2002-28, as modified by Announcement
2004-16 (regarding placement of § 481(a)
adjustment on the Form 3115), and Rev .
Proc . 2011-14 (removing § 7 .02(1)(a) of
Rev . Proc . 2002-28) .
(b) Inapplicability . This change does
not apply for any taxable year beginning
after December 31, 2017 . See, however,
section 15 .18 of this revenue procedure
for making a change in method of ac-
counting to the overall cash method for
taxable years beginning after December
31, 2017 .
(2) Manner of making change . See
either Rev . Proc . 2001-10 or Rev . Proc .
2002-28 for additional guidance on the
computation of the § 481(a) adjustment
and the completion of the Form 3115 .
(3) Concurrent automatic change to
treat inventoriable items as nonincidental
materials and supplies under Rev. Proc.
2001-10 or Rev. Proc. 2002-28 . A tax-
payer making both a change to the over-
all cash method under this section 15 .03
and a change to treat inventoriable items
as materials and supplies that are not in-
cidental pursuant to § 1 .162-3 under sec-
tion 22 .03 of this revenue procedure for
the same year of change may file a single
Form 3115 for both changes, provided the
taxpayer enters the designated automatic
accounting method change numbers for
both changes on the appropriate line on
that Form 3115 . See section 6 .03(1)(b) of
Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
for information on making concurrent
changes .
(4) Banks changing to overall cash/hy-
brid method . This change does not apply
to a bank described in section 15 .12(2)(a)
of this revenue procedure . However, such
a bank may be eligible to change to the
overall cash/hybrid method under section
15 .12 of this revenue procedure if it meets
the requirements of that section .
(5) Farming businesses changing to
overall cash method . A farming business
may be eligible to make this change under
section 15 .03(1)(a) of this revenue proce-
dure . However, a farming business is not
eligible to make this change under section
15 .03(1)(b) of this revenue procedure . A
farming business that is not eligible under
this section 15 .03 may still be eligible to
change to the overall cash method under
section 15 .13 of this revenue procedure if
it meets the requirements of that section .
(6) Designated automatic account-
ing method change number . The des-
ignated automatic accounting method
change number for a change under section
15 .03(1)(a) of this revenue procedure is
“32 .” The designated automatic account-
ing method change number for a change
under section 15 .03(1)(b) of this revenue
procedure is “33 .”
(7) Contact information . For further
information regarding a change under this
section, contact Evan Hewitt at (202) 317-
7007 (not a toll-free number) .
.04 Nonaccrual-experience method .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to make one or
more of the changes in method of account-
ing to, from, or within a nonaccrual-expe-
rience (NAE) method of accounting that
are described in sections 3 .01(1) through
(5) of Rev . Proc . 2006-56, 2006-2 C .B .
1169, as modified by Rev. Proc. 2011-14,
2011-4 I.R.B. 330, and as modified and
amplified by Rev. Proc. 2011-46, 2011-42
I .R .B . 518 .
(b) Inapplicability . This change does
not apply to a taxpayer within the scope of
sections 3 .01(6) through 3 .01(8) of Rev .
Proc. 2006-56, as modified and amplified
by Rev . Proc . 2011-46 .
(2) Manner of making the change .
(a) Changes made with a § 481(a) ad-
justment . A change in method of account-
ing described in section 3 .01(1), (2), (3),
or (5) of Rev. Proc. 2006-56, as modified
and amplified by Rev. Proc. 2011-46, is
made with a § 481(a) adjustment .
(b) Changes made on a cut-off basis .
(i) In general . A change described in
section 3 .01(4) of Rev . Proc . 2006-56 is
made on a cut-off basis and the new ap-
plicable period applies only to the taxpay-
er’s NAE calculation of its uncollectible
amount for the year of change and for
subsequent years . Moreover, a change de-
scribed in sections 5 .02 and 5 .03 of Rev .
Proc . 2011-46 is made on a cut-off basis
and the proposed method applies only to
accounts receivable earned on or after the
first day of the year of change. According-
ly, a § 481(a) adjustment is neither permit-
ted nor required for a change described in
section 3 .01(4) of Rev . Proc . 2006-56 or
in section 5 .02 or 5 .03 of Rev . Proc . 2011-
46 .
(ii) Special filing rules for changes
made under section 5.02 and 5.03 of Rev.
Proc. 2011-46, as modified by this revenue
procedure .
(A) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to a change in method
of accounting made under section 5 .02 or
5.03 of Rev. Proc. 2011-46, as modified by
this revenue procedure .
(B) Filing rules . In accordance with
§ 1 .446-1(e)(3)(ii), the requirement of
§ 1.446-1(e)(3)(i) to file a Form 3115 is
waived and a statement in lieu of a Form
3115 is authorized for this change . Not-
withstanding the definition of Form 3115
in section 3 .07 of Rev . Proc . 2015-13, the
statement in lieu of a Form 3115 that is
permitted under section 5 .02 or 5 .03 of
Rev . Proc . 2011-46 and this section 15 .04
is considered a Form 3115 for purposes of
the automatic consent procedures of Rev .
Proc . 2015-13 . However, the requirement
to file the Duplicate copy, under sec-
tion 6 .03(1)(a) of Rev . Proc . 2015-13, is
waived . See section 5 .02 or 5 .03 of Rev .
Proc . 2011-46, as applicable, for what in-
formation is required to be provided on
the statement .
(3) Concurrent change to overall ac-
crual method and a NAE method of ac-
counting . A taxpayer making both an au-
tomatic change to, from, or within a NAE
method of accounting under this section

November 25, 2019 1168 Bulletin No. 2019–48
15 .04 and an automatic change to an over-
all accrual method under section 15 .01 of
this revenue procedure (whether or not it
is the taxpayer’s first § 448 year), must
file a single Form 3115 for both changes.
The taxpayer must complete all applicable
sections of Form 3115, including sections
that apply to the change to an overall ac-
crual method and to the change to a NAE
method, and must enter the automatic
accounting method change numbers for
both changes on Form 3115 . See section
6 .03(1)(b) of Rev . Proc . 2015-13 for in-
formation on making concurrent changes .
A taxpayer making both an automatic
change to, from, or within a NAE meth-
od of accounting under this section 15 .04
and a required change to an overall ac-
crual method under § 448 (the taxpayer’s
first § 448 year), and is either not eligible
to make the change to an overall accrual
method under section 15 .01 of this revenue
procedure or chooses to make the change
to an overall accrual method using the
procedures of § 1 .448-1(h)(2), must make
both changes (change to, from, or within
a NAE method and change to an overall
accrual method) on a single Form 3115 .
The taxpayer must follow the automatic
change procedures of Rev . Proc . 2015-
13 and this section 15 .04 for the NAE
change, and the procedures of § 1 .448-
1(h)(2) for the change to an overall accrual
method (except that entering the designat-
ed automatic accounting method change
number “34” on the Form 3115 fulfills
the requirement of § 1 .448-1(h)(2) to type
or print “Automatic Change to Accrual –
Section 448” at the top of page 1 of the
Form 3115) . The taxpayer must complete
all applicable sections of Form 3115, in-
cluding sections that apply to the change
to an overall accrual method and to the
change to the NAE method and must en-
ter the designated automatic accounting
method change numbers for both changes
on Form 3115 .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to, from, or within
a NAE method of accounting under this
section 15 .04 is “35 .”
(5) Contact information . For further
information regarding a change under this
section, contact Roy Hirschhorn at (202)
317-7007 (not a toll-free number) .
.05 Interest accruals on short-term
consumer loans—Rule of 78’s method .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting from the Rule of
78’s method to the constant yield method
for stated interest (including stated in-
terest that is original issue discount) on
short-term consumer loans described in
Rev . Proc . 83-40, 1983-1 C .B . 774, which
was obsoleted by Rev . Proc . 97-37, 1997-
2 C .B . 455 .
(2) Background .
(a) A short-term consumer loan is de-
scribed in Rev . Proc . 83-40, provided:
(i) the loan is a self-amortizing loan
that requires level payments, at regular in-
tervals at least annually, over a period not
in excess of five years (with no balloon
payment at the end of the loan term); and
(ii) the loan agreement between the
borrower and the lender provides that in-
terest is earned, or upon the prepayment
of the loan interest is treated as earned, in
accordance with the Rule of 78’s method .
(b) In general, the Rule of 78’s method
allocates interest over the term of a loan
based, in part, on the sum of the periods’
digits for the term of the loan . See Rev .
Rul . 83-84, 1983-1 C .B . 97, for a descrip-
tion of the Rule of 78’s method .
(c) In general, the constant yield meth-
od allocates interest and original issue
discount over the term of a loan based on
a constant yield . See § 1 .1272-1(b) for a
description of the constant yield method .
The Rule of 78’s method generally front-
loads interest as compared to the constant
yield method .
(d) Rev . Proc . 83-40 was obsoleted
because, under §§ 1 .446-2 and 1 .1272-1
(which were effective for debt instruments
issued on or after April 4, 1994), taxpayers
generally must account for stated interest
and original issue discount on a debt in-
strument (loan) by using a constant yield
method . As a result, the Rule of 78’s meth-
od is no longer an acceptable method of
accounting for federal income tax purpos-
es .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .05 is “71 .”
(4) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
.06 Film producer’s treatment of cer-
tain creative property costs .
(1) Description of change . This change
applies to a taxpayer that wants to change
the method of accounting for creative
property costs to the safe harbor method
provided by section 5 of Rev . Proc . 2004-
36, 2004-1 C .B . 1063 . This safe harbor
method of accounting applies to a tax-
payer engaged in the trade of business of
film production and to creative property
costs (as defined in section 2.01 of Rev.
Proc . 2004-36) properly written off by the
taxpayer under The American Institute of
Certified Public Accountants Statement
of Position (SOP) 00-2, “Accounting for
Producers or Distributors of Film .”
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .06 is “85 .”
(3) Contact information . For further
information regarding a change under this
section, contact Bernard Harvey at (202)
317-7005 (not a toll-free number) .
.07 Deduction of incentive payments to
health care providers .
(1) Description of change . This change
applies to a taxpayer that wants to change
to the method of accounting for provider
incentive payments under which those
payments are included in discounted un-
paid losses without regard to § 404, as pro-
vided in Rev . Proc . 2004-41, 2004-2 C .B .
90 . A payment by a taxpayer to a health
care provider is a “provider incentive pay-
ment,” and thus eligible for this treatment,
if (a) the taxpayer is taxable as an insur-
ance company under Part II of subchapter
L; (b) the payment is made pursuant to a
written agreement the purpose of which
is to encourage participating health care
providers to provide quality health care
to the taxpayer’s subscribers in a cost-ef-
ficient manner; (c) the taxpayer’s liability
for the payment is dependent on the attain-
ment of one or more preestablished goals
during a performance period consisting
of not more than 12 consecutive months;
(d) the terms of the arrangement pursuant
to which the payment is made are estab-
lished unilaterally by the taxpayer, and are
not negotiated with the health care provid-
ers; (e) the taxpayer normally makes pay-

Bulletin No. 2019–48 1169 November 25, 2019
ments to health care providers under the
arrangement within 12 months after the
close of the performance period; (f) de-
ferring the receipt of income by the health
care provider or otherwise providing a tax
benefit to the provider is not a principal
purpose of the arrangement; (g) the tax-
payer records a liability for the payment
on its annual statement filed for state regu-
latory purposes, and includes this liability
in the determination of discounted unpaid
losses under § 846; and (h) the health care
provider is not an employee, and is not
providing health care as an agent, of the
taxpayer . See Rev . Proc . 2004-41 .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .07 is “90 .”
(3) Contact information . For further
information regarding a change under
this section, contact Rebecca L . Baxter at
(202) 317-6995 (not a toll-free number) .
.08 Change by bank for uncollected in-
terest .
(1) Description of change . This change
applies to a “bank” as defined in § 1.166-
2(d)(4)(i) that: (a) uses an overall accru-
al method of accounting to determine its
taxable income for federal income tax
purposes; (b) is subject to supervision by
Federal authorities, or by state authorities
maintaining substantially equivalent stan-
dards; (c) has uncollected interest other
than interest described in § 1 .446-2(a)(2);
and (d) has six or more years of collection
experience . Under the safe harbor meth-
od of accounting provided by section 4 of
Rev . Proc . 2007-33, 2007-1 C .B . 1289,
a bank determines for each taxable year
the amount of uncollected interest (other
than interest described in § 1 .446-2(a)(2))
for which it is considered to have a rea-
sonable expectancy of payment by multi-
plying: (a) the total accrued (determined
under § 1 .446-2) but uncollected interest
for the year, by (b) the bank’s “recovery
percentage” (determined under section
4 .02 of Rev . Proc . 2007-33) for that year .
Solely for purposes of this safe harbor,
the bank is not considered to have a rea-
sonable expectancy of payment for the
excess, if any, of the accrued but uncol-
lected interest over the expected collec-
tion amount determined using the bank’s
recovery percentage . The bank includes
in gross income the portion of accrued but
uncollected interest for which it has a rea-
sonable expectancy of payment . The bank
excludes from income the portion of ac-
crued but uncollected interest for which it
has no reasonable expectancy of payment .
(2) Recovery percentage . Subject to the
limitations and conditions in Rev . Proc .
2007-33, sections 4 .02(2), (3), and (4), a
bank determines its recovery percentage
for each taxable year by dividing: (a) total
payments that the bank received on loans
(including principal and interest) during
the 5 taxable years immediately preced-
ing the taxable year, by (b) total amounts
that were due and payable to the bank on
loans during the same 5 taxable years .
The recovery percentage cannot exceed
100 percent and must be calculated to at
least four decimal places . The data used
in the recovery percentage must take into
account acquisitions and dispositions . If a
bank acquires the major portion of a trade
or business of another person (predeces-
sor) or the major portion of a separate unit
of a trade or business of a predecessor,
then in applying Rev . Proc . 2007-33 for
any taxable year ending on or after the ac-
quisition, the data from preceding taxable
years of the predecessor attributable to the
portion of the trade or business acquired,
if available, must be used in determining
the bank’s recovery percentage . If a bank
disposes of a major portion of a trade or
business or the major portion of a separate
unit of a trade or business, and the bank
furnished the acquiring person the infor-
mation necessary for the computations
required by Rev . Proc . 2007-33, then in
applying the revenue procedure for any
taxable year ending on or after the disposi-
tion, the data from preceding taxable years
attributable to the disposed portion of the
trade or business may not be used in de-
termining the bank’s recovery percentage .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .08 is “108 .”
(4) Contact information . For further
information regarding a change under this
section, contact K . Scott Brown at (202)
317-6945 (not a toll-free number) .
.09 Change from the cash method to an
accrual method for specific items .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that uses an overall accrual
method of accounting but has identified
a specific item or items of income or ex-
pense (or both) that are being accounted
for on the cash method of accounting . This
change does not apply to a taxpayer that is
changing its overall method of accounting
from cash to accrual . Such a taxpayer may
be eligible to change to an overall accrual
method using section 15 .01 of this reve-
nue procedure .
(b) Inapplicability . This change does
not apply to:
(i) a taxpayer that will not have all
items of income and expense on an accru-
al method subsequent to the change under
this section 15 .09;
(ii) a cooperative organization de-
scribed in § 501(c)(12), 521, or 1381;
(iii) an individual taxpayer, except for
activities conducted as a sole proprietor-
ship;
(iv) a taxpayer engaged in two or more
trades or businesses, unless the taxpayer
makes this change so that the identical ac-
crual method is used for each such trade
or business beginning with the year of
change;
(v) a change in method of accounting
for any payment liability described in
§ 1 .461-4(g);
(vi) a change in the method of account-
ing for interest that is not taken into ac-
count under § 1 .446-2;
(vii) a taxpayer that has included in its §
481(a) adjustment any amount of deferred
compensation that is described under §
457A(d)(3) that is attributable to services
performed before January 1, 2009; and
(viii) any change that is specifically
provided in another section of this reve-
nue procedure .
(2) Definitions .
(a) “Cash method of accounting” is
the method identified by § 446(c)(1)
and §§ 1 .446-1(c)(1)(i), 1 .451-1(a), and
1 .461-1(a)(1) .
(b) “Accrual method of accounting”
is the method identified by § 446(c)(2)
and §§ 1 .446-1(c)(1)(ii), 1 .451-1(a), and
1 .461-1(a)(2) .
(3) Additional requirements . To change
a method of accounting under this section
15 .09, a taxpayer must attach to its com-
pleted Form 3115 a full and complete de-
scription of each specific item for which

November 25, 2019 1170 Bulletin No. 2019–48
the change in method of accounting is
being made and how the accrual method
of accounting applies to each item, and
list the § 481(a) adjustment, if any, for
each item associated with the change .
The change is fully and completely de-
scribed if each income and expense item
is described with specificity and how the
all-events test (and the economic perfor-
mance requirement, if applicable) applies
to each item is described under the facts
and circumstances of the taxpayer’s trade
or business . For example, a taxpayer that
merely states that it is changing its ac-
counting method for advertising expenses
from the cash method to an accrual meth-
od, recites the regulations under § 1 .461-
1(a)(2), and enters the associated § 481(a)
adjustment has failed to describe fully and
completely the specific item for which the
change in method of accounting is being
made . In contrast, a taxpayer that states
that it is changing its method of account-
ing for print advertising expenses from the
cash method of accounting to an accrual
method of accounting, describes all of the
relevant facts related to the print advertis-
ing expenses, and explains how the all-
events test applies to those facts and when
economic performance occurs has fully
and completely described the item and
the change . See section 6 .03 of Rev . Proc .
2015-13, 2015-5 I .R .B . 419, for additional
filing requirements.
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .09 is “124 .”
(5) Contact information . For further
information regarding a change under this
section, contact Douglas Kim at (202)
317-7003 (not a toll-free number) .
.10 Multi-year service warranty con-
tracts .
(1) Description of change .
(a) Applicability . This change applies
to a manufacturer, wholesaler, or retailer
of motor vehicles or other durable con-
sumer goods that uses an overall accru-
al method of accounting, and wants to
change to the service warranty income
method described in section 5 of Rev .
Proc . 97-38, 1997-2 C .B . 479 . Under the
service warranty income method, a qual-
ifying taxpayer may, in certain specified
and limited circumstances, include a por-
tion of an advance payment related to the
sale of a multi-year service warranty con-
tract in gross income generally over the
life of the service warranty obligation .
(b) Inapplicability . This change does
not apply to a taxpayer not within the
scope of Rev . Proc . 97-38 .
(2) Manner of making change and
designated automatic accounting method
change number .
(a) This change is made on a cut-off ba-
sis and applies only to qualified advance
payments for multi-year service warranty
contracts on or after the beginning of the
year of change . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired .
(b) In accordance with § 1 .446-1(e)(3)
(ii), the requirement of § 1 .446-1(e)(3)(i)
to file a Form 3115 is waived and pursuant
to section 6 .02(2) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, a short Form 3115 is
authorized for this change . The short Form
must include the following information:
(i) the identification section of page 1
(above Part I);
(ii) the signature section at the bottom
of page 1;
(iii) Part I, line 1(a); and
(iv) the information required under sec-
tion 6 .03 of Rev . Proc . 97-38, except that
the statement under section 6 .03(2) (that
the taxpayer agrees to all of the terms and
conditions of the revenue procedure) also
should refer to Rev . Proc . 2015-13 .
(3) Additional requirement . A taxpayer
changing to the service warranty income
method of accounting under this section
15 .10 must satisfy the annual reporting re-
quirement set forth in section 6 .04 of Rev .
Proc . 97-38 .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .10 is “125 .”
(5) Contact information . For further
information regarding a change under
this section, contact David Christensen at
(202) 317-7011 (not a toll-free number) .
.11 Overall cash method for specified
transportation industry taxpayers .
(1) Description of change . This change
applies to a “specified transportation in-
dustry taxpayer” with “average annual
gross receipts” of more than $10,000,000
and not in excess of $50,000,000 that
wants to change to the overall cash re-
ceipts and disbursement (cash) method .
(2) Definitions . For purposes of this
section 15.11 the following definitions
apply:
(a) Specified transportation industry
taxpayer. A specified transportation indus-
try taxpayer is a taxpayer that satisfies the
following criteria for the year of change:
(i) The taxpayer reasonably identi-
fies its “business” (as defined in section
15 .11(2)(b) below) as being described in
one of the following NAICS subsector
codes (first three digits of the six-digit
NAICS codes):
(A) Air Transportation, Rail Transpor-
tation, Water Transportation, Truck Trans-
portation, Transit and Ground Passenger
Transportation, or Scenic and Sightseeing
Transportation, within the meaning of
NAICS subsector codes 481-485 and 487;
or
(B) Support Activities for Transporta-
tion within the meaning of NAICS sub-
sector code 488 .
(ii) The taxpayer is not prohibited
from using the overall cash method under
§ 448 .
(b) Business . A taxpayer may use any
reasonable method of applying the rele-
vant facts and circumstances to determine
its business . A business may consist of
several activities, which may or may not
be related . For example, a taxpayer en-
gaged in transportation activities may pro-
vide various services such as transporting
air cargo and then subsequently trucking
the cargo throughout a metropolitan area
to warehouses and wholesale/retail stores .
However, each activity within a taxpay-
er’s business must individually satisfy
the description of a NAICS subsector
code in section 15 .11(2)(a)(i)(A) or (B)
of this revenue procedure . For example,
a sightseeing bus operator that sells box
lunches in connection with its tours is not
a “specified transportation industry tax-
payer” because one of the two activities
of its business (food sales) does not satis-
fy the description of a NAICS subsector
code in section 15 .11(2)(a)(i)(A) or (B) of
this revenue procedure . While the sight-
seeing transportation activity satisfies
the description of the NAICS subsector
code in section 15 .11(2)(a)(i)(A) of this
revenue procedure, the food sales activi-
ty does not satisfy the description of any

Bulletin No. 2019–48 1171 November 25, 2019
NAICS subsector code in section 15 .11(2)
(a)(i)(A) or (B) of this revenue procedure,
and thus, the taxpayer’s business fails to
meet the criteria of section 15 .11(2)(a)
(i) . Similarly, a train operator who oper-
ates a dining car where meals are served
is not a “specified transportation industry
taxpayer” because one of the two activi-
ties of its business (food service) does not
satisfy the description of a NAICS sub-
sector code in section 15 .11(2)(a)(i)(A)
or (B) of this revenue procedure . While
the rail transportation activity satisfies the
description of a NAICS subsector code in
section 15 .11(2)(a)(i)(A) of this revenue
procedure, the food service activity does
not satisfy the description of any NAICS
subsector code in section 15 .11(2)(a)(i)
(A) or (B) of this revenue procedure, and
thus, the taxpayer’s business fails to meet
the criteria of section 15 .11(2)(a)(i) .
(c) Average annual gross receipts . A
taxpayer has average annual gross receipts
of more than $10,000,000 and not in ex-
cess of $50,000,000 if, for each prior tax-
able year ending on or after December 31,
2006, the taxpayer’s average annual gross
receipts for the three prior taxable-year
period ending with the applicable prior
taxable year are more than $10,000,000
and do not exceed $50,000,000 . If a tax-
payer has not been in existence for three
prior taxable years, the taxpayer must de-
termine its average annual gross receipts
for the number of years (including short
taxable years) that the taxpayer has been
in existence . See § 448(c)(3)(A) .
(d) Gross receipts . Gross receipts is
defined consistent with § 1.448-1T(f)(2)
(iv) . Thus, gross receipts for a taxable year
equal all receipts that must be recognized
under the method of accounting actually
used by the taxpayer for that taxable year
for federal income tax purposes . See also
§ 448(c)(3)(C) .
(e) Aggregation of gross receipts . For
purposes of computing gross receipts un-
der section 15 .11(2)(d) of this revenue
procedure, all taxpayers treated as a single
employer under § 52(a) or (b) or § 414(m)
or (o) (or that would be treated as a single
employer under these sections if the tax-
payers had employees) will be treated as
a single taxpayer . However, when trans-
actions occur between taxpayers that are
treated as a single taxpayer by the previ-
ous sentence, gross receipts arising from
these transactions will not be treated as
gross receipts for purposes of the aver-
age annual gross receipts limitation . See
§ 448(c)(2) and § 1 .448-1T(f)(2)(ii) .
(f) Treatment of short taxable year .
In the case of a short taxable year, a tax-
payer’s gross receipts must be annualized
by multiplying the gross receipts for the
short taxable year by 12 and then dividing
the result by the number of months in the
short taxable year . See § 448(c)(3)(B) and
§ 1 .448-1T(f)(2)(iii) .
(g) Treatment of predecessors . Any ref-
erence to a taxpayer in this section 15 .11
includes a reference to any predecessor of
that taxpayer . See § 448(c)(3)(D) .
(h) Cash method . The “cash method”
is the method identified by § 446(c)(1)
and §§ 1 .446-1(c)(1)(i), 1 .451-1(a), and
1 .461-1(a)(1) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .11 is “126 .”
(4) Example . Taxpayer X is an LLC and
taxed for federal income tax purposes as a
partnership . Taxpayer X does not have any
C corporations as partners and Taxpayer
X is not a tax shelter within the meaning
of § 448(d)(3) . Taxpayer X’s business
consists of short-haul trucking among var-
ious cities within State Y, which satisfies
the description of the NAICS subsector
code 484 . Taxpayer X determines that its
3-year average annual gross receipts for
each prior taxable year ending on or af-
ter December 31, 2006, have been more
than $10,000,000 and not in excess of
$50,000,000 . Taxpayer X qualifies to
change to the overall cash method using
this section 15 .11 .
(5) Contact information . For further
information regarding a change under this
section, contact Evan Hewitt at (202) 317-
7007 (not a toll-free number) .
.12 Change to overall cash/hybrid
method for certain banks .
(1) Description of change .
(a) Applicability . This change applies
to a bank described in section 15 .12(2)
(a) of this revenue procedure that wants to
change to an overall cash/hybrid method
described in section 15 .12(2)(b) of this
revenue procedure .
(b) Inapplicability . A bank’s change to
an overall cash/hybrid method under this
section 15 .12 does not include any change
in the accounting treatment of an item for
which the bank uses a special method (as
described in section 15 .12(2)(b) of this
revenue procedure) before the change,
or is required to use a special method, or
will use a special method after the change .
A bank may not change the accounting
treatment of such an item under this sec-
tion 15 .12 . Any change in the accounting
treatment of such an item must be made
under an applicable section of this reve-
nue procedure, under the non-automatic
change procedures of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, or under another guid-
ance published in the Internal Revenue
Bulletin, as appropriate .
(2) Definitions. The following defini-
tions apply for purposes of this section
15 .12 .
(a) Bank . A bank is described in this
section 15 .12(2)(a) if the bank:
(i) is a bank as defined in § 581;
(ii) is an S corporation as defined in
§ 1361(a)(1), or a qualified subchapter S
subsidiary as defined in § 1361(b)(3)(B);
and
(iii) has average annual gross re-
ceipts (computed as described in section
15 .12(5) of this revenue procedure) not in
excess of $50,000,000 .
(b) Overall cash/hybrid method . An
overall cash/hybrid method is the use of a
combination of accounting methods under
which some items of income or expense
are reported on the cash receipts and dis-
bursements method (cash method) and
other items of income or expense are re-
ported on methods permitted or required
for the accounting treatment of special
items (special methods) .
(i) Cash method . The cash method
is the method identified by § 446(c)(1)
and §§ 1 .446-1(c)(1)(i), 1 .451-1(a), and
1 .461-1(a)(1) .
(ii) Special methods . A few of the spe-
cial methods typically used by banks in-
clude those provided for the accounting
treatment of the following items: securi-
ties held by a dealer in securities as de-
fined in § 475(c)(1) (the mark-to-market
method of § 475); securities held by a
dealer in securities as defined in § 1.471-5
(inventories maintained under § 471 and
§ 1 .446-1(c)(2)(i)); hedging transactions
(§ 1 .446-4); contracts to which § 1256
applies (§ 1256); original issue discount

November 25, 2019 1172 Bulletin No. 2019–48
on debt instruments (§§ 163(e) and 1271-
1275); interest income (including acquisi-
tion discount and original issue discount)
on short-term obligations (§§ 1281-1283);
and stripped debt instruments (§ 1286) .
For example, a bank that regularly pur-
chases or originates mortgages in the ordi-
nary course of its business and engages in
more than negligible sales of those mort-
gages generally is a dealer in securities
under § 475(c)(1) and § 1 .475(c)-1(c) and
thus must use the mark-to-market method
of § 475 for mortgages and any other se-
curities (as defined in § 475(c)(2)) held by
the bank .
(3) Additional condition of change . To
change to an overall cash/hybrid meth-
od under this section 15 .12, a bank must
comply with the following additional con-
dition . In addition to complying with the
terms and conditions set forth in section
7 of Rev . Proc . 2015-13, the bank must
keep its books and records for the year of
change and for subsequent taxable years
on an overall cash/hybrid method allowed
by this section 15 .12 . This condition is
considered satisfied if the bank reconciles
the results obtained under the method
used in keeping its books and records and
those obtained under the method used for
federal income tax purposes pursuant to
this section 15 .12 and the bank maintains
sufficient records to support such recon-
ciliation . See also § 1 .446-1(a)(4) .
(4) Additional filing requirement . To
change to an overall cash/hybrid meth-
od under this section 15 .12, a bank must
include with its completed Form 3115 a
description of each specific item of the
bank’s income or expense that is affected
by the change under this section 15 .12 and,
for each such item, identify the following:
the method of accounting under which
the bank reports that item for federal in-
come tax purposes immediately before the
change; and the amount of the § 481(a)
adjustment associated with changing that
item to the cash method under this section
15 .12 .
(5) Computation of average annual
gross receipts . For purposes of section
15 .12(2)(a)(iii) of this revenue procedure,
a bank’s average annual gross receipts
are computed as described in this section
15 .12(5) .
(a) Average annual gross receipts . A
bank has average annual gross receipts not
in excess of $50,000,000 if, for each prior
taxable year ending on or after December
31, 2006, the bank’s average annual gross
receipts for the three prior taxable-year
period ending with the applicable prior
taxable year do not exceed $50,000,000 . If
a bank has not been in existence for three
prior taxable years, the bank must deter-
mine its average annual gross receipts for
the number of years (including short tax-
able years) that the bank has been in exis-
tence . See § 448(c)(3)(A) .
(b) Gross receipts . Gross receipts is
defined consistent with § 1.448-1T(f)(2)
(iv) . Thus, gross receipts for a taxable year
equal all receipts that must be recognized
under the method of accounting actual-
ly used by the bank for that taxable year
for federal income tax purposes . See also
§ 448(c)(3)(C) .
(c) Aggregation of gross receipts . For
purposes of computing gross receipts un-
der section 15 .12(5)(b) of this revenue
procedure, all taxpayers treated as a single
employer under § 52(a) or (b) or § 414(m)
or (o) (or that would be treated as a sin-
gle employer under these sections if the
taxpayers had employees) will be treat-
ed as a single taxpayer (that is, a single
bank) . However, when transactions occur
between taxpayers that are treated as a
single taxpayer by the previous sentence,
gross receipts arising from these transac-
tions will not be treated as gross receipts
for purposes of the average annual gross
receipts limitation . See § 448(c)(2) and
§ 1 .448-1T(f)(2)(ii) .
(d) Treatment of short taxable year . In
the case of a short taxable year, a bank’s
gross receipts must be annualized by mul-
tiplying the gross receipts for the short
taxable year by 12 and then dividing the
result by the number of months in the
short taxable year . See § 448(c)(3)(B) and
§ 1 .448-1T(f)(2)(iii) .
(e) Treatment of predecessors . Any
reference to a bank or taxpayer in section
15 .12(5) of this revenue procedure in-
cludes a reference to any predecessor of
that bank or taxpayer . See § 448(c)(3)(D) .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .12 is “127 .”
(7) Contact information . For further
information regarding a change under this
section, contact K . Scott Brown at (202)
317-6945 (not a toll-free number) .
.13 Change to overall cash method for
farmers .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer engaged in the trade or busi-
ness of farming that wants to change to
the overall cash receipts and disbursement
(cash) method . If a taxpayer is engaged
in more than one trade or business, this
change applies only to the taxpayer’s trade
or business of farming .
(b) Inapplicability . This change does
not apply to a taxpayer that is required to
use an accrual method pursuant to § 447,
or prohibited from using the cash method
by § 448 .
(2) Definitions .
(a) Cash method of accounting is
the method defined by § 446(c)(1) and
§§ 1 .446-1(c)(1)(i), 1 .451-1(a), and 1 .461-
1(a)(1) . See also §§ 1 .61-4 and 1 .162-12
for specific rules relating to farmers.
(b) The trade or business of farming is a
farming business as defined by § 263A(e)
(4) and the regulations thereunder .
(3) Certain eligibility rule temporar-
ily inapplicable . The eligibility rule in
section 5 .01(1)(e) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, does not apply to this
change for a taxpayer’s first, second, or
third taxable year beginning after Decem-
ber 31, 2017 .
(4) Manner of making change . Gener-
ally, a taxpayer changing its method of
accounting under this section 15 .13 must
compute a § 481(a) adjustment . Howev-
er, if the taxpayer is changing from the
crop method, that portion of the change
is made using a cut-off basis under which
expenses reported on the crop method
and not deducted prior to the year of
change are deducted in the year the relat-
ed crop is sold .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .13 is “128 .”
(6) Contact information . For further
information regarding a change under this
section, contact Mon Lam at (202) 317-
5100 (not a toll-free number) .
.14 Nonshareholder contributions to
capital under § 118 .
(1) Description of change .

Bulletin No. 2019–48 1173 November 25, 2019
(a) Water and sewerage disposal util-
ities under § 118(c) (as in effect on the
day before the date of enactment of Pub-
lic Law 115-97, 131 Stat. 2054 (Dec. 22,
2017) (“former § 118(c)”)) .
(i) This change applies to a regulat-
ed public utility described in former §
118(c) that wants to change its method of
accounting for payments received from
customers as customer connection fees,
which are not contributions to the capital
of the regulated public utility within the
meaning of former § 118(c), from exclud-
ing the payments from gross income as
nontaxable contributions to capital under
§ 118 to including the payments in gross
income under § 61 . See Rev . Rul . 2008-
30, 2008-1 C .B . 1156 .
(ii) This change applies to a regulat-
ed public utility described in former §
118(c) that wants to change its method
of accounting for payments or property
received that are contributions in aid of
construction under former § 118(c) and §
1 .118-2 and that meet the requirements of
former § 118(c)(1)(B) and (c)(1)(C) from
including the payments or the fair market
value of the property in gross income un-
der § 61 to excluding the payments or the
fair market value of the property from in-
come as nontaxable contributions to capi-
tal under § 118(a) .
(b) Other payments or property re-
ceived . This change applies to a taxpayer
that wants to change its method of account-
ing for payments or property received
(other than the payments received by a
public utility described in former § 118(c)
that are addressed in section 15 .14(1)(a)
(i) of this revenue procedure) that do not
constitute contributions to the capital of
the taxpayer within the meaning of § 118
and the regulations thereunder, from ex-
cluding the payments or the fair market
value of the property from gross income
as nontaxable contributions to capital un-
der § 118 to including the payments or the
fair market value of the property in gross
income under § 61 .
(2) Inapplicability . The change de-
scribed in section 15 .14(1)(a)(ii) of this
revenue procedure does not apply to con-
tributions made after December 22, 2017,
the date of enactment of Public Law 115-
97 .
(3) Additional requirement . A taxpayer
that is making a change described in sec-
tion 15 .14(1)(a)(i) or (1)(b) of this reve-
nue procedure must complete Schedule E
of Form 3115 for the depreciable property
to which the change relates (as well as all
other relevant portions of the Form 3115) .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .14 is “129 .”
(5) Contact information . For further
information regarding a change under this
section, contact David H . McDonnell at
(202) 317-4137 (not a toll-free number) .
.15 Debt issuance costs .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for capital-
ized debt issuance costs to comply with
§ 1 .446-5, which provides rules for allo-
cating the costs over the term of the debt .
This change also applies to a taxpayer that
wants to change its method of accounting
for capitalized debt issuance costs from
one permissible method to another per-
missible method under the last sentence
in § 1 .446-5(b)(2) if the total original is-
sue discount determined for purposes of
§ 1 .446-5 is de minimis .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .15 is “148 .”
(3) Contact information . For further
information regarding a change under
this section, contact Charles W . Culmer at
(202) 317-6945 (not a toll-free number) .
.16 Transfers of interties under the safe
harbor described in Notice 2016-36 (§
118) .
(1) Description of change .
(a) Safe harbor applicable . This
change, as described in Notice 2016-36,
2016-25 I .R .B . 1029, applies to a utility
that wants to change to the safe harbor
method of accounting provided in section
III .C of Notice 2016-36 for the treatment
under § 118 of a transfer of an intertie, in-
cluding a dual-use intertie, by a generator
to a utility . Under this safe harbor meth-
od of accounting, such a transfer will not
be treated as gross income under § 118(a)
or a contribution in aid of construction
(CIAC) under § 118(b) if all of the con-
ditions specified in section III.C of Notice
2016-36 are met .
(b) Safe harbor terminates . This
change, as described in Notice 2016-36,
applies to a utility that is using the safe
harbor method of accounting provided in
section III .C of Notice 2016-36 and is re-
quired to terminate that safe harbor meth-
od of accounting because of the occur-
rence of an event specified in section IV of
Notice 2016-36 . The occurrence of such
event will require the utility to recognize
income as a consequence of the transfer of
an intertie, including a dual-use intertie, to
the utility by a generator .
(2) Definitions . For purposes of this
section 15 .16, the terms “utility,” “inter-
tie,” “dual-use intertie,” and “generator”
are defined in section III.B of Notice
2016-36 .
(3) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(d) and (f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, do not apply to a utility
making a change under this section 15 .16 .
(4) Manner of making change .
(a) The change in method of account-
ing under section 15 .16(1)(a) of this rev-
enue procedure is made with a § 481 (a)
adjustment .
(b) The change in method of account-
ing under section 15 .16(1)(b) of this rev-
enue procedure is made using a cut-off
method and applies to a transfer of an in-
tertie, including a dual-use intertie, by a
generator to a utility made on or after the
beginning of the taxable year in which the
safe harbor method of accounting termi-
nates .
(5) Concurrent automatic change . A util-
ity making a change under this section 15 .16
for more than one transfer of an intertie, in-
cluding a dual-use intertie, for the same year
of change should file a single Form 3115
for all such transfers . The single Form 3115
must provide a single net § 481(a) adjust-
ment for all changes under section 15 .16(1)
(a) of this revenue procedure .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change to the methods of ac-
counting under this section 15 .16 is “226 .”
(7) Contact information . For further
information regarding a change under
this section, contact Barbara Campbell at
(202) 317-4137 (not a toll-free number) .
.17 Change to or from the net asset val-
ue (NAV) method .

November 25, 2019 1174 Bulletin No. 2019–48
(1) Description of change . This change,
as described in Rev . Proc . 2016-39, 2016-
30 I .R .B . 164, applies to a taxpayer that
holds shares in a money market fund
(MMF) as defined in § 1.446-7(b)(4) (giv-
ing effect to § 1 .446-7(c)(5), under which
MMF holdings in different accounts are
treated as different MMFs) and that wants
to change its method of accounting for
gain or loss on the shares from a realiza-
tion method to the NAV method described
in § 1 .446-7 or from the NAV method to a
realization method .
(2) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(c), (d), and (f) of Rev . Proc . 2015-
13 do not apply to this change .
(3) Definitions .
(a) “Rule 2a-7” means Rule 2a-7 (17
CFR 270 .2a-7) under the Investment
Company Act of 1940 .
(b) “Floating-NAV MMF” means an
MMF that is required to value its assets
using market factors and to round its price
per share to the nearest basis point (the
fourth decimal place, in the case of a fund
with a $1 .0000 share price) under Rule
2a-7 .
(c) “Stable-NAV MMF” means an
MMF that is not a floating-NAV MMF.
(4) Manner of making change .
(a) A change to or from the NAV
method is made on a cut-off basis . See
§ 1 .446-7(c)(8) . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired . A taxpayer making a change to
or from the NAV method for shares in an
MMF applies the new method only to the
computation of gain or loss on the shares
beginning with the year of change . Under
§ 1 .446-7(b)(7)(ii), a taxpayer changing
to the NAV method takes a starting basis
(as defined in § 1.446-7(b)(7)) in those
shares for the year of change equal to the
aggregate adjusted basis of the taxpayer’s
shares in the MMF at the end of the imme-
diately preceding taxable year . A taxpayer
changing from the NAV method to a reali-
zation method for shares in an MMF must
adjust the basis in the shares beginning
on the first day of the year of change to
account for gain or loss previously recog-
nized under the NAV method . According-
ly, the taxpayer generally takes a basis in
each MMF share at the beginning of the
year of change equal to the fair market
value of that share under § 1 .446-7(b)(3)
used in computing the ending value (as
defined in § 1.446-7(b)(2)) of the shares
in that MMF for the final computation pe-
riod (as defined in § 1.446-7(b)(1)) of the
taxable year prior to the year of change .
(b) Short Form 3115 in lieu of a Form
3115 . In accordance with § 1 .446-1(e)
(3)(ii), the requirement of § 1 .446-1(e)
(3)(i) to file a Form 3115 is waived and,
pursuant to section 6 .02(2) of Rev . Proc .
2015-13, a short Form 3115 is authorized
for a taxpayer changing from a realization
method to the NAV method, or changing
from the NAV method to a realization
method, for shares in an MMF . Unless the
change meets the requirements of section
15 .17(4)(c) of this revenue procedure, the
taxpayer must file a short Form 3115 that
includes the following information:
(i) the identification section of page 1
(above Part I);
(ii) the signature section at the bottom
of page 1;
(iii) Part I, line 1(a);
(iv) a statement specifying whether the
taxpayer is changing from a realization
method to the NAV method or from the
NAV method to a realization method; and
(v) a statement specifying the MMF
or MMFs to which the change applies, if
the change does not apply to all MMFs in
which the taxpayer holds shares (and, to
the extent applicable, whether the change
applies only to shares of the MMF or
MMFs held in a particular account) .
(c) No Form 3115 Required . In accor-
dance with § 1 .446-1(e)(3)(ii), a taxpayer
changing to the NAV method for shares
in a stable-NAV MMF may change to the
NAV method on a federal tax return with-
out filing a Form 3115 if the following re-
quirements are satisfied:
(i) the taxpayer has not used the NAV
method for shares in the MMF for any tax-
able year prior to the year of change; and
(ii) prior to the year of change, either
(A) the taxpayer’s basis in each share
of the MMF has been at all times equal to
the MMF’s target share price, or
(B) the taxpayer has not realized any
gain or loss with respect to shares in the
MMF .
(5) Multiple changes . A taxpayer mak-
ing multiple changes under this section
15 .17 for the same year of change on a
short Form 3115 should file a single short
Form 3115 . The short Form 3115 will be
treated as applying to all shares that the
taxpayer holds in any MMF unless the
taxpayer specifies the MMFs to which the
change applies. If the taxpayer specifies an
MMF, the short Form 3115 will be treated
as applying to all shares in that MMF held
in any account by the taxpayer, unless the
short Form 3115 specifies the accounts to
which the change applies .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .17 is “227 .”
(7) Contact Information . For further
information regarding a change under this
section, contact Grace Cho at (202) 317-
6945 (not a toll-free number) .
.18 Small business taxpayer changing
to overall cash method .
(1) Description of change . This change
applies to a small business taxpayer, as de-
fined in section 15.18(5)(a) of this revenue
procedure, that wants to change its overall
method of accounting from an overall ac-
crual method of accounting to the overall
cash method of accounting for a trade or
business, and is otherwise not prohibited
from using the overall cash method or
required to use another overall method
of accounting . A small business taxpayer
may be required to use a method of ac-
counting (other than the cash method) for
one or more items of income or expense
under certain provisions of the Code or
regulations, including, for example §§ 475
and 1272 .
(2) Applicability . This section 15 .18 is
effective for taxable years beginning after
December 31, 2017 .
(3) Inapplicability . This change does
not apply to the following:
(a) Banks changing to overall cash/hy-
brid method . This change does not apply
to a bank described in section 15 .12(2)(a)
of this revenue procedure . However, such
a bank may be eligible to change to the
overall cash/hybrid method under section
15 .12 of this revenue procedure if it meets
the requirements of that section .
(b) Farmers changing to overall cash
method . This change does not apply to a
farming business changing to the overall
cash method . See, however, section 15 .13
of this revenue procedure .
(4) Special rules for open accounts re-
ceivables . Notwithstanding § 1001 and the

Bulletin No. 2019–48 1175 November 25, 2019
accompanying regulations, a small busi-
ness taxpayer that uses the overall cash
method for a trade or business includes
amounts attributable to open accounts re-
ceivable, as defined in section 15.18(5)(c)
of this revenue procedure, in income as
the amounts are actually or constructively
received on the receivables .
(5) Definitions .
(a) Small business taxpayer . A small
business taxpayer is a taxpayer, other than
a tax shelter (as defined in § 448(d)(3)),
that meets the § 448(c) gross receipts test .
(b) Section 448(c) gross receipts test .
The § 448(c) gross receipts test is met if
a taxpayer has average annual gross re-
ceipts for the three prior taxable years of
$25,000,000 or less (adjusted for infla-
tion) .
(c) Open accounts receivable . For pur-
poses of this section 15 .18, an open ac-
counts receivable is any receivable that is
due in full in 120 days or less and that is
not subject to § 475 .
(6) Certain eligibility rule temporar-
ily inapplicable . The eligibility rule in
section 5 .01(1)(e) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, does not apply to this
change for a taxpayer’s first, second, or
third taxable year beginning after Decem-
ber 31, 2017 .
(7) Reduced filing requirement . A tax-
payer is required to complete only the fol-
lowing information on Form 3115 (Rev .
December 2018) to make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except line 16;
(e) Part IV, all lines except line 25; and
(f) Schedule A, Part I, all lines except
lines 3 and 4 .
(8) Concurrent automatic changes . A
taxpayer making a change to the over-
all cash method under this section 15 .18
and a change under sections 12 .16 and/
or 22 .19 of this revenue procedure for
the same year of change may file a single
Form 3115 for all changes, provided the
taxpayer enters the designated automatic
accounting method change numbers for
the changes on the appropriate line of
Form 3115 . See section 6 .03(1)(b) of Rev .
Proc . 2015-13 for information on making
concurrent changes .
(9) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
15 .18 is “233 .”
(10) Contact information . For further
information regarding a change under this
section, contact Anna Gleysteen at (202)
317-7007 (not a toll-free number) .
SECTION 16 . TAXABLE YEAR OF
INCLUSION (§ 451)
.01 Accrual of interest on nonperform-
ing loans .
(1) Description of change .
(a) This change applies to a taxpayer
using an overall accrual method of ac-
counting that is a bank as defined in § 581
(or whose primary business is making
or managing loans) and wants to change
its method of accounting to comply with
§ 451 and § 1.451-1(a) for qualified stated
interest (as defined in § 1.1273-1(c)) on
nonperforming loans .
(b) Section 1 .451-1(a) requires income
to be accrued when all the events have
occurred that fix the right to receive the
income and the amount thereof can be
determined with reasonable accuracy . A
taxpayer may not stop accruing qualified
stated interest on a nonperforming loan
for federal income tax purposes merely
because payments on the loan are over-
due by a certain length of time, such as 90
days, even if a federal, state, or other reg-
ulatory authority having jurisdiction over
the taxpayer permits or requires that the
overdue interest not be accrued for regu-
latory purposes .
(c) Under § 451 and § 1 .451-1(a), a
taxpayer must continue accruing qualified
stated interest on any nonperforming loan
until either (i) the loan is worthless under
§ 166 and charged off as a bad debt, or (ii)
the interest is determined to be uncollect-
ible . In order for interest to be determined
uncollectible, the taxpayer must substan-
tiate, taking into account all the facts and
circumstances, that it has no reasonable
expectation of payment of the interest .
This substantiation requirement is applied
on a loan by loan basis .
(d) A taxpayer that changes its meth-
od of accounting under this section 16 .01
must do so for all of its loans .
(2) Section 481(a) adjustment . In
general, the § 481(a) adjustment for a
method change under this section 16 .01
represents the amount of qualified stated
interest on the taxpayer’s nonperforming
loans outstanding as of the beginning of
the year of change that should have been
accrued under § 451 and § 1 .451-1(a) and
was not accrued . Interest for which the
taxpayer, as of the beginning of the year
of change, has no reasonable expectation
of payment is not taken into account in
determining the amount of the § 481(a)
adjustment .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .01 is “36 .”
(4) Contact information . For further
information regarding a change under this
section, contact K . Scott Brown at (202)
317-6945 (not a toll-free number) .
.02 Advance rentals .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for advance rent-
als (other than advance rentals subject to
§ 467 and the regulations thereunder) to
include such advance rentals in gross in-
come in the taxable year received . See
§ 1 .61-8(b) .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .02 is “37 .”
(3) Contact information . For further
information regarding a change under this
section, contact Daniel Cassano at (202)
317-7011 (not a toll-free number) .
.03 State or local income or franchise
tax refunds .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that receives
a state or local income or franchise tax
refund and wants to accrue the refund in
the taxable year the taxpayer receives pay-
ment or notice that the claim has been ap-
proved, whichever is earlier, as provided
in Rev . Rul . 2003-3, 2003-1 C .B . 252 .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .03 is “38 .”

November 25, 2019 1176 Bulletin No. 2019–48
(3) Contact information . For further
information regarding a change under this
section, contact Daniel Cassano at (202)
317-7011 (not a toll-free number) .
.04 Capital Cost Reduction Payments .
(1) Description of change . This change
applies to a taxpayer that purchases motor
vehicles subject to leases and assumes the
associated leases from the vehicles’ deal-
ers and wants to use the safe harbor meth-
od of accounting for capital cost reduction
(CCR) payments specified in Rev. Proc.
2002-36, 2002-1 C .B . 993 .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .04 is “39 .”
(3) Contact information . For further
information regarding a change under this
section, contact Bill Ruane at (202) 317-
4718 (not a toll-free number) .
.05 Credit card annual fees .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for credit card
annual fees as described in Rev . Rul .
2004-52, 2004-1 C .B . 973, either to a
method that satisfies the all events test in
accordance with Rev . Rul . 2004-52 or to
the Ratable Inclusion Method for Cred-
it Card Annual Fees that is described in
section 4 of Rev . Proc . 2004-32, 2004-1
C .B . 988 . Rev . Rul . 2004-52 holds that
credit card annual fees are not interest
for federal income tax purposes and that
such fees are includible in income by the
card issuer when the all events test un-
der § 451 is satisfied. Rev. Proc. 2004-
32 provides additional guidance for tax-
payers seeking to change their methods
of accounting for such fees, including
guidance with respect to the Ratable In-
clusion Method for Credit Card Annual
Fees . However, a taxpayer may make
either change under this revenue proce-
dure only if the taxpayer uses an overall
accrual method of accounting for feder-
al income tax purposes and issues credit
cards to, and receives annual fees from,
cardholders under agreements that allow
each cardholder to use a credit card to
access a revolving line of credit to make
purchases of goods and services and, if
so authorized, to obtain cash advances .
(2) Manner of making change . In com-
pleting its Form 3115 to make this change,
a taxpayer must identify the specific meth-
od to which the taxpayer is changing .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16.05 to a method that satisfies the all
events test in accordance with Rev . Rul .
2004-52 is “80 .” The designated automat-
ic accounting method change number for
a change under this section 16 .05 to the
Ratable Inclusion Method for Credit Card
Annual Fees is “81 .”
(4) Contact information . For further
information regarding a change under this
section, contact Kate Sleeth at (202) 317-
7053 (not a toll-free number) .
.06 Credit card late fees .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for credit card
late fees to a method that treats these fees
as interest income that creates or increas-
es the amount of original issue discount
(OID) on the pool of credit card loans to
which the fees relate . This change is avail-
able only to a taxpayer that issues cred-
it cards allowing cardholders to access a
revolving line of credit established by the
taxpayer and that, for federal income tax
purposes, does not treat the credit card
purchase transactions of its cardholders as
creating either debt that is given in consid-
eration for the sale or exchange of prop-
erty (within the meaning of § 1274) or
debt that is deferred payment for property
(within the meaning of § 483) . See Rev .
Proc . 2004-33, 2004-1 C .B . 989, for ad-
ditional guidance relating to this change .
(2) Additional requirements . A tax-
payer making this change must be able to
demonstrate both of the following:
(a) the amount of any credit card late
fee charged to each cardholder by the tax-
payer is separately stated on the cardhold-
er’s account when that fee is imposed; and
(b) under the applicable credit card
agreement governing each cardholder’s
use of the credit card, no amount iden-
tified as a credit card late fee is charged
for property or for specific services per-
formed by the taxpayer for the benefit of
the cardholder .
(3) Audit protection . Any audit pro-
tection provided in connection with this
change is not a determination by the Com-
missioner that the taxpayer is properly ac-
counting for any OID income on that pool
of credit card loans . Thus, for example,
the IRS is not precluded from pursuing
the issue of whether a taxpayer is properly
accounting for its OID income (including
any OID income attributable to credit card
late fees) on its pool of credit card loans in
accordance with § 1272(a)(6) .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .06 is “82 .”
(5) Contact information . For further
information regarding a change under this
section, contact Kate Sleeth at (202) 317-
7053 (not a toll-free number) .
.07 Advance payments .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer using or changing to an
overall accrual method of accounting that
receives advance payments, as defined in
Rev . Proc . 2004-34, 2004-1 C .B . 991, as
modified and clarified by Rev. Proc. 2011-
18, 2011-5 I .R .B . 443, and Rev . Proc .
2013-29, 2013-33 I .R .B . 141, and as mod-
ified by Rev. Proc. 2011-14, 2011-4 I.R.B.
330, and wants to change to either the full
inclusion or deferral method, as described
in Rev . Proc . 2004-34, other than a tax-
payer changing to a method described in
section 16 .10 of this revenue procedure .
See also Notice 2018-35, 2018-18 I .R .B .
520, and Announcement 2004-48, 2004-1
C .B . 998 .
(b) Inapplicability . This change does
not apply to a taxpayer that wants to use
the Deferral Method for payments de-
scribed in section 5 .02(4)(a) of Rev . Proc .
2004-34 (other than allocable payments
described in section 5 .02(4)(c) of Rev .
Proc . 2004-34) or for payments for which
a method under section 5 .02(3)(b)(i) or
(iii) of Rev . Proc . 2004-34 applies . The
taxpayer must request any such change in
method of accounting using the non-au-
tomatic change procedures in Rev . Proc .
2015-13, 2015-5 I .R .B . 419 . See section
8 .03 of Rev . Proc . 2004-34 .
(2) Certain eligibility rule temporarily
inapplicable . The eligibility rule in section
5 .01(1)(f) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, does not apply to a taxpayer
that changes to a method of accounting
provided under section 16 .07(1)(a) of this
revenue procedure for the taxpayer’s first

Bulletin No. 2019–48 1177 November 25, 2019
or second taxable year ending on or after
May 9, 2018 .
(3) Concurrent automatic change to
an overall accrual method . A taxpayer
making both a change to its method of ac-
counting for advance payments under this
section 16 .07 and a change to an overall
accrual method under section 15 .01 of
this revenue procedure for the same year
of change must file a single Form 3115
for both changes and enter the designat-
ed automatic accounting method change
numbers for both changes on the appro-
priate line on that Form 3115 . See section
6 .03(1)(b) of Rev . Proc . 2015-13 for in-
formation on making concurrent changes .
(4) Designated automatic account-
ing method change number . The des-
ignated automatic accounting method
change number for a change under section
16 .07(1)(a) of this revenue procedure to
use the full-inclusion method is “83 .” The
designated automatic accounting method
change number for a change under section
16 .07(1)(a) of this revenue procedure to
use the deferral method is “84 .”
(5) Contact information . For further in-
formation regarding a change under this sec-
tion, contact Peter E . Ford or Jo Lynn Ricks
at (202) 317-7003 (not a toll-free number) .
.08 Credit card cash advance fees .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for credit card
cash advance fees to a method that treats
these fees as creating or increasing orig-
inal issue discount (OID) on a pool of
credit card loans that includes the cash
advances that give rise to the fees . This
change is available only to a taxpayer that
issues credit cards allowing cardholders
to access a revolving line of credit estab-
lished by the taxpayer both to make credit
card purchase transactions and to obtain
cash advances and that, for federal income
tax purposes, does not treat the credit card
purchase transactions of its cardholders
as creating debt that is given in consider-
ation for the sale or exchange of property .
See Rev . Proc . 2005-47, 2005-2 C .B . 269,
for additional guidance relating to this
change .
(2) Other requirements . A taxpay-
er making this change must be able to
demonstrate both of the following:
(a) the amount of any credit card cash
advance fee charged to a cardholder by the
taxpayer is separately stated on the card-
holder’s account when that fee is imposed;
and
(b) under the credit card agreement
with the cardholder, no amount identi-
fied as a credit card cash advance fee is
charged for property or for specific ser-
vices performed by the taxpayer for the
benefit of the cardholder.
(3) Audit protection . Any audit pro-
tection applicable to this change under
section 8 of Rev . Proc . 2015-13, 2015-5
I .R .B . 419, is not a determination by the
Commissioner that the taxpayer is prop-
erly accounting for any OID income on
that pool of credit card loans . Thus, for
example, the IRS is not precluded from
pursuing the issue of whether, under
§ 1272(a)(6), a taxpayer is correctly ac-
counting for its OID income (including
any OID income attributable to credit
card cash advance fees) on its pool of
credit card loans .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under section 16 .08
is “94 .”
(5) Contact information . For further
information regarding a change under this
section, contact Kate Sleeth at (202) 317-
7053 (not a toll-free number) .
.09 Retainages .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer using an overall accru-
al method of accounting that wants to
change its method of accounting for treat-
ing retainages to a method consistent with
the holding in Rev . Rul . 69-314, 1969-1
C .B . 139 . A taxpayer changing its meth-
od of accounting for retainages under this
section 16 .09 must treat all retainages,
that is both receivables and payables, in
the same manner .
(b) Inapplicability . This change does
not apply to retainages (receivables and
payables) for long-term contracts that
must be accounted for under the percent-
age-of-completion method (PCM) un-
der § 460 . Nor does this change apply to
long-term contracts otherwise accounted
for under the PCM or long-term contracts
accounted for under exempt percent-
age-of-completion method or the complet-
ed contract method . For the treatment of
retainages under such methods, see Treas .
Reg . §§ 1 .460-4(b)(4)(i)(A) and 1 .460-
4(d)(3) .
(2) Manner of making change .
(a) Except as provided in section
16 .09(2)(b) of this revenue procedure, a
taxpayer changing its method of account-
ing under this section 16 .09 must take into
account a § 481(a) adjustment .
(b) For retainages received and paid in
connection with long term contracts that
are exempt construction contracts (as de-
fined in § 1.460-3(b)(1)) accounted for
using the taxpayer’s overall accrual meth-
od of accounting, this change is made on
a cut-off basis and applies only to long-
term contracts entered into on or after
the beginning of the year of change . See
§ 1 .460-1(c)(2) for a description of when
a contract is treated as “entered into .” Ac-
cordingly, a § 481(a) adjustment is neither
permitted nor required .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .09 for retainages not received under
long-term contracts is “130 .” The desig-
nated automatic method change number
for a change under this section 16 .09
for retainages received under long-term
contracts is “217 .” A taxpayer making a
change under this section 16 .09 that has
both types of retainages must file a single
Form 3115 and enter both change num-
bers on the appropriate line on Form 3115 .
(4) Contact information . For further
information regarding a change under this
section, contact Peter Cohn at (202) 317-
7011 (not a toll-free number) .
.10 Change in applicable financial
statements (AFS) for purposes of applying
certain revenue recognition methods of
accounting.
(1) Description of change .
(a) Applicability .
(i) This change applies to a taxpay-
er that: (A) receives advance payments,
as defined in Rev. Proc. 2004-34, 2004-
1 C.B. 991, as modified and clarified by
Rev . Proc . 2011-18, 2011-5 I .R .B . 443,
and Rev . Proc . 2013-29, 2013-33 I .R .B .
141, and as modified by Rev. Proc. 2011-
14, 2011-4 I .R .B . 330, (B) uses the defer-
ral method described in section 5 .02(3)
(a) of Rev . Proc . 2004-34 for including
those advance payments in gross income
in accordance with its applicable financial

November 25, 2019 1178 Bulletin No. 2019–48
statement (AFS), (C) changes the manner
in which it recognizes advance payments
in revenues in its AFS, and (D) wants to
change its method of accounting to use its
proposed method of recognizing advance
payments in revenues in its AFS for deter-
mining the extent to which advance pay-
ments are included in gross income under
Rev . Proc . 2004-34 . See also Notice 2018-
35, 2018-18 I .R .B . 520 .
(ii) This change applies to a taxpayer
that: (A) receives advance payments, as
defined in proposed § 1.451-8(b)(1); (B)
uses the deferral method described in
proposed § 1 .451-8(c); (C) changes the
manner in which it recognizes advance
payments in revenues in its AFS; and (D)
wants to change its method of accounting
to use its proposed method of recogniz-
ing advance payments in revenues in its
AFS for determining the extent to which
advance payments are included in income
under proposed § 1 .451-8(c) .
(iii) This change applies to a taxpayer
that: (A) includes amounts in income in
accordance with § 451(b); (B) changes
the manner in which the item, or portion
thereof, is taken into account in revenue
in its AFS; and (C) wants to change its
method of accounting to use the proposed
method of taking into account the item, or
portion thereof, in revenue in its AFS for
purposes of § 451(b), including, if appli-
cable, allocation of the transaction price
to performance obligations under § 451(b)
(4) .
(iv) This change applies to a taxpayer
that: (A) includes amounts in income in
accordance with proposed § 1 .451-3; (B)
changes the manner in which the item,
or portion thereof, is taken into account
as revenue in its AFS; and (C) wants to
change its method of accounting to use the
proposed method of taking into account
the item, or portion thereof, in revenue in
its AFS for purposes of proposed § 1 .451-
3, including for purposes of allocating
transaction price to performance obliga-
tions under proposed § 1 .451-3(g) .
(b) Inapplicability .
(i) Changes relating to Rev. Proc.
2004-34 . This change does not apply to:
(A) a taxpayer that uses a present meth-
od of accounting for advance payments
that is not the deferral method described in
section 5 .02(3)(a) of Rev . Proc . 2004-34 .
For example, this change does not apply
to a taxpayer that uses the full inclusion
method under section 5 .01 of Rev . Proc .
2004-34; or
(B) a taxpayer that wants to change
its method for allocating payments under
section 5 .02(4) of Rev . Proc . 2004-34 .
(ii) Changes relating to § 451(b), pro-
posed § 1.451-3, or proposed § 1.451-8 .
This change does not apply to:
(A) a taxpayer whose present method
of accounting does not use its AFS for
purposes of § 451(b), proposed § 1 .451-3,
or proposed § 1 .451-8;
(B) a change in the manner in which
the taxpayer identifies contracts or deter-
mines the transaction price, including the
inclusion and exclusion of variable con-
sideration in the transaction price, under
the New Standards, as defined in section
16 .11(1) of this revenue procedure;
(C) any change in method of account-
ing that qualifies under another automatic
change described in the List of Automatic
Changes provided in this revenue proce-
dure (or any successor); or
(D) with respect to a change described
in section 16 .10(1)(a)(ii) of this reve-
nue procedure, a taxpayer whose present
method is not the deferral method under
proposed § 1 .451-8(c) . For example, this
change does not apply to a taxpayer that
uses the full inclusion method under §
451(c) or the non-AFS deferral method
under proposed § 1 .451-8(d) .
(c) Restatements . A taxpayer’s restate-
ment of its AFS for financial accounting
presentation does not affect the propriety
of the taxpayer’s method of accounting
for revenue recognized in the prior tax-
able year(s) . For example, if the taxpay-
er uses the deferral method described in
section 5 .02(3)(a) of Rev . Proc . 2004-34
for including advance payments in gross
income in accordance with its AFS (even
if the AFS for that taxable year is later re-
stated), the taxpayer satisfies the require-
ment of section 16 .10(1)(a)(i)(B) of this
revenue procedure and may change its
method of accounting under this section
16 .10 if it is otherwise eligible .
(2) Manner of making change and
designated automatic accounting method
change number .
(a) Cut-off basis for certain changes . A
change made under section 16 .10(1)(a)(i)
or (ii) of this revenue procedure is made
on a cut-off basis and applies to items of
income received by the taxpayer on or af-
ter the beginning of the year of change .
Any advance payments received prior to
the year of change are accounted for un-
der the taxpayer’s former method of ac-
counting (that is, according to its former
AFS), and any advance payments received
in the year of change and in subsequent
taxable years are accounted for under the
taxpayer’s new method of accounting . A
taxpayer that makes a change in allocation
for purposes of § 451(c)(4)(D) must allo-
cate any payment allocations prior to the
year of change using the taxpayer’s for-
mer method of accounting . Accordingly,
a § 481(a) adjustment is neither permitted
nor required .
(b) In accordance with § 1 .446-1(e)
(3)(ii), the requirement of § 1 .446-1(e)
(3)(i) to file a Form 3115 is waived and
a statement in lieu of a Form 3115 is au-
thorized for this change . Notwithstanding
the definition of Form 3115 in section
3 .07 of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, the statement in lieu of a Form 3115
that is permitted under this section 16 .10
is considered a Form 3115 for purposes
of the automatic consent procedures of
Rev . Proc . 2015-13 . However, the require-
ment to file the duplicate copy, under sec-
tion 6 .03(1)(a) of Rev . Proc . 2015-13, is
waived . The statement attached to the tax-
payer’s return for the year of change must
include the following information:
(i) the designated automatic accounting
change number for this change, which is
“153;”
(ii) the taxpayer’s name and employer
identification (or social security number
in the case of an individual) for each ap-
plicant as would be provided had a Form
3115 been required;
(iii) the year of change (both the begin-
ning and ending dates);
(iv) for each applicant, identify the
type of applicable financial statement
used by the taxpayer, as defined in appli-
cable guidance . See, as applicable, section
4 .06 of Rev . Proc . 2004-34, § 451(b)(3),
proposed § 1 .451-8(b)(2), or proposed §
1 .451-3(c)(1);
(v) a detailed and complete descrip-
tion of each type of item affected by the
change in revenue recognition and the line
number (or schedule) where the affected
item is reflected on the federal tax return
for the year of change, and if applicable,

Bulletin No. 2019–48 1179 November 25, 2019
the section 481(a) adjustment for each
change; and
(vi) a detailed description of the basis
used for revenue recognition (that is, the
method the taxpayer uses in its applicable
financial statement or how the taxpayer
determines amounts earned, as applica-
ble) both before and after the change in
the revenue recognition policy for the ap-
plicable financial statement.
(c) Concurrent automatic change . A
taxpayer may make more than one change
under this section 16 .10 on the same
statement in lieu of a Form 3115 for the
same year of change . The taxpayer must
provide all of the information required for
each change .
(3) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) Rev . Proc . 2015-13 does not apply to
this change .
(4) No audit protection . A taxpayer
does not receive audit protection under
section 8 .01 of Rev . Proc . 2015-13 in
connection with this change . See section
8 .02(2) of Rev . Proc . 2015-13 .
(5) Special rule – advance payments
under Rev. Proc. 2004-34 .
(a) Background . Under § 446(e), a
taxpayer that changes its book method of
accounting must secure the Commission-
er’s consent before applying its new book
method of accounting for tax purposes .
See also § 1 .446-1(e)(2)(i) . Accordingly,
a taxpayer that previously elected to de-
fer advance payments under Rev . Proc .
2004-34 is required to obtain consent
under § 446(e) if the taxpayer subse-
quently changes its book method for the
deferred advance payments and wants to
use its new AFS in determining the ex-
tent to which advance payments are in-
cluded in gross income under Rev . Proc .
2004-34 . The IRS recognizes that some
taxpayers took the position that consent
under § 446(e) was not required in these
circumstances and changed their method
of accounting without properly obtaining
consent . The safe harbor described below
in section 16 .10(5)(b) of this revenue pro-
cedure is provided to reduce controversy
in this area .
(b) Safe harbor . If before January 10,
2011, a taxpayer: (i) received advance
payments, as defined in Rev. Proc. 2004-
34; (ii) used the deferral method described
in section 5 .02(3)(a) of Rev . Proc . 2004-
34 for including those advance payments
in gross income in accordance with its
AFS; (iii) changed the manner in which
advance payments are recognized in rev-
enues in its AFS; and (iv) used its new
AFS method with respect to a timely filed
original federal income tax return in deter-
mining the amount of advance payments
included in gross income under the defer-
ral method of Rev . Proc . 2004-34 without
securing the consent of the Commissioner
to that change in accordance with § 446(e)
and § 1 .446-1(e)(2)(i), the IRS will not as-
sert that the taxpayer’s present method of
accounting for advance payments is not a
proper deferral method described in sec-
tion 5 .02(3)(a) of Rev . Proc . 2004-34 sole-
ly on the ground that the taxpayer failed
to obtain the consent of the Commissioner
for that change .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .10 is “153 .”
(7) Contact information . For further
information regarding a change under
this section, contact Justin Grill or Peter
E . Ford at (202) 317-7003 (not a toll-free
number) .
.11 Changes in the timing of recogni-
tion of income due to the New Standards .
(1) Description of change . On May 28,
2014, the Financial Accounting Standards
Board (FASB) and the International Ac-
counting Standards Board (IASB) joint-
ly announced new financial accounting
standards for revenue recognition entitled
“Revenue from Contracts with Custom-
ers (Topic 606)” (New Standards) . See
FASB Update No . 2014-09, and IASB In-
ternational Financial Reporting Standard
(IFRS) 15 . Under the New Standards, a
taxpayer generally recognizes revenue for
financial accounting purposes when the
taxpayer satisfies a performance obliga-
tion by transferring a promised good or
service to a customer, as described in the
New Standards .
(2) Applicability . This change applies
to a taxpayer that wants to change its
method of accounting for the recognition
of income for federal income tax purposes
to a method under the New Standards for:
(a) identifying performance obligations,
(b) allocating transaction price to perfor-
mance obligations, and/or (c) consider-
ing performance obligations satisfied. A
taxpayer may request a change under this
section 16 .11 only if the taxpayer’s new
method of accounting is otherwise per-
missible for federal income tax purposes
and the change in method of accounting
is made for the taxable year in which the
taxpayer adopts the New Standards for fi-
nancial accounting purposes . The taxpay-
er’s allocation of transaction price to per-
formance obligations to comply with the
New Standards under this section 16 .11 is
deemed to be an allocation based on ob-
jective criteria . See section 5 .02(4)(c) of
Rev . Proc . 2004-34, 2004-1 C .B . 991, as
modified and clarified by Rev. Proc. 2011-
18, 2011-5 I .R .B . 443, and Rev . Proc .
2013-29, 2013-33 I .R .B . 141, and as mod-
ified by Rev. Proc. 2011-14, 2011-4 I.R.B.
330 .
(3) Inapplicability . This change does
not apply to:
(a) a change in the manner in which the
taxpayer identifies contracts or determines
the transaction price, including the inclu-
sion and exclusion of variable consider-
ation in the transaction price, under the
New Standards;
(b) a change in method of accounting
for recognizing income that is made in a
year that is different from the year that the
taxpayer adopts the New Standards;
(c) a change in method of accounting
that does not comply with § 451 or other
guidance;
(d) any change in method of account-
ing that qualifies under another automat-
ic change described in the List of Auto-
matic Changes provided in this revenue
procedure (or any successor), even if it is
described in section 16 .11(2) of this rev-
enue procedure, and otherwise satisfies
the requirements of paragraphs 5 .01(1)
(a)-(d) of Rev . Proc . 2015-13, 2015-5
I .R .B . 419 (or any successor) . The taxpay-
er must request such change(s) in method
of accounting by applying the automatic
change procedures in section 6 of Rev .
Proc . 2015-13 (or any successor) and the
respective section of Rev . Proc . 2019-43
(or any successor); or
(e) any change in the method of ac-
counting for income from a long-term
contract, as defined in § 460(f), unless
the long-term contract is excepted from
required use of the percentage-of-comple-
tion method by § 460(e)(1) .

November 25, 2019 1180 Bulletin No. 2019–48
(4) Time for making change . The
change under this section 16 .11 may only
be made for a taxable year ending on or
before May 10, 2021 .
(5) Manner of making change .
(a) Cut-off basis or § 481(a) adjustment .
A taxpayer making a change under this sec-
tion 16 .11 may implement the change with
either a § 481(a) adjustment as provided in
sections 7 .02 and 7 .03 of Rev . Proc . 2015-
13, or on a cut-off basis . If the taxpayer im-
plements the change on a cut-off basis, (i)
the taxpayer must allocate any payment al-
locations prior to the year of change using
the taxpayer’s former method of account-
ing, (ii) all changes made under this section
16 .11 must be implemented using a cut-off
basis, and (iii) a § 481(a) adjustment is nei-
ther permitted nor required . Notwithstand-
ing anything to the contrary in this section
16 .11(5)(a), if a taxpayer is a member of
a consolidated group (within the meaning
of § 1 .1502-1 (h)), then the member must
implement all changes with respect to its
intercompany transactions (within the
meaning of § 1 .1502-13 (b)(1)(i)) under
this section 16 .11 on a cut-off basis and can
apply the first two sentences of this section
16 .11(5)(a) to all other transactions . See §
1 .1502-17(b)(2); section 7 .02 of Rev . Proc .
2015-13 .
(b) Reduced filing requirement . A tax-
payer making a change under this section
16 .11 is required to complete only the fol-
lowing information on Form 3115 (Rev .
December 2018):
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,16c,
and 19; and
(v) Part IV, all lines . For a taxpayer
making a change under this section 16 .11
using a § 481(a) adjustment, the statement
required for Line 26 of Form 3115 should
list a description of each change, the §
481(a) adjustment for each change (or a
statement that the change is being made
on a cut-off basis) and, if applicable, a de-
scription of where the item’s § 481(a) ad-
justment is reflected on the federal income
tax return (line number (or schedule)) .
In addition, the requirement to file the
duplicate copy, under section 6 .03(1)(a) of
Rev . Proc . 2015-13, is waived .
(6) Under examination – certain au-
dit protection exceptions temporarily
inapplicable. For a taxpayer’s first, sec-
ond, or third taxable year beginning af-
ter December 31, 2017, section 8 .02(1)
of Rev . Proc . 2015-13 does not apply to
a change in method of accounting made
under section 16 .11(2) of this revenue
procedure if the method of accounting to
be used complies with the proposed regu-
lations under § 1 .451-3 and/or § 1 .451-8 .
However, section 8 .02(1) of Rev . Proc .
2015-13 continues to apply for purposes
of determining the § 481(a) adjustment
period for a positive § 481(a) adjustment
provided in section 7 .03(3)(b) of Rev .
Proc . 2015-13 .
(7) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13 does not apply to
this change for a taxable year ending on or
before May 10, 2021 .
(8) No ruling on method used . The
consent granted under section 9 of Rev .
Proc . 2015-13 for a change made under
this section 16 .11 is not a determination
by the Commissioner that the new method
of accounting is a permissible method of
accounting and does not create any pre-
sumption that the allocation method is a
permissible method of accounting under
any provision of the Code . Further, the
consent granted under section 9 of Rev .
Proc . 2015-13 for a change made under
this section 16 .11 is not a determination
that the amount of income included in tax-
able income using an allocation method
described in the New Standards is correct .
The director will ascertain whether the
new method of accounting is a permissi-
ble method of accounting and whether the
allocation method is permissible under the
Code (for example, a method that is per-
mitted under § 451) .
(9) Concurrent automatic change . A
taxpayer that wants to make one or more
changes in method of accounting under
this section 16.11 may file a single Form
3115 that includes all of the changes, must
separately state the § 481(a) adjustment
for each change made under this section,
and may not net the § 481(a) adjustments
with § 481(a) adjustments from other
changes .
(10) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
16 .11 is “231 .”
(11) Contact information . For further
information regarding a change under this
section, contact Peter E . Ford or Jo Lynn
Ricks at (202) 317-7003 (not a toll free
number) .
.12 Changes in the timing of income
recognition under § 451(b) or proposed
§ 1.451-3, and changes relating to advance
payments under proposed § 1.451-8 .
(1) Description of change . This change
applies to an accrual method taxpayer with
an applicable financial statement (AFS) that
wants to make certain changes in method
of accounting described in section 16 .12(2)
(a) of this revenue procedure for taxable
years beginning after December 31, 2017,
or, in the case of a specified credit card fee
(as defined in proposed § 1.451-3(i)(2)), for
taxable years beginning after December 31,
2018 . This change also applies to a taxpayer
without an AFS that wants to make certain
changes in method of accounting described
in section 16 .12(2)(b) of this revenue pro-
cedure for a taxable year beginning after
December 31, 2017 . For purposes of this
section 16.12, the term AFS is defined un-
der § 451(b)(3), or for a taxpayer making a
change to apply proposed § 1 .451-3 or pro-
posed § 1.451-8, the term AFS is defined in
proposed § 1 .451-3(c)(1) .
(2) Applicability .
(a) Taxpayer with an AFS . This change
applies to a taxpayer with an AFS that:
(i) wants to change to a method of ac-
counting that treats an item of gross in-
come, or portion thereof, as meeting the
all events test no later than when such
item, or portion thereof, is taken into ac-
count as revenue in its AFS under § 451(b)
(1)(A);
(ii) is not adopting the New Standards
(as defined in section 16.11(1) of this rev-
enue procedure) for the year of change,
and wants to allocate the transaction price
to performance obligations under § 451(b)
(4);
(iii) wants to change to a method of ac-
counting that complies with the proposed
regulations under § 1 .451-3 (including a
change for a specified credit card fee un-
der proposed §§ 1 .451-3(i) and 1 .1275-
2(l)); or
(iv) wants to change to a method of ac-
counting that complies with the proposed
regulations under § 1 .451-8(c) .

Bulletin No. 2019–48 1181 November 25, 2019
(b) Taxpayer without an AFS . This
change applies to a taxpayer that does not
have an AFS and that wants to change to a
method of accounting that complies with
the proposed regulations under § 1 .451-
8(d) .
(3) Inapplicability . This change does
not apply to:
(a) a taxpayer that wants to make a
change for federal income tax purposes to
a method that adopts the New Standards,
as provided in section 16 .11 of this rev-
enue procedure (for example, a change
to comply with § 451(b)(4), proposed §
1 .451-3(g), or proposed § 1 .451-8(c)(6));
(b) a taxpayer that wants to make a
change in method of accounting to a meth-
od described in § 451(b)(2);
(c) a taxpayer without an AFS that
wants to change to defer income based on
earned income under proposed § 1 .451-
8(d)(4)(ii) determined using the follow-
ing: (i) a statistical basis if adequate data
are available to the taxpayer; or (ii) the use
of any other basis that in the opinion of the
Commissioner results in a clear reflection
of income; or
(d) a taxpayer that wants to make a
change in method of accounting for spec-
ified fees (as defined in proposed § 1.451-
3(i)(2)) other than specified credit card
fees .
(4) Manner of making change .
(a) Short Form 3115 . A taxpayer mak-
ing a change under this section 16 .12 is
required to complete only the following
information on Form 3115 (Rev . Decem-
ber 2018):
(i) The identification section of page 1
(above Part I);
(ii) The signature section at the bottom
of page 1;
(iii) Part I;
(iv) Part II, all lines except lines 13,16c,
and 19; and
(v) Part IV, all lines . For a taxpay-
er making a change under this section
16 .12, the statement required for Line
26 of Form 3115 should list the § 481(a)
adjustment(s), and a description of where
the § 481(a) adjustment is reflected on the
federal income tax return (line number or
schedule) .
In addition, the requirement to file the
duplicate copy, under section 6 .03(1)(a) of
Rev . Proc . 2015-13, 2015-5 I .R .B . 419, is
waived .
(b) Special rules relating to § 481(a)
adjustment or cut-off basis .
(i) Section 481(a) adjustment period
for changes relating to specified credit
card fees . In the case of income from a
specified credit card fee, the § 481(a) ad-
justment period for any qualified change
in method of accounting described in
this section 16 .12(4)(b)(i) is six taxable
years (year of change and next five tax-
able years) . For purposes of the preceding
sentence, a qualified change in method
of accounting is a change in method of
accounting for income from a specified
credit card fee to a method that is required
by § 451(b), as added by section 13221 of
the Tax Cuts and Jobs Act (TCJA), Pub-
lic Law 115-97, 131 Stat . 2054 (Dec . 22,
2017), for such income, but only for the
taxpayer’s first taxable year beginning af-
ter December 31, 2018 . Section 16 .12(4)
(b)(ii) of this revenue procedure may not
be used for a change relating to specified
credit card fees .
(ii) Cut-off basis or § 481(a) adjust-
ment .
(A) Cut-off basis or § 481(a) adjust-
ment for changes made under section
16.12(2)(a)(i) or (iii) of this revenue pro-
cedure . Except as otherwise provided
in this section 16 .12(4)(b)(ii), a taxpay-
er making a change described in section
16 .12(2)(a)(i) or (iii) of this revenue pro-
cedure may implement the change with
either a § 481(a) adjustment as provided
in sections 7 .02 and 7 .03 of Rev . Proc .
2015-13 or on a cut-off basis provided
the taxpayer is also making a concurrent
method change under section 16 .11 of this
revenue procedure . See section 16 .12(8)
(b) of this revenue procedure for informa-
tion on making this concurrent change . A
taxpayer described in section 16 .12(4)(c)
(i)(B) of this revenue procedure that uses
the streamlined procedures provided in
section 16 .12(4)(c) of this revenue proce-
dure may not make a change in method of
accounting on a cut-off basis . If the tax-
payer makes a concurrent change under
section 16 .11 of this revenue procedure
and implements the change under this sec-
tion 16 .12(4)(b)(ii) of this revenue pro-
cedure on a cut-off basis, (1) the change
applies to contracts entered into on or after
the beginning of the year of change, (2) all
changes made under section 16 .12(2)(a)(i)
or (iii) of this revenue procedure must be
implemented using a cut-off basis, and (3)
a § 481(a) adjustment is neither permitted
nor required . Notwithstanding anything
to the contrary in this section 16 .12(4)
(b)(ii)(A), if a taxpayer is a member of
a consolidated group (within the mean-
ing of § 1 .1502–1(h)), then the member
must implement all changes under this
section 16 .12 with respect to its intercom-
pany transactions (within the meaning of
§ 1 .1502–13(b)(1)(i)) under this section
16 .12(4)(b)(ii) on a cut-off basis .
(B) Cut-off basis or § 481(a) adjust-
ment for changes to use proposed § 1.451-
8(c) . Except as otherwise provided in this
section 16 .12(4)(b)(ii), a taxpayer making
a change described in section 16 .12(2)(a)
(iv) of this revenue procedure may imple-
ment the change with either a § 481(a)
adjustment as provided in sections 7 .02
and 7 .03 of Rev . Proc . 2015-13 or on a
cut-off basis . A taxpayer described in
section 16 .12(4)(c)(i)(B) of this revenue
procedure that uses the streamlined pro-
cedures provided in section 16 .12(4)(c)
of this revenue procedure may not make a
change in method of accounting on a cut-
off basis . If the taxpayer implements the
change on a cut-off basis, (1) the change
applies to contracts entered into on or after
the beginning of the year of change, (2) all
changes made under this section 16 .12 to
adopt proposed § 1 .451-8(c) must be im-
plemented using a cut-off basis, and (3) a
§ 481(a) adjustment is neither permitted
nor required . Notwithstanding anything
to the contrary in this section 16 .12(4)
(b)(ii)(B), if a taxpayer is a member of a
consolidated group (within the meaning
of § 1 .1502–1(h)), then the member must
implement all changes to adopt proposed
§ 1 .451-8(c) with respect to its intercom-
pany transactions (within the meaning of
§ 1 .1502–13(b)(1)(i)) under this section
16 .12(4)(b)(ii)(B) on a cut-off basis .
(c) Streamlined method change proce-
dures for certain taxpayers .
(i) Applicability . The procedures de-
scribed in this section 16 .12(4)(c) may be
used by a taxpayer to make a change in
method of accounting described in sec-
tion 16 .12(2)(a)(i) or (ii) of this revenue
procedure in the taxpayer’s first taxable
year beginning after December 31, 2017 .
The procedures described in this section
16 .12(4)(c) may also be used by a tax-
payer to make a change in method of ac-

November 25, 2019 1182 Bulletin No. 2019–48
counting described in section 16 .12(2)(a)
(iii), 16 .12(2)(a)(iv), or 16 .12(2)(b) of this
revenue procedure in the taxpayer’s first
or second taxable year beginning after
December 31, 2017 . A taxpayer is permit-
ted to use the streamlined method change
procedures in this section 16 .12(4)(c) if
the taxpayer meets one of the following
requirements:
(A) the taxpayer, other than a tax shel-
ter (as defined in § 448(d)(3)), meets the §
448(c) gross receipts test (a “small busi-
ness taxpayer”) . The taxpayer meets the §
448(c) gross receipts test if the taxpayer
has average annual gross receipts for the
three prior taxable years of $25,000,000
or less (adjusted for inflation); or
(B) the taxpayer is making one or more
changes under section 16 .12(2) of this
revenue procedure, and the § 481(a) ad-
justment required by each of the changes
is zero . A taxpayer making more than one
change in method of accounting under
section 16 .12(2) of this revenue procedure
is not permitted to net the § 481(a) adjust-
ments to determine if the taxpayer meets
the requirements to use the streamlined
method change procedures . See section
16 .12(8)(a) of this revenue procedure for
more information on making a permitted
concurrent change .
(ii) Inapplicability . In addition to the
inapplicability rules provided in section
16 .12(3) of this revenue procedure, a
taxpayer may not use these streamlined
method change procedures if the taxpay-
er wants to make a concurrent automatic
change described in section 16 .12(8)(b) of
this revenue procedure .
(iii) No Form 3115 required . In ac-
cordance with § 1 .446-1(e)(3)(ii), the
requirement of § 1.446-1(e)(3)(i) to file
a Form 3115 is waived for a taxpayer
making a change in method of accounting
under this section 16 .12 using the stream-
lined method change procedures . Thus,
a taxpayer using the streamlined method
change procedures is not required to file a
Form 3115 and is not required to attach a
separate statement when making a change
under this section 16 .12 .
(5) Certain eligibility rules inapplica-
ble .
(a) In general . Except as otherwise
provided in this section 16 .12(5), the el-
igibility rule in section 5 .01(1)(f) of Rev .
Proc . 2015-13 does not apply to a change
under this section 16 .12 for a taxpayer’s
first, second, or third taxable year begin-
ning after December 31, 2017 .
(b) Changes related to specified cred-
it card fees . For a change related to in-
come from a specified credit card fee,
the eligibility rule in section 5 .01(1)(f) of
Rev . Proc . 2015-13 does not apply to this
change for a taxpayer’s first, second, or
third taxable year beginning after Decem-
ber 31, 2018 .
(c) Changes made under the stream-
lined method change procedures . For a
change made using the streamlined proce-
dures of section 16 .12(4)(c) of this reve-
nue procedure for a change in method of
accounting described in section 16 .12(2)
(a)(i) or (ii) of this revenue procedure,
the eligibility rule in section 5 .01(f) of
Rev . Proc . 2015-13 does not apply to this
change for a taxpayer’s first taxable year
beginning after December 31, 2017 . For
a change made using the streamlined pro-
cedures of section 16 .12(4)(c) of this rev-
enue procedure for a change in method of
accounting described in section 16 .12(2)
(a)(iii), 16 .12(2)(a)(iv), or 16 .12(2)(b) of
this revenue procedure, the eligibility rule
in section 5 .01(f) of Rev . Proc . 2015-13
does not apply to this change for the tax-
payer’s first or second taxable year begin-
ning after December 31, 2017 .
(6) Audit protection .
(a) Streamlined procedures . A taxpayer
making a change in method of accounting
under this section 16 .12 using the stream-
lined method change procedures provided
in section 16 .12(4)(c) of this revenue pro-
cedure does not receive audit protection
under section 8 .01 of Rev . Proc . 2015-13 .
(b) Taxpayers under examination .
(i) In general – certain audit protection
exception temporarily inapplicable . Ex-
cept as otherwise provided in this section
16.12(6)(b), for a taxpayer’s first, second,
or third taxable year beginning after De-
cember 31, 2017, the audit protection rule
in section 8 .02(1) of Rev . Proc . 2015-13
does not apply to a change in method of
accounting made under section 16 .12(2)
(a)(iii) or (iv) of this revenue procedure .
However, section 8 .02(1) of Rev . Proc .
2015-13 continues to apply for purposes
of determining the § 481(a) adjustment
period for a positive § 481(a) adjustment
provided in section 7 .03(3)(b) of Rev .
Proc . 2015-13 . This paragraph applies to a
taxpayer under examination that does not
use the streamlined procedures described
in section 16 .12(4)(c) of this revenue pro-
cedure .
(ii) Changes related to specified credit
card fees . For a change related to income
from a specified credit card fee, for a tax-
payer’s first, second, or third taxable year
beginning after December 31, 2018, the
audit protection rule in section 8 .02(1) of
Rev . Proc . 2015-13 does not apply to a
taxpayer that makes a change in method of
accounting described in section 16 .12(2)
(a)(iii) of this revenue procedure . Howev-
er, for a taxpayer’s second or third taxable
year beginning after December 31, 2018,
section 8 .02(1) of Rev . Proc . 2015-13 con-
tinues to apply for purposes of determin-
ing the § 481(a) adjustment period for a
positive § 481(a) adjustment provided in
section 7 .03(3)(b) of Rev . Proc . 2015-13 .
(7) No ruling on method used . The con-
sent granted under section 9 of Rev . Proc .
2015-13 for a change made under this
section 16 .12 for a change in method of
accounting described in section 16 .12(2)
(a)(i) or (ii) of this revenue procedure is
not a determination by the Commission-
er that the new method of accounting is a
permissible method of accounting under §
451 and does not create a presumption that
the allocation method used under § 451(b)
(4) is a permissible method of accounting .
The director may ascertain whether the
new method of accounting is a permissi-
ble method of accounting under § 451 and
whether the allocation method is permissi-
ble under § 451(b)(4) .
(8) Concurrent automatic changes .
(a) In general . A taxpayer that wants to
make one or more concurrent changes in
method of accounting under this section
16.12 may file a single Form 3115 that
includes all of the changes, must separate-
ly state the § 481(a) adjustment for each
change, if applicable, and may not net the
§ 481(a) adjustment for a change with the
§ 481(a) adjustment from another change .
However, a taxpayer that makes a concur-
rent change in method of accounting to
allocate transaction price to performance
obligations under section 16 .12(2)(a)(ii),
(iii), or (iv) of this revenue procedure is
required to make the allocation change be-
fore a change to a method under § 451(b)
(1)(A), the AFS income inclusion rule in
proposed § 1 .451-3, or the deferral meth-

Bulletin No. 2019–48 1183 November 25, 2019
od described in proposed § 1 .451-8(c),
as applicable . For example, a taxpayer
that makes a change under both section
16 .12(2)(a)(i) and (2)(a)(ii) of this reve-
nue procedure is required to implement
the change under section 16 .12(2)(a)(ii)
of this revenue procedure before making
the change under section 16 .12(2)(a)(i) of
this revenue procedure .
(b) Concurrent change in the timing
of recognition of income due to the New
Standards . Except as provided in section
16 .12(4)(c)(i) of this revenue procedure,
a taxpayer that wants to make a change
under section 16 .12(2)(a)(i), (iii), or (iv)
of this revenue procedure and a change
under section 16 .11 of this revenue pro-
cedure for the same year of change may
file a single Form 3115 for both changes
and enter the designated automatic ac-
counting method change number for both
changes on the appropriate line of Form
3115 . A taxpayer that makes both changes
is required to make the change under sec-
tion 16 .11 of this revenue procedure be-
fore making the change under this section
16 .12(2)(a)(i), (iii), or (iv), as applicable .
(9) Designated automatic account-
ing method change number . The desig-
nated automatic method change number
for a change under section 16 .12(2)(a)
(i) or (ii) of this revenue procedure is
“239 .” The designated automatic method
change number for a change under section
16 .12(2)(a)(iii), (iv), or 16 .12(2)(b) of this
revenue procedure (that is, a change to
comply with the proposed regulations un-
der § 1 .451-3 or § 1 .451-8) is “242 .”
(10) Contact information . For further
information regarding a change under this
section, contact Peter E . Ford or Jo Lynn
Ricks at (202) 317-7003 (not toll-free
number) . For further information regard-
ing a change under this section for OID,
contact Charles W . Culmer at (202) 317-
4528 (not a toll-free number) .
SECTION 17 . OBLIGATIONS ISSUED
AT DISCOUNT (§ 454)
.01 Series E, EE or I U.S. savings
bonds .
(1) Description of change . This change
applies to a taxpayer that uses the over-
all cash receipts and disbursements (cash)
method of accounting and that wants to
change its method of accounting for inter-
est income on Series E, EE, or I U .S . sav-
ings bonds . However, this change only ap-
plies to a taxpayer that previously made an
election under § 454 to report as interest
income the increase in redemption price
on a bond occurring in a taxable year,
and that now wants to report this income
in the taxable year in which the bond is
redeemed, disposed of, or finally matures,
whichever is earliest .
(2) Manner of making change and
designated automatic accounting method
change number .
(a) This change is made on a cut-off
basis and is effective for any increase in
redemption price occurring after the be-
ginning of the year of change for all Series
E, EE and I U .S . savings bonds held by the
taxpayer on or after the beginning of the
year of change . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired .
(b) In accordance with § 1 .446-1(e)
(3)(ii), the requirement of § 1 .446-1(e)
(3)(i) to file a Form 3115 is waived and
a statement in lieu of a Form 3115 is au-
thorized for this change . Notwithstanding
the definition of Form 3115 in section 3.07
of Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
the statement in lieu of a Form 3115 that
is permitted under this section 17 .01 is
considered a Form 3115 for purposes of
the automatic consent procedures of Rev .
Proc . 2015-13 . However, the requirement
to file the Duplicate copy, under sec-
tion 6 .03(1)(a) of Rev . Proc . 2015-13, is
waived . The statement must include the
following information:
(i) the designated automatic accounting
method change number for this change,
which is “131”;
(ii) the taxpayer’s name and employer
identification number or social security
number, as applicable;
(iii) the year of change (both the begin-
ning and ending dates);
(iv) the Series E, EE or I U .S . savings
bonds for which this change in accounting
method is requested;
(v) a statement that the taxpayer will
report all interest on any U .S . savings
bonds acquired during or after the year of
change when the interest is realized upon
disposition, redemption, or final maturity,
whichever is earliest; and
(vi) a statement that the taxpayer will
report all interest on the U .S . savings
bonds acquired before the year of change
when the interest is realized upon disposi-
tion, redemption, or final maturity, which-
ever is earliest, with the exception of any
interest income previously reported in pri-
or taxable years .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
17 .01 is “131 .”
(4) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
SECTION 18 . PREPAID
SUBSCRIPTION INCOME (§ 455)
.01 Prepaid subscription income .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that wants to
change its method of accounting for pre-
paid subscription income to the method
described in § 455 and the regulations
thereunder, including an eligible taxpayer
that wants to make the “within 12 months”
election under § 1 .455-2 .
(2) Manner of making change and
designated automatic accounting method
change number .
(a) This change is made on a cut-off
basis and applies only to prepaid subscrip-
tion income received on or after the be-
ginning of the year of change . The taxpay-
er must continue to account for prepaid
subscription income received prior to the
year of change under the taxpayer’s pres-
ent method of accounting . Accordingly, a
§ 481(a) adjustment is neither permitted
nor required .
(b) In accordance with § 1 .446-1(e)(3)
(ii), the requirement in § 1.455-6 to file a
statement requesting consent is satisfied
by filing a short Form 3115 for a change
under this section 18 .01 . The short Form
3115 must include the following informa-
tion:
(i) the identification section of page 1
(above Part I);
(ii) the signature section at the bottom
of page 1;
(iii) Part I, line 1(a);
(iv) the information described in
§ 1 .455-6(a), as required by § 1 .455-6(b);
and

November 25, 2019 1184 Bulletin No. 2019–48
(v) if the taxpayer wants to make
a “within 12 months” election under
§ 1 .455-6(c), the information described in
section § 1 .455-6(c)(2) .
(c) The consent granted in section 9
of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, satisfies the consent required under
§ 455(c)(3) and § 1 .455-6(b) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
18 .01 is “132 .”
(4) Contact information . For further
information regarding a change under this
section, contact Patrick Clinton at (202)
317-7005 (not a toll-free number) .
SECTION 19 . SPECIAL RULES FOR
LONG-TERM CONTRACTS (§ 460)
.01 Small business taxpayer exceptions
from requirement to account for certain
long-term contracts under § 460 or to
capitalize costs under § 263A for certain
home construction contracts.
(1) Description of Change . This change
applies to a taxpayer that, beginning in
the year of change, qualifies as a small
business taxpayer, as defined in section
15 .18(5)(a) of this revenue procedure, and
(a) wants to change its method of account-
ing for exempt long-term construction
contracts described in § 460(e)(1)(B) from
the percentage-of-completion method of
accounting described in § 1 .460-4(b) to
an exempt contract method of accounting
described in § 1 .460-4 (c), or (b) chooses
to stop capitalizing costs under § 263A for
home construction contracts defined in §
460(e)(1)(A) .
(2) Applicability . This change applies
to exempt long-term contracts described
in § 460(e)(1) that are entered into after
December 31, 2017, in taxable years end-
ing after December 31, 2017 .
(3) Inapplicability . A taxpayer can use
a method of accounting for its exempt
long-term contracts that is different from
the method used for contracts that are not
exempt . Thus, a taxpayer must use the
percentage-of-completion method of ac-
counting for nonresidential long-term con-
struction contracts entered into in the first
taxable year that the taxpayer fails the §
448(c) gross receipts test, but must contin-
ue to use its exempt contract method of ac-
counting for its existing exempt long-term
construction contracts . Similarly, in the
taxable year that a taxpayer first meets the §
448(c) gross receipts test, the taxpayer can
use a permissible exempt contract method
of accounting for long-term construction
contracts it expects to complete within two
years . Rev . Rul . 92-28, 1992-1 C .B . 153 .
Accordingly, only a taxpayer who pre-
viously adopted the percentage-of-com-
pletion method of accounting for exempt
long-term construction contracts and wants
to change to another permissible exempt
contract method of accounting is required
to request consent to change under this sec-
tion 19 .01 . Similarly, a taxpayer that meets
the § 448(c) gross receipts test and enters
into a home construction contract that it ex-
pects to complete within two years requires
consent to change its method of accounting
to not capitalize costs under § 263A only if
the taxpayer has previously applied § 263A
to home construction contracts exempt
from the capitalization requirement under
§ 460(e)(1) .
(4) Manner of making change . This
change is made on a cut-off basis and
applies only to long-term construction
contracts entered into after December 31,
2017, in taxable years ending after De-
cember 31, 2017 . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired .
(5) Certain eligibility rule temporar-
ily inapplicable . The eligibility rule in
section 5 .01(1)(f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, does not apply to this
change for a taxpayer’s first, second, or
third taxable year ending after December
31, 2017 .
(6) Reduced filing requirement . A tax-
payer is required to complete only the fol-
lowing information on Form 3115 (Rev .
December 2018) to make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except line 16;
(e) Part IV, line 25; and
(f) Schedule D, Part I .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
19 .01 is “236 .”
(8) Contact information . For further
information regarding changes under this
section, contact Innessa Glazman at (202)
317-7006 (not a toll-free number) .
SECTION 20 . TAXABLE YEAR
INCURRED (§ 461)
In general . Applicable provisions of
the Code, regulations and other guidance
published in the Internal Revenue Bul-
letin may prescribe the manner in which
a taxpayer takes into account a liability
that has been incurred . For example, for
a taxpayer with inventories and subject
to § 263A, the taxpayer must include di-
rect and indirect costs in inventory costs,
which may be recovered through cost of
goods sold . See § 1 .263A-1(e)(2)(i)(B) .
A taxpayer may not rely on any provision
in this section 20 to take a current year
deduction if another applicable provision
requires the taxpayer to take the liability
into account in a year other than the year
incurred .
.01 Timing of incurring liabilities for
employee compensation .
(1) Self-insured employee medical ben-
efits .
(a) Description of change .
(i) Applicability . This change applies to
a taxpayer using an overall accrual meth-
od of accounting that wants to change its
method of accounting for self-insured li-
abilities (including any amounts not cov-
ered by insurance, such as a “deductible”
amount under an insurance policy) relating
to employee medical expenses (including
liabilities resulting from medical services
provided to retirees and to employees who
have filed claims under a workers’ com-
pensation act) that are not paid from a
welfare benefit fund within the meaning
of § 419(e) to a method as follows:
(A) If the taxpayer has a liability to
pay an employee for medical expenses in-
curred by the employee, the taxpayer will
treat the liability as incurred in the taxable
year in which the employee files the claim
with the employer . See United States v.
General Dynamics Corp., 481 U .S . 239
(1987), 1987-2 C .B . 134 .
(B) If the taxpayer has a liability to pay
a 3
rd
party for medical services provided to
its employees, the taxpayer will treat the
liability as incurred in the taxable year in
which the services are provided .

Bulletin No. 2019–48 1185 November 25, 2019
(ii) Inapplicability . This change does
not apply to a taxpayer that is required
under § 263A and the regulations there-
under to capitalize the costs with respect
to which the taxpayer wants to change its
method of accounting under this section
20 .01(1) if the taxpayer is not capitaliz-
ing these costs, unless the taxpayer con-
currently changes its method to capitalize
these costs in conjunction with a change
to a UNICAP method under section 12 .01,
12 .02, 12 .08, or 12 .12 of this revenue pro-
cedure (as applicable) .
(b) Concurrent automatic change . A
taxpayer making both this change and a
change to a UNICAP method described in
section 20 .01(1)(a)(ii) of this revenue pro-
cedure under section 12 .01, 12 .02, 12 .08,
or 12 .12 of this revenue procedure (as
applicable) for the same year of change
should file a single Form 3115 for both
changes, in which case the taxpayer must
enter the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13, 2015-5 I .R .B . 419, for information on
making concurrent changes .
(c) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .01(1) is “42 .”
(2) Bonuses .
(a) Description of change .
(i) Applicability . This change applies to
a taxpayer using an overall accrual meth-
od of accounting that wants to change its
method of accounting to treat bonuses as
incurred in the taxable year in which all
events have occurred that establish the
fact of the liability to pay a bonus and the
amount of the liability can be determined
with reasonable accuracy (see § 1 .446-
1(c)(1)(ii)). specifically, a taxpayer may
change its method of accounting under
this section 20 .01(2) to one of the follow-
ing methods:
(A) If all the events that establish the
fact of the liability to pay a bonus have
occurred by the end of the taxable year in
which the related services are provided,
and the bonus is received by the employee
no later than the 15
th
day of the 3
rd
calen-
dar month after the end of the taxable year
in which the related services are provided,
the taxpayer will treat the bonus liability
as incurred in that taxable year . See Rev .
Rul. 55-446, 1955-2 C.B. 531, as modified
by Rev . Rul . 61-127, 1961-2 C .B . 36 .
(B) If all the events that establish the
fact of the liability to pay a bonus occur
in the taxable year subsequent to the tax-
able year in which the related services are
provided, the taxpayer will treat the bonus
liability as incurred in such subsequent
taxable year .
(ii) Inapplicability . This change does
not apply to a taxpayer that is required
under § 263A and the regulations there-
under to capitalize the costs with respect
to which the taxpayer wants to change its
method of accounting under this section
20 .01(2) if the taxpayer is not capitaliz-
ing these costs, unless the taxpayer con-
currently changes its method to capitalize
these costs in conjunction with a change
to a UNICAP method under section 12 .01,
12 .02, 12 .08, or 12 .12 of this revenue pro-
cedure (as applicable) .
(b) Concurrent automatic change . A
taxpayer making both this change and a
change to a UNICAP method described in
section 20 .01(2)(a)(ii) of this revenue pro-
cedure under section 12 .01, 12 .02, 12 .08,
or 12 .12 of this revenue procedure (as
applicable) for the same year of change
should file a single Form 3115 for both
changes, in which case the taxpayer must
enter the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes .
(c) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .01(2) is “133 .”
(3) Vacation pay, sick pay, and sever-
ance pay .
(a) Description of change .
(i) Applicability . This change applies to
a taxpayer using an overall accrual meth-
od of accounting that wants to change its
method of accounting to treat vacation pay,
sick pay, and severance pay as incurred in
the taxable year in which all events have
occurred that establish the fact of the lia-
bility to pay vacation pay, sick pay, and
severance pay and the amount of the lia-
bility can be determined with reasonable
accuracy (see § 1 .446-1(c)(1)(ii)) . specif-
ically, a taxpayer may change its method
of accounting under this section 20 .01(3)
to one of the following methods:
(A) If all the events that establish the
fact of the liability to pay vacation pay,
sick pay, and severance pay have oc-
curred by the end of the taxable year in
which the related services are provided,
the vacation pay, sick pay, and severance
pay vests in the taxable year the related
services are provided, and the vacation
pay, sick pay, and severance pay is re-
ceived by the employee no later than the
15
th
day of the 3
rd
calendar month after
the end of the taxable year in which the
related services are provided, the taxpay-
er will treat the vacation pay, sick pay,
and severance pay liability as incurred in
the taxable year in which the related ser-
vices are provided .
(B) If all the events that establish the
fact of the liability to pay vacation pay,
sick pay, and severance pay occur in the
taxable year subsequent to the taxable
year in which the related services are pro-
vided, the taxpayer will treat the vacation
pay, sick pay, and severance pay liability
as incurred in such subsequent taxable
year .
(ii) Inapplicability . This change does
not apply to a taxpayer that is required
under § 263A and the regulations there-
under to capitalize the costs with respect
to which the taxpayer wants to change its
method of accounting under this section
20 .01(3) if the taxpayer is not capitaliz-
ing these costs, unless the taxpayer con-
currently changes its method to capitalize
these costs in conjunction with a change
to a UNICAP method under section 12 .01,
12 .02, 12 .08, or 12 .12 of this revenue pro-
cedure (as applicable) .
(b) Concurrent automatic change . A
taxpayer making both this change and a
change to a UNICAP method described in
section 20 .01(3)(a)(ii) of this revenue pro-
cedure under section 12 .01, 12 .02, 12 .08,
or 12 .12 of this revenue procedure (as
applicable) for the same year of change
should file a single Form 3115 for both
changes, in which case the taxpayer must
enter the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes .

November 25, 2019 1186 Bulletin No. 2019–48
(c) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .01(3) is “134 .”
(4) Contact information . For further
information regarding a change under this
section, contact Alicia Lee-Won or Joanna
Trebat at (202) 317-7003 (not a toll-free
numbers) .
.02 Timing of incurring liabilities for
real property taxes, personal property tax-
es, state income taxes, and state franchise
taxes .
(1) Background . A taxpayer using an
overall accrual method of accounting
generally incurs a liability in the taxable
year that all the events have occurred
that establish the fact of the liability, the
amount of the liability can be determined
with reasonable accuracy, and economic
performance has occurred with respect to
the liability . See § 1 .446-1(c)(1)(ii) . Un-
der § 1 .461-4(g)(6), if the liability of the
taxpayer is to pay a tax, economic perfor-
mance occurs as the tax is paid to the gov-
ernment authority that imposed the tax .
(2) Description of change .
(a) Applicability . This change applies to
a taxpayer using an overall accrual meth-
od of accounting that wants to change its
method of accounting to:
(i) treat liabilities (for which the all
events test of § 461(h)(4) is otherwise
met) for real property taxes, personal
property taxes, state income taxes, or state
franchise taxes as incurred in the taxable
year in which the taxes are paid, under
§ 461 and § 1 .461-4(g)(6);
(ii) account for real property taxes, per-
sonal property taxes, state income taxes,
or state franchise taxes under the recurring
item exception method under § 461(h)(3)
and § 1 .461-5(b)(1); or
(iii) revoke an election under § 461(c)
(ratable accrual election) .
(b) Inapplicability . This change does
not apply to:
(i) a taxpayer’s liability for a tax sub-
ject to the limitation on acceleration of ac-
crual of taxes under § 461(d); or
(ii) a taxpayer that is required under
§ 263A and the regulations thereunder to
capitalize the costs with respect to which
the taxpayer wants to change its method
of accounting under this section 20 .02 if
the taxpayer is not capitalizing these costs,
unless the taxpayer concurrently chang-
es its method to capitalize these costs in
conjunction with a change to a UNICAP
method under section 12 .01, 12 .02, 12 .08,
or 12 .12 of this revenue procedure (as ap-
plicable) .
(3) Concurrent automatic change . A
taxpayer making both this change and a
change to a UNICAP method described in
section 20 .02(2)(b)(ii) of this revenue pro-
cedure under section 12 .01, 12 .02, 12 .08,
or 12 .12 of this revenue procedure (as
applicable) for the same year of change
should file a single Form 3115 for both
changes, in which case the taxpayer must
enter the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13, 2015-5 I .R .B . 419, for information on
making concurrent changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .02 is “43 .”
(5) Contact information . For further
information regarding a change under this
section, contact Christine Merson at (202)
317-5100 (not a toll-free number) .
.03 Timing of incurring liabilities un-
der a workers’ compensation act, tort,
breach of contract, or violation of law .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer using an overall accrual
method of accounting that wants to change
its method of accounting for self-insured
liabilities (including any amounts not cov-
ered by insurance, such as a “deductible”
amount under an insurance policy) arising
under any workers’ compensation act or
out of any tort, breach of contract, or vi-
olation of law, to treating the liability for
the workers’ compensation, tort, breach
of contract, or violation of law as being
incurred in the taxable year in which all
the events have occurred that establish
the fact of the liability, the amount of the
liability can be determined with reason-
able accuracy, and payment is made to
the person to which the liability is owed .
See § 461 and § 1 .461-4(g)(1) and (2) . If
the taxpayer has self-insured liabilities
resulting from medical services provided
to employees who have filed claims under
a workers compensation act, the taxpayer
may change its method of accounting for
those liabilities under section 20 .01(1) of
this revenue procedure (if the taxpayer is
otherwise eligible) .
(b) Inapplicability . This change does
not apply to a taxpayer that is required
under § 263A and the regulations there-
under to capitalize the costs with respect
to which the taxpayer wants to change its
method of accounting under this section
20 .03 if the taxpayer is not capitalizing
these costs, unless the taxpayer concur-
rently changes its method to capitalize
these costs in conjunction with a change
to a UNICAP method under section 12 .01,
12 .02, 12 .08, or 12 .12 of this revenue pro-
cedure (as applicable) .
(2) Concurrent automatic change . A
taxpayer making both this change and
change to either a method provided in sec-
tion 20 .01(1) of this revenue procedure for
self-insured employee medical expenses
or a UNICAP method described in section
20 .03(1)(b) of this revenue procedure un-
der section 12 .01, 12 .02, 12 .08, or 12 .12
of this revenue procedure (as applicable)
for the same year of change should file a
single Form 3115, in which case the tax-
payer must enter the designated automatic
accounting method change numbers for
each change on the appropriate line on that
Form 3115 . See section 6 .03(1)(b) of Rev .
Proc . 2015-13, 2015-5 I .R .B . 419, for in-
formation on making concurrent changes .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .03 is “44 .”
(4) Contact information . For further
information regarding a change under this
section, contact Christine Merson at (202)
317-5100 (not a toll-free number) .
.04 Timing of incurring certain liabili-
ties for payroll taxes .
(1) Description of change .
(a) Applicability . This change applies
to:
(i) an employer using an overall ac-
crual method of accounting that wants to
change its method of accounting for:
(A) FICA and FUTA taxes to a method
consistent with the holding in Rev . Rul .
96-51, 1996-2 C .B . 36 . Rev . Rul . 96-51
permits an accrual method employer to
take into account in Year 1, under the all
events test of § 461, its otherwise deduct-

Bulletin No. 2019–48 1187 November 25, 2019
ible FICA and FUTA taxes imposed with
respect to year-end wages properly ac-
crued in Year 1, but paid in Year 2, if the
requirements of the recurring item excep-
tion are met; and
(B) state unemployment taxes and,
in the event the taxpayer is an employer
within the meaning of the Railroad Re-
tirement Tax Act (RRTA) (see § 3231(a)),
RRTA taxes to a method under which the
taxpayer may take into account in Year 1
its otherwise deductible state unemploy-
ment taxes and railroad retirement taxes
(if applicable) imposed with respect to
year-end wages properly accrued in Year
1, but paid in Year 2, if the requirements
of the recurring item exception are met
(including the requirement that, as of the
end of the taxable year, all events have oc-
curred that establish the fact of the liabil-
ity and the amount of the liability can be
determined with reasonable accuracy, see
§ 1 .461-5(b));
(ii) an accrual method employer that
utilizes a method of accounting for FICA
and FUTA taxes that is consistent with
the holding in Rev . Rul . 96-51 and wants
to change its method of accounting for
state unemployment taxes and, in the
event the employer is an employer with-
in the meaning of RRTA (see § 3231(a)),
RRTA taxes to a method under which the
taxpayer may take into account in Year 1
its otherwise deductible state unemploy-
ment taxes and railroad retirement taxes
(if applicable) imposed with respect to
year-end wages properly accrued in Year
1, but paid in Year 2, if the requirements
of the recurring item exception are met
(including the requirement that, as of the
end of the taxable year, all events have
occurred that establish the fact of the lia-
bility and the amount of the liability can
be determined with reasonable accuracy,
see § 1 .461-5(b)); or
(iii) a taxpayer using an overall ac-
crual method of accounting that wants to
change its method of accounting for FICA
and FUTA taxes to the safe harbor meth-
od provided in Rev . Proc . 2008-25, 2008-
1 C .B . 686 . Rev . Proc . 2008-25 provides
that for purposes of the recurring item ex-
ception, a taxpayer will be treated as sat-
isfying the requirement in § 1 .461-5(b)(1)
(i) for its payroll tax liability in the same
taxable year in which all events have oc-
curred that establish the fact of the related
compensation liability and the amount of
the related compensation liability can be
determined with reasonable accuracy .
(b) Inapplicability . This change does
not apply to a taxpayer that is required
under § 263A and the regulations there-
under to capitalize the costs with respect
to which the taxpayer wants to change its
method of accounting under this section
20 .04 if the taxpayer is not capitalizing
these costs, unless the taxpayer concur-
rently changes its method to capitalize
these costs in conjunction with a change
to a UNICAP method under section 12 .01,
12 .02, 12 .08, or 12 .12 of this revenue pro-
cedure (as applicable) .
(2) Recurring item exception . A tax-
payer that previously has not changed to
or adopted the recurring item exception
for FICA taxes, FUTA taxes, state unem-
ployment taxes, and RRTA taxes (if appli-
cable) must change to the recurring item
exception method for FICA taxes, FUTA
taxes, state unemployment taxes, and
RRTA taxes (if applicable) as specified in
§ 461(h)(3) as part of this change .
(3) Concurrent automatic change . A
taxpayer making both this change and a
change to a UNICAP method described in
section 20 .04(1)(b) of this revenue proce-
dure under section 12 .01, 12 .02, 12 .08, or
12 .12 of this revenue procedure (as appli-
cable) for the same year of change should
file a single Form 3115 for both changes,
in which case the taxpayer must enter the
designated automatic accounting method
change numbers for both changes on the
appropriate line on that Form 3115 . See
section 6 .03(1)(b) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, for information on
making concurrent changes .
(4) Designated automatic account-
ing method change number . The des-
ignated automatic accounting method
change number for a change under section
20 .04(1)(a)(i) or (ii) of this revenue pro-
cedure is “45 .” The designated automatic
accounting method change number for a
change under section 20 .04(1)(a)(iii) of
this revenue procedure is “113 .”
(5) Contact information . For further
information regarding a change under this
section, contact Mon Lam at (202) 317-
5100 (not a toll-free number) .
.05 Cooperative advertising .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that wants to
change its method of accounting for co-
operative advertising costs to a method
consistent with the holding in Rev . Rul .
98-39, 1998-2 C .B . 198 . Rev . Rul . 98-
39 generally provides that, under the all
events test of § 461, an accrual method
manufacturer’s liability to pay a retail-
er for cooperative advertising services is
incurred in the year in which the services
are performed, provided the manufacturer
is able to reasonably estimate this liabili-
ty, and even though the retailer does not
submit the required claim form until the
following year .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .05 is “46 .”
(3) Contact information . For further
information regarding a change under this
section, contact Mon Lam at (202) 317-
5100 (not a toll-free number) .
.06 Timing of incurring certain liabili-
ties for services or insurance .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that is cur-
rently treating the mere execution of a
contract for services or insurance as estab-
lishing the fact of the liability under § 461
and wants to change from that method of
accounting for liabilities for services or
insurance to comply with Rev . Rul . 2007-
3, 2007-1 C .B . 350, that is, all the events
needed to establish the fact of the liability
occur when (a) the event fixing the liabil-
ity, whether that be the required perfor-
mance or other event occurs or (b) pay-
ment is due, whichever happens earliest .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .06 is “106 .”
(3) Contact information . For further
information regarding a change under this
section, contact Sharon Horn at (202) 317-
7003 (not a toll-free number) .
.07 Rebates and allowances .
(1) Description of change .
(a) Applicability . This change applies
to taxpayer using an overall accrual meth-
od of accounting that wants to change its
method of accounting for treating its li-
ability for rebates and allowances to the

November 25, 2019 1188 Bulletin No. 2019–48
recurring item exception method under
§ 461(h)(3) and § 1 .461-5 .
(b) Inapplicability . This change does
not apply to a taxpayer’s liability to pay
a refund .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .07 is “135 .”
(3) Contact information . For further
information regarding a change under this
section, contact Mon Lam at (202) 317-
5100 (not a toll-free number) .
.08 Ratable accrual of real property
taxes .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that wants to
change its method of accounting for real
property taxes to the method described
in § 461(c) and § 1 .461-1(c)(1) (ratable
accrual election) . This change applies to
real property taxes that relate to a defi-
nite period of time . This change does not
apply to a taxpayer’s first taxable year in
which the taxpayer incurs real property
taxes, in which case the change is made
using the provisions of § 1 .461-1(c)(3)
(i) .
(2) Manner of making change and
designated automatic accounting method
change number .
(a) This change is made on a cut-off ba-
sis and applies only to real property taxes
accrued on or after the beginning of the
year of change . Any real property taxes
accrued prior to the year of change are
accounted for under the taxpayer’s former
method of accounting . See § 1 .461-1(c)
(6), Examples (2) – (5) . Accordingly, a
§ 481(a) adjustment is neither permitted
nor required .
(b) In accordance with § 1 .446-1(e)(3)
(ii), the requirement in § 1 .461-1(c)(3)(ii)
for requesting consent is satisfied by fil-
ing a short Form 3115 for this change . The
taxpayer’s short Form 3115 must include
all of the following information:
(i) the identification section of page 1
(above Part I);
(ii) the signature section at the bottom
of page 1;
(iii) Part I, line 1(a); and
(iv) the information described in
§ 1 .461-1(c)(3)(ii)(a) through (f) .
(c) The consent granted under section
9 of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, satisfies the consent required under
§ 461(c)(2)(B) and § 1 .461-1(c)(3)(ii) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .08 is “149 .”
(4) Contact information . For further
information regarding a change under this
section, contact Daniel Cassano at (202)
317-7011 (not a toll-free number) .
.09 California Franchise Taxes .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that wants to
change its method of accounting for Cali-
fornia franchise taxes to a method consis-
tent with the holding in Rev . Rul . 2003-
90, 2003-2 C .B . 353 . Rev . Rul . 2003-90
provides that for taxable years beginning
on or after January 1, 2000, a taxpayer
that uses an accrual method of accounting
incurs a liability for California franchise
tax for federal income tax purposes in the
taxable year following the taxable year in
which the California franchise tax is in-
curred under the Cal . Rev . & Tax Code,
as amended .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .09 is “154 .”
(3) Contact information . For further
information regarding a change under this
section, contact Sharon Horn at (202) 317-
7003 (not a toll-free number) .
.10 Gift cards issued as a refund for re-
turned goods .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer using an overall accrual
method of accounting that sells goods at
retail and that wants to change its method
of accounting for gift cards (as defined by
section 4 .02 of Rev . Proc . 2011-17, 2011-5
I .R .B . 441) issued as a refund for returned
goods to treat the transaction as (1) the
payment of a cash refund in the amount of
the gift card, and (2) the sale of a gift card
in the amount of the gift card .
(b) Treatment of proceeds of the deemed
sale . A taxpayer must treat the proceeds of
the deemed sale of a gift card in accor-
dance with the method of accounting it
otherwise employs for sales of gift cards .
(2) Concurrent automatic change . A
taxpayer making both this change and an
automatic change to the deferral method
for advance payments under Rev . Proc .
2004-34 (see section 16 .07 of this reve-
nue procedure) for the same taxable year
of change must file a single Form 3115
for both changes and enter the designat-
ed automatic accounting method change
numbers for both changes on the appro-
priate line on that Form 3115 . See section
6 .03(1)(b) of Rev . Proc . 2015-13, 2015-
5 I .R .B . 419, for information on making
concurrent changes .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .10 is “156 .”
(4) Contact information . For further
information regarding a change under this
section, contact Alicia Lee-Won at (202)
317-7003 (not a toll-free number) .
.11 Timing of incurring liabilities un-
der the recurring item exception to the
economic performance rules .
(1) Description of change . This change
applies to a taxpayer using an overall ac-
crual method of accounting that wants to
conform to any of the holdings in Rev .
Rul . 2012-1, 2012-2 I .R .B . 255, which
clarifies the treatment of certain liabilities
under the recurring item exception to the
economic performance requirement under
§ 461(h)(3) by addressing the application
of the “not material” and “better match-
ing” requirements, and distinguishes con-
tracts for the provision of services from
insurance and warranty contracts .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
20 .11 is “161 .”
(3) Contact information . For further
information regarding a change under this
section, contact Justin Grill at (202) 317-
7003 (not a toll-free number) .
.12 Economic performance safe harbor
for ratable service contracts .
(1) Description of change. This change
applies to an accrual method taxpayer that
wants to change its treatment of Ratable
Service Contracts to conform to the safe

Bulletin No. 2019–48 1189 November 25, 2019
harbor method provided by Rev . Proc .
2015-39, 2015-33 I .R .B . 195 .
(2) Certain eligibility rules temporar-
ily inapplicable . The eligibility rule in
section 5 .01(1)(f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, does not apply to a tax-
payer that wants to make a change under
this section 20.12 for the taxpayer’s first,
second, or third taxable year ending on or
after July 30, 2015 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for changes in methods of ac-
counting under this section 20 .12 is “220 .”
(4) Contact information . For further
information regarding a change under this
section, contact David Christensen or Pe-
ter E . Ford at (202) 317-7003 (not a toll-
free number) .
SECTION 21 . RENT (§ 467)
.01 Change from an improper method
of inclusion of rental income or expense
to inclusion in accordance with the rent
allocation .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that:
(i) is a party to § 467 rental agreements
(within the meaning of § 1 .467-1(c)(1) for
rental agreements entered into after May
18, 1999, and § 467(d) for all other agree-
ments); and
(ii) except as provided in section
21 .01(1)(b)(ii) of this revenue procedure,
wants to change its method of accounting
for its fixed rent (as defined in § 1.467-
1(d)(2)) to the rent allocation method pro-
vided in § 1 .467-1(d)(2)(iii) .
(b) Inapplicability . This change does
not apply to:
(i) rental agreements for which taxpay-
ers are required to use the constant rent-
al accrual method described in § 1 .467-
(3)(a) or the proportional rental accrual
method described in § 1 .467-(2)(a) for
their fixed rent; and
(ii) rental agreements that provide a
specific allocation of fixed rent as de-
scribed in § 1 .467-1(c)(2)(ii)(A)(2) that
allocate rent to periods other than when
such rents are payable .
(2) Additional requirements . The tax-
payer must attach to its Form 3115 a copy
of one of its § 467 rental agreements to
be covered by this automatic change (or at
least the pages of the agreement relating
to the manner in which rent is allocated) .
(3) Audit protection limited . Any audit
protection under section 8 of Rev . Proc .
2015-13, 2015-5 I .R .B . 419, does not
apply to this change for any § 467 rent-
al agreement determined by the Com-
missioner to be a disqualified leaseback
or long-term agreement described in
§ 1 .467-(3)(b) .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
21 .01 is “136 .”
(5) Contact information . For further
information regarding a change under this
section, contact William Ruane at (202)
317-4718 (not a toll-free number) .
SECTION 22 . INVENTORIES (§ 471)
.01 Cash discounts .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for cash dis-
counts (that is, discounts granted for time-
ly payment) when they approximate a fair
interest rate, from a method of consistent-
ly including the price of the goods before
discount in the cost of the goods and in-
cluding in gross income any discounts
taken (the “gross invoice method”), to a
method of reducing the cost of the goods
by the cash discounts and deducting as an
expense any discounts not taken (the “net
invoice method”), or vice versa . See Rev .
Rul . 73-65, 1973-1 C .B . 216 .
(2) Computation of § 481(a) adjust-
ment for changes to net invoice method . In
the case of a taxpayer changing from the
gross invoice method to the net invoice
method, a negative § 481(a) adjustment
is required to prevent duplications arising
from the fact that the gross invoice meth-
od reported income upon timely payment
for some or all of the goods that remain
in inventory, and a positive § 481(a) ad-
justment is required to prevent omissions
arising from the fact that the gross invoice
method included the invoice price, unad-
justed for the cash discounts, of some or
all goods in cost of goods sold and the
discount will be earned by payment in a
subsequent taxable year . The net § 481(a)
adjustment is computed by deducting the
“Applicable Discount” at the beginning
of the year of change from the “Available
Discount” at the beginning of the year of
change . The Available Discount is equal
to the difference between the accounts
payable balance under the gross invoice
method and the net invoice method . The
Applicable Discount is equal to the dif-
ference between the beginning inventory
value under the gross invoice method and
the net invoice method .
Example . Taxpayer’s accounts payable balance
at the beginning of the year of change was $1,000
under the gross invoice method and $980 under the
net invoice method . Taxpayer’s inventory value was
$3,000 under the gross invoice method and $2,955
under the net invoice method . The Available Dis-
count is $20 ($1,000 - $980) and the Applicable Dis-
count is $45 ($3,000 - $2,955) . Thus, Taxpayer’s net
§ 481(a) adjustment is a negative $25 ($20 - $45) .
(3) Computation of § 481(a) adjust-
ment for changes to gross invoice meth-
od . In the case of a taxpayer changing
from the net invoice method to the gross
invoice method, a positive § 481(a) ad-
justment is required to prevent omissions
arising from the fact that the net invoice
method did not report income upon time-
ly payment for some or all of the goods
that remain in inventory, and a negative
§ 481(a) adjustment is required to prevent
duplications arising from the fact that the
net invoice method included the invoice
price, adjusted for the cash discounts, of
some or all goods in cost of goods sold
and the discount will be earned by pay-
ment in a subsequent taxable year . The net
§ 481(a) adjustment can be computed by
deducting the “Available Discount” at the
beginning of the year of change from the
“Applicable Discount” at the beginning
of the year of change . The Available Dis-
count is equal to the difference between
the accounts payable balance under the
gross invoice method and the net invoice
method . The Applicable Discount is equal
to the difference between the beginning
inventory value under the gross invoice
method and the net invoice method .
Example . Taxpayer’s accounts payable balance
at the beginning of the year of change was $980
under the net invoice method and $1,000 under the
gross invoice method . Taxpayer’s inventory value
was $2,955 under the net invoice method and $3,000
under the gross invoice method . The Applicable
Discount is $45 ($3,000 - $2,955) and the Available
Discount is $20 ($1,000 - $980) . Thus, Taxpayer’s
net § 481(a) adjustment is a positive $25 ($45 - $20) .
(4) Designated automatic accounting
method change number . The designat-

November 25, 2019 1190 Bulletin No. 2019–48
ed automatic accounting method change
number for a change under this section
22 .01 is “48 .”
(5) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.02 Estimating inventory “shrinkage”
(1) Description of change . This change
applies to a taxpayer that wants to change
to a method of accounting for estimating
inventory shrinkage in computing ending
inventory, using:
(a) the “retail safe harbor method” de-
scribed in section 4 of Rev . Proc . 98-29,
1998-1 C.B. 857, as modified by this rev-
enue procedure; or
(b) a method other than the retail safe
harbor method, provided (i) the taxpayer’s
present method of accounting does not
estimate inventory shrinkage, and (ii) the
taxpayer’s proposed method of account-
ing (that estimates inventory shrinkage)
clearly reflects income under § 446(b).
(2) Additional requirements . If the
taxpayer wants to change to a method
of accounting for inventory shrinkage
other than the retail safe harbor meth-
od, the taxpayer must attach to its Form
3115 a statement setting forth a detailed
description of all aspects of the proposed
method of estimating inventory shrinkage
(including, for last-in, first-out (LIFO)
taxpayers, the method of determining in-
ventory shrinkage for, or allocating inven-
tory shrinkage to, each LIFO pool) . The
director or national office subsequently
may review whether the proposed meth-
od clearly reflects the taxpayer’s income
under § 446(b), notwithstanding any
provision of Rev . Proc . 2015-13, 2015-5
I .R .B . 419 (or successor) . If the director
or the national office determines that the
proposed method of accounting does not
clearly reflect the taxpayer’s income, the
taxpayer will be treated as having made a
change in method of accounting without
obtaining the consent of the Commission-
er as required by § 446(e) . See sections
2 .01(3) and 2 .03 of Rev . Proc . 2015-13 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .02 is “49 .”
(4) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.03 Small taxpayer exception from re-
quirement to account for inventories un-
der § 471 .
(1) Description of change .
(a) Applicability . This change applies
to either a taxpayer (other than a taxpayer
described § 448(a)(3)) with “average an-
nual gross receipts” (as defined in section
5.01 of Rev. Proc. 2001-10, as modified
by Announcement 2004-16 (regarding
placement of § 481(a) adjustment on the
Form 3115), and Rev . Proc . 2011-14 (re-
moving § 6 .02(1)(a) of Rev . Proc . 2001-
10)) of $1,000,000 or less or a qualifying
taxpayer (other than a taxpayer described
in § 448) with “average annual gross re-
ceipts” (as defined in section 5.02 of
Rev. Proc. 2002-28, as modified by An-
nouncement 2004-16 (regarding place-
ment of § 481(a) adjustment on the Form
3115), and Rev . Proc . 2011-14 (removing
§ 7 .02(1)(a) of Rev . Proc . 2002-28)) of
$10,000,000 or less that wants to change
from a method of accounting for invento-
riable items (including, if applicable, from
the method of capitalizing costs under
§ 263A) to the method described in Rev .
Proc . 2001-10 and Rev . Proc . 2002-28, for
treating inventoriable items in the same
manner as materials and supplies that are
not incidental under § 1 .162-3 .
(b) Inapplicability . This change does
not apply for taxable years beginning after
December 31, 2017 . See, however, sec-
tion 22 .19 of this revenue procedure for
making a change in method of accounting
for inventories for taxable years beginning
after December 31, 2017 .
(2) Manner of making change . See Rev .
Proc . 2001-10 or Rev . Proc . 2002-28 (as
applicable) for additional guidance on the
computation of the § 481(a) adjustment
and the completion of the Form 3115 .
(3) Concurrent automatic change to
the overall cash method under Rev. Proc.
2001-10 or Rev. Proc. 2002-28 . A taxpay-
er making both this change and a change
to the overall cash method under Rev .
Proc . 2001-10 or Rev . Proc . 2002-28 (see
section 15 .03 of this revenue procedure)
for the same year of change may file a sin-
gle Form 3115 for both changes, provided
the taxpayer enters the designated auto-
matic accounting method change numbers
for both changes on the appropriate line
on that Form 3115 . See section 6 .03(1)(b)
of Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
for information on making concurrent
changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .03 for the small taxpayer ($1,000,000)
inventory exception contained in Rev .
Proc . 2001-10 is “50 .” The designated au-
tomatic accounting method change num-
ber for a change under this section 22 .03
for the small taxpayer ($10,000,000) in-
ventory exception contained in Rev . Proc .
2002-28 is “51 .”
(5) Contact information . For further
information regarding a change under this
section, contact Anna Gleysteen at (202)
317-7007 (not a toll-free number) .
.04 Qualifying volume-related trade
discounts .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting to treat quali-
fying volume-related trade discounts as
a reduction in the cost of merchandise
purchased at the time the discount is rec-
ognized in accordance with § 1 .471-3(b) .
A “qualifying volume-related trade dis-
count” means a discount satisfying the
following criteria:
(a) the taxpayer receives or earns the
discount based solely upon the purchase
of a particular volume of the merchandise
to which the discount relates;
(b) the taxpayer is neither obligated
nor expected to perform or provide any
services in exchange for the discount; and
(c) the discount is not a reimbursement
of any expenditure incurred or to be in-
curred by the taxpayer .
(2) Section 481(a) adjustment . The net
§ 481(a) adjustment attributable to the
change is computed in a manner similar
to the computation of a net § 481(a) ad-
justment in the case of a change to the net
invoice method of accounting for cash
discounts . See section 22 .01(2) of this rev-
enue procedure .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .04 is “53 .”
(4) Contact information . For further
information regarding a change under this

Bulletin No. 2019–48 1191 November 25, 2019
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.05 Impermissible methods of identifi-
cation and valuation of inventories .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to change from
an impermissible method of identifying or
valuing inventories to a permissible meth-
od of identifying or valuing inventories .
For example, a taxpayer:
(i) using last-in, first-out (LIFO) as
its inventory-identification method may
change its inventory-valuation method
from below cost to cost;
(ii) using an impermissible method of
accounting described in §§ 1 .471-2(f)(1)
through (5) may change to a permissible
method of accounting that corrects the
impermissible method described in §§
1 .471-2(f)(1) through (5);
(iii) using a method that is not in ac-
cordance with § 1 .471-2(c) may change to
a permissible method of valuing “subnor-
mal goods” under § 1 .471-2(c);
(iv) changing from a gross profit
method . For this purpose, a gross prof-
it method is a method in which the tax-
payer estimates the cost of goods sold by
reducing its gross sales by a percentage
“mark-up” from cost . The estimated cost
of goods sold is subtracted from the sum
of the beginning inventory and purchases
and the result is used as the ending in-
ventory; or
(v) changing from a method of deter-
mining market that is not in accordance
with § 1 .471-4 . For this purpose, an ex-
ample of a method of determining market
that is not in accordance with § 1 .471-4
is where a taxpayer, under ordinary cir-
cumstances, determines the market value
of purchased merchandise using judgment
factors, and not using the prevailing cur-
rent bid price on the inventory date for the
particular merchandise in the volume in
which it is usually purchased by the tax-
payer .
(b) Inapplicability . This change does
not apply to:
(i) any change for real property or im-
provements to the real property because
real property is not inventoriable property
under § 1 .471-1;
(ii) a taxpayer who meets the definition
of a “dealer in securities” under both §
1 .471-5 and § 475 because such dealer is
required to account for securities, as de-
fined in § 475, under § 475 and may not
use the rules described in § 1 .471-5 for
those securities;
(iii) any change described in another
section of this revenue procedure or in
other guidance published in the Internal
Revenue Bulletin, or to any change with-
in the last-in, first-out (LIFO) inventory
method . For example, this change does not
apply to a taxpayer that wants to change to
a rolling-average method (but see section
22 .14 of this revenue procedure);
(iv) any change to a method of allocat-
ing costs to inventory under § 471 or any
change to a method under § 263A (but see
sections 12 .01 and 12 .02 of this revenue
procedure); or
(v) a taxpayer that is currently deduct-
ing inventories (but see section 22 .18 of
this revenue procedure) .
(c) Permissible method defined . For
purposes of this change, a permissible
method is an inventory method of identi-
fication or valuation, or both, specifically
permitted by the Code, the regulations,
or other guidance published in the Inter-
nal Revenue Bulletin, or a decision of the
United States Supreme Court . However,
an otherwise permissible inventory meth-
od is not permissible under this section
22.05 for a specific taxpayer if that tax-
payer is prohibited from using that meth-
od or if that taxpayer is required to use a
different method .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .05 is “54 .”
(3) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.06 Core Alternative Valuation Method .
(1) Description of change .
(a) Applicability . This change applies
to a remanufacturer and rebuilder of mo-
tor vehicle parts and a reseller of reman-
ufactured and rebuilt motor vehicle parts
that use the cost or market, whichever is
lower (LCM), inventory valuation meth-
od to value their inventory of cores held
for remanufacturing or sale and wants to
use the Core Alternative Valuation (CAV)
method specified in Rev. Proc. 2003-20,
2003-1 C .B . 445 .
(b) Inapplicability . This change does
not apply to a taxpayer that values its in-
ventory of cores at cost (including a tax-
payer using the LIFO inventory method)
unless the taxpayer concurrently changes
(under section 6 .02 of Rev . Proc . 2003-20)
from cost to the LCM method for its cores
(including labor and overhead related to
the cores in raw materials, work-in-pro-
cess, and finished goods).
(2) Concurrent automatic change . A
taxpayer making both this change and
(i) a change from the cost method to the
LCM method under section 22 .11 of this
revenue procedure, or (ii) a change from
the LIFO inventory method to a permitted
method for identification under (and as de-
termined and defined in) section 23.01(1)
(b) of this revenue procedure for the same
year of change, should file a single Form
3115 for both changes, provided the tax-
payer enters the designated automatic ac-
counting method change numbers for both
changes on the appropriate line on that
Form 3115 . See section 6 .03(1)(b) of Rev .
Proc . 2015-13, 2015-5 I .R .B . 419, for in-
formation on making concurrent changes .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .06 is “55 .”
(4) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.07 Replacement cost for automobile
dealers’ parts inventory .
(1) Description of change . This change
applies to a taxpayer that is engaged in the
trade or business of selling vehicle parts
at retail, that is authorized under an agree-
ment with one or more vehicle manufac-
turers or distributors to sell new automo-
biles or new light, medium, or heavy-duty
trucks, and that wants to use the replace-
ment cost method described in section 4 of
Rev . Proc . 2002-17, 2002-1 C .B . 676, as
modified by Rev. Proc. 2006-14, 2006-1
C .B . 350, for its vehicle parts inventory .
See Rev . Proc . 2002-17 for further infor-
mation regarding this change .
(2) Manner of making change . This
change is made on a cut-off basis and ap-
plies only to the computation of ending in-
ventories on or after the beginning of the
year of change . Accordingly, a § 481(a)

November 25, 2019 1192 Bulletin No. 2019–48
adjustment is neither permitted nor re-
quired .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .07 is “63 .”
(4) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.08 Replacement cost for heavy equip-
ment dealers’ parts inventory .
(1) Description of change . This change
applies to a heavy equipment dealer that is
engaged in the trade or business of selling
heavy equipment parts at retail, that is au-
thorized under an agreement with one or
more heavy equipment manufacturers or
distributors to sell new heavy equipment,
and that wants to use the replacement cost
method described in section 4 of Rev .
Proc . 2006-14, 2006-1 C .B . 350, for its
heavy equipment parts inventory .
(2) Manner of making the change . This
change is made on a cut-off basis and ap-
plies only to the computation of ending
inventories after the beginning of the year
of change . Accordingly, a § 481(a) adjust-
ment is neither permitted nor required .
(3) Concurrent automatic change . A
taxpayer making both this change and an-
other automatic change in method of ac-
counting under § 263A (see section 12 of
this revenue procedure) for the same year
of change may file a single Form 3115 for
both changes, provided the taxpayer en-
ters the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115,
and complies with the ordering rules of
§ 1 .263A-7(b)(2) .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .08 is “96 .”
(5) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.09 Rotable spare parts .
(1) Description of change . This change
applies to a taxpayer that is using the safe
harbor method of accounting to treat its
rotable spare parts as depreciable assets
in accordance with Rev . Proc . 2007-48,
2007-2 C.B. 110, as modified by this rev-
enue procedure, and wants to change its
method of accounting to treat its rotable
spare parts as inventoriable items . This
change also applies to a taxpayer who is
treating its rotable spare parts as deprecia-
ble assets in a manner similar to the safe
harbor method described in Rev . Proc .
2007-48, and wants to change its meth-
od of accounting to treat its rotable spare
parts as inventoriable items . A taxpayer
changing its method of accounting for ro-
table spare parts under this section 22 .09,
must use a proper inventory method to
identify and value its rotable spare parts .
(2) Eligibility rule inapplicable . The
eligibility rule in section 5 .01(1)(f) of Rev .
Proc . 2015-13, 2015-5 I .R .B . 419, does
not apply to a taxpayer that is required to
make the change in method of account-
ing pursuant to section 5 .06 of Rev . Proc .
2007-48 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .09 is “110 .”
(4) Contact information . For further
information regarding a change under this
section, contact Stephen Rothandler at
(202) 317-7003 (not a toll-free number) .
.10 Advance Trade Discount Method .
(1) Description of change . This change
applies to a taxpayer that wants to use
the Advance Trade Discount Method de-
scribed in Rev . Proc . 2007-53, 2007-2
C .B . 233 .
(2) Applicability . This change in meth-
od of accounting applies to a taxpayer
using an overall accrual method of ac-
counting that is required to use an inven-
tory method of accounting, that maintains
inventories as provided in § 471 and the
regulations thereunder, and that receives
advance trade discounts as defined in sec-
tion 4 .03 of Rev . Proc . 2007-53 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .10 is “111 .”
(4) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.11 Permissible methods of identifica-
tion and valuation of inventories .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer that wants to change from
one permissible method of identifying or
valuing inventories to another permissi-
ble method of identifying or valuing in-
ventories . For example, a taxpayer using
the first-in, first-out (FIFO) method as
its inventory-identification method may
change its inventory-valuation method
from cost to cost or market, whichever
is lower (LCM), or a taxpayer valuing
“subnormal” goods at cost may change its
valuation method to another permissible
method of valuing “subnormal goods” un-
der § 1 .471-2(c) .
(b) Inapplicability . This change does
not apply to:
(i) any change for real property or im-
provements to the real property because
real property is not inventoriable property
under § 1 .471-1:
(ii) a taxpayer who meets the definition
of a “dealer in securities” under both §
1 .471-5 and § 475 because such dealer is
required to account for securities, as de-
fined in § 475, under § 475 and may not
use the rules described in § 1 .471-5 for
those securities;
(iii) any change described in another
section of this revenue procedure or in
other guidance published in the Internal
Revenue Bulletin, or to any change with-
in the last-in, first-out (LIFO) inventory
method . For example, this change does not
apply to a taxpayer that wants to change to
a rolling-average method (but see section
22 .14 of this revenue procedure); or
(iv) any change to a method of allocat-
ing costs to inventory under § 471 or any
change to a method under § 263A (but see
sections 12 .01 and 12 .02 of this revenue
procedure) .
(c) Permissible method defined . For
purposes of this change, a permissible
method is an inventory method of identi-
fication or valuation, or both, specifically
permitted for inventories by the Code,
the regulations, or other guidance pub-
lished in the Internal Revenue Bulletin, or
a decision of the United States Supreme
Court . However, an otherwise permissible
inventory method is not permissible under
this section 22.11 for a specific taxpayer if
that taxpayer is prohibited from using that
method or if that taxpayer is required to
use a different method .

Bulletin No. 2019–48 1193 November 25, 2019
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .11 is “137 .”
(3) Contact information . For further
information regarding a change under this
section, contact Steven Gee at (202) 317-
7007 (not a toll-free number) .
.12 Change in the official used vehicle
guide utilized in valuing used vehicles .
(1) Description of change . Used vehi-
cles taken in trade as part payment on the
sale of vehicles by a dealer may be val-
ued for inventory purposes at valuations
comparable to those listed in an official
used vehicle guide as the average whole-
sale prices for comparable vehicles . See
Rev . Rul . 67-107, 1967-1 C .B . 115 . This
change applies to:
(a) a taxpayer that wants to change
from not using an official used vehicle
guide to using an official used vehicle
guide for valuing used vehicles; or
(b) a taxpayer that wants to change to
a different official used vehicle guide for
valuing used vehicles .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .12 is “138 .”
(3) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.13 Invoiced advertising association
costs for new vehicle retail dealerships .
(1) Description of change . This change
applies to a taxpayer that is engaged in
the trade or business of retail sales of
new automobiles or new light-duty trucks
(“dealership”) that wants to discontinue
capitalizing certain advertising costs as
acquisition costs under § 1 .471-3(b) . The
change applies to advertising costs that
meet the following criteria: (a) the deal-
ership must pay this advertising fee when
acquiring vehicles from the manufacturer;
(b) the advertising costs are separately
coded and included in the manufacturer’s
invoice cost of the new vehicle; (c) the ad-
vertising cost is a flat fee per vehicle or a
fixed percentage of the invoice price; and
(d) the fees collected by the manufacturer
are paid to local advertising associations
that promote and advertise the manufac-
turer’s products in the dealership’s mar-
ket area . Under the proposed method, the
dealership will exclude advertising costs
that meet the above criteria from the cost
of new vehicles and deduct the advertising
costs under § 162 as the advertising ser-
vices are provided to the dealership . See
§ 1 .461-4(d)(2)(i) .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .13 is “139 .”
(3) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.14 Rolling-average method of ac-
counting for inventories .
(1) Description of change . This change
applies to a taxpayer that uses a rolling-av-
erage method to value inventories for fi-
nancial accounting purposes and wants to
use the same rolling-average method to
value inventories for federal income tax
purposes in accordance with Rev . Proc .
2008-43, 2008-30 C.B. 186, as modified
by Rev . Proc . 2008-52, 2008-2 C .B . 587
(see section 13) .
(2) Manner of making change . This
change is made on a cut-off basis and is
applied only to the computation of end-
ing inventories after the beginning of the
year of change . However, if the taxpayer’s
books and records contain sufficient infor-
mation to compute a § 481(a) adjustment,
the taxpayer may choose to implement
the change with a § 481(a) adjustment as
provided in sections 7 .02 and 7 .03 of Rev .
Proc . 2015-13, 2015-5 I .R .B . 419 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
22 .14 is “114 .”
(4) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.15 Sales-Based Vendor Chargebacks .
(1) Description of change. This change,
as described in Rev . Proc . 2014-33, 2014-
22 I .R .B . 1060, applies to a taxpayer that
wants to change its method of accounting
to treat sales-based vendor chargebacks as
a reduction in cost of goods sold in accor-
dance with § 1 .471-3(e)(1) .
(2) Concurrent automatic changes . A
taxpayer making both this change and the
change described in section 12 .11 of this
revenue procedure for the same taxable
year of change may file a single Form 3115
for both changes, provided the taxpayer
enters the designated automatic change
numbers for both changes on the appropri-
ate line on the Form 3115, and complies
with the ordering rules of § 1 .263A-7(b)
(2) . See section 6 .03(1)(b) of Rev . Proc .
2015-13, 2015-5 I .R .B . 419, for informa-
tion on making concurrent changes .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for changes in methods of ac-
counting under this section 22 .15 is “203 .”
(4) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.16 Certain changes to the cost com-
plement of the retail inventory method.
(1) Description of change. This change,
as described in Rev . Proc . 2014-48, 2014-
36 I .R .B . 527, applies to a taxpayer using
the retail inventory method that wants to
make one of the following changes:
(a) From adjusting to not adjusting the
numerator of the cost complement by the
amount of an allowance, discount, or price
rebate that is required under § 1 .471-3(e)
to reduce only cost of goods sold;
(b) From adjusting to not adjusting the
denominator of the cost complement for
temporary markups and markdowns;
(c) In the case of a retail LCM taxpayer,
to computing the cost complement using a
method described in § 1 .471-8(b)(3), in-
cluding changes from a method described
in § 1 .471-8(b)(3) to another method de-
scribed in § 1 .471-8(b)(3); or
(d) In the case of a retail cost taxpay-
er, from not adjusting to adjusting the
denominator of the cost complement for
permanent markups and markdowns .
(2) Effective date . This section 22 .16 is
effective for taxable years beginning after
December 31, 2014 .
(3) Multiple changes . A taxpayer mak-
ing multiple changes under this section
22 .16 for the same year of change should
file a single Form 3115.
(4) Manner of making change . A tax-
payer making a change under this section
22.16 for its first or second taxable year be-

November 25, 2019 1194 Bulletin No. 2019–48
ginning after December 31, 2014, may use
either a § 481(a) adjustment as provided in
sections 7 .02 and 7 .03 of Rev . Proc . 2015-
13 or implement the change on a cut-off
basis . If the taxpayer uses a cut-off basis,
the change applies only to the computation
of ending inventories after the beginning of
the year of change, and a § 481(a) adjust-
ment is neither permitted nor required if a
change is made on a cut-off basis .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for changes in methods of ac-
counting under this section 22 .16 is “204 .”
(6) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.17 Certain changes within the retail
inventory method .
(1) Description of change. This change
applies to a taxpayer using the retail in-
ventory method that wants to change
from including to not including temporary
markups and markdowns in determining
the retail selling prices of goods on hand
at the end of the taxable year .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for changes in methods of ac-
counting under this section 22 .17 is “225 .”
(3) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.18 Change from currently deducting
inventories to permissible methods of
identification and valuation of inventories .
(1) Description of change .
(a) Applicability . This change applies to
a taxpayer that wants to change from cur-
rently deducting inventories to a permis-
sible method of identifying and valuing
inventories . For example, a taxpayer cur-
rently deducting inventories may change
to using the first-in, first-out (FIFO) meth-
od as its inventory-identification method
and cost or market, whichever is lower
(LCM), as its inventory-valuation method .
(b) Inapplicability . This change does
not apply to:
(i) any change for real property or im-
provements to the real property because
real property is not inventoriable property
under § 1 .471-1;
(ii) a taxpayer who meets the definition
of a “dealer in securities” under both §
1 .471-5 and § 475 because such dealer is
required to account for securities, as de-
fined in § 475, under § 475 and may not
use the rules described in § 1 .471-5 for
those securities;
(iii) any change described in another
section of this revenue procedure or in
other guidance published in the Internal
Revenue Bulletin, or to any change with-
in the last-in, first-out (LIFO) inventory
method . For example, this change does not
apply to a taxpayer that wants to change to
a rolling-average method (but see section
22 .14 of this revenue procedure); or
(iv) any change to a method of allocat-
ing costs to inventory under § 471 or any
change to a method under § 263A (but see
sections 12 .01 and 12 .02 of this revenue
procedure) .
(c) Permissible method defined . For
purposes of this change, a permissible
method is an inventory method of identi-
fication or valuation, or both, specifically
permitted for inventories by the Code,
the regulations, or other guidance pub-
lished in the Internal Revenue Bulletin, or
a decision of the United States Supreme
Court . However, an otherwise permissible
inventory method is not permissible under
this section 22.18 for a specific taxpayer if
that taxpayer is prohibited from using that
method or if that taxpayer is required to
use a different method .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for changes in methods of ac-
counting under this section 22 .18 is “230 .”
(3) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.19 Small business taxpayer exception
from requirement to account for invento-
ries under § 471 .
(1) Description of change . This change
applies to a small business taxpayer, as de-
fined in section 15.18(5)(a) of this revenue
procedure, that wants to change its § 471
method of accounting for inventory items
to one of the following:
(a) treating inventory as non-incidental
materials and supplies under § 1 .162-3; or
(b) conforming to the taxpayer’s meth-
od of accounting reflected in its applicable
financial statements, as defined in § 451(b)
(3), with respect to the taxable year, or if
the taxpayer does not have an applicable
financial statement for the taxable year,
the books and records of the taxpayer pre-
pared in accordance with the taxpayer’s
accounting procedures .
(2) Applicability . This change is effec-
tive for taxable years beginning after De-
cember 31, 2017 .
(3) Certain eligibility rule temporarily
inapplicable . The eligibility rule in sec-
tion 5 .01(1)(f) of Rev . Proc . 2015-13 does
not apply to this change for a taxpayer’s
first, second, or third taxable year begin-
ning after December 31, 2017 .
(4) Reduced filing requirement . A tax-
payer is required to complete only the fol-
lowing information on Form 3115 (Rev .
December 2018) to make this change:
(a) The identification section of page 1
(above Part I);
(b) The signature section at the bottom
of page 1;
(c) Part I;
(d) Part II, all lines except line 16; and
(e) Part IV, all lines except line 25 .
(5) No ruling on method of accounting
used .
The consent granted under section 9
of Rev . Proc . 2015-13 for a change made
under section 22 .19(1)(b) of this revenue
procedure is not a determination by the
Commissioner that the proposed inventory
method of accounting is permissible, and
does not create any presumption that the
proposed method is a permissible meth-
od of accounting under a provision of the
Code . The director will ascertain whether
the proposed method is permissible under
the Code .
(6) Concurrent automatic changes . A
taxpayer making a change under this sec-
tion 22 .19 and a change under sections
15 .18 and/or 12 .16 of this revenue pro-
cedure for the same year of change may
file a single Form 3115 for all changes,
provided the taxpayer enters the designat-
ed automatic accounting method change
numbers for the changes on the appropri-
ate line of Form 3115 . See section 6 .03(1)
(b) of Rev . Proc . 2015-13 for information
on making concurrent changes .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change

Bulletin No. 2019–48 1195 November 25, 2019
number for a change under this section
22 .19 is “235 .”
(8) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
SECTION 23 . LAST-IN, FIRST-OUT
(LIFO) INVENTORIES (§ 472)
.01 Change from the LIFO inventory
method .
(1) Description of change .
(a) In general . This change applies to a
taxpayer that wants to:
(i) change from the LIFO inventory
method for all its LIFO inventory or for
the entire content of one or more dol-
lar-value pools; and
(ii) change to a permitted method or
methods as determined in section 23 .01(1)
(b) of this revenue procedure .
(b) Method to be used .
(i) Determining the permitted method
to be used . A taxpayer may change to one
or more non-LIFO inventory methods for
the LIFO inventories that are the subject
of this accounting method change, but
only if the selected non-LIFO method is a
permitted method for the inventory goods
to which it will be applied . For example,
a heavy equipment dealer may change to
the specific identification method for new
heavy equipment inventories and the re-
placement cost method, as described in
Rev . Proc . 2006-14, 2006-1 C .B . 350, for
heavy equipment parts inventories .
(ii) Permitted method defined . For pur-
poses of this section 23 .01, an inventory
method (identification or valuation, or
both) is a permitted method if it is specifi-
cally permitted for the inventory goods by
the Code, the regulations, or other guid-
ance published in the Internal Revenue
Bulletin, or a decision of the United States
Supreme Court and if the taxpayer is nei-
ther prohibited from using that method
nor required to use a different inventory
method for those inventory goods .
(iii) Determining permitted method .
Whether an inventory method is a permit-
ted method is determined without regard
to the types and amounts of costs capital-
ized under the taxpayer’s method of com-
puting inventory cost . See § 263A and the
regulations thereunder, which govern the
types and amounts of costs required to be
included in inventory cost for taxpayers
subject to those provisions .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply for the first taxable
year that the taxpayer does not or will not
comply with the requirements of § 472(e)
(2) because the taxpayer has applied or
will apply International Financial Report-
ing Standards in its financial statements or
because the taxpayer has been acquired by
an entity that has not or will not use the
LIFO method in its financial statements.
(3) Limitation on LIFO election . The
taxpayer may not re-elect the LIFO in-
ventory method for a period of at least
five taxable years beginning with the year
of change unless, based on a showing of
unusual and compelling circumstanc-
es, consent is specifically granted by the
Commissioner to change the method of
accounting at an earlier time . A taxpayer
that wants to re-elect the LIFO invento-
ry method within a period of five taxable
years (beginning with the year of change)
must file a Form 3115 in accordance with
the non-automatic change procedures in
Rev . Proc . 2015-13 . A taxpayer that wants
to re-elect the LIFO inventory method af-
ter a period of five taxable years (begin-
ning with the year of change) does not
file a Form 3115 using the non-automatic
change procedures in Rev . Proc . 2015-13,
but, rather, must file a Form 970, Appli-
cation To Use LIFO Inventory Method, in
accordance with § 1 .472-3 .
(4) Effect of subchapter S election by
corporation . See section 7 .03(4)(b) and
(c) of Rev . Proc . 2015-13 .
(5) Additional requirements . The tax-
payer must complete the following state-
ments and attach them to its Form 3115 .
If the taxpayer will use different methods
for different inventory goods to which the
change applies, the taxpayer must com-
plete the statements for each of those dif-
ferent types of inventory goods .
(a) “The proposed method of identify-
ing [Insert description of inventory goods]
is the [Insert method, as appropriate; that
is, specific identification; FIFO; retail;
etc.] method .”
(b) “The proposed method of valuing
[Insert description of inventory goods] is
[Insert method, as appropriate; that is,
cost; LCM; etc.] .”
(6) Pool split and partial termina-
tion . If a taxpayer must remove goods
from a LIFO inventory pool because
those goods are not within the scope of
that pool (for example, removing resale
goods from a manufacturing pool), and
if the taxpayer wants to change from
the LIFO inventory method for those
removed goods, the taxpayer may split
the pool pursuant to section 23 .10 of this
revenue procedure and then may change
from the LIFO method pursuant to this
section 23 .01 . See section 23 .10(2) of
this revenue procedure . The taxpayer
must file a separate Form 3115 for each
such change .
(7) Section 481(a) adjustment required .
(a) General rule . A taxpayer changing
from a LIFO inventory method must com-
pute a § 481(a) adjustment for the year
of change . See section 7 .02 of Rev . Proc .
2015-13 .
(b) Special rule for changes that
would otherwise be implemented on a
cut-off basis . If a taxpayer is chang-
ing from the LIFO inventory method to
a method of accounting that is imple-
mented on a cut-off basis under another
section of this revenue procedure (see,
for example, sections 22 .07, 22 .08, and
22 .14 of this revenue procedure), the tax-
payer’s § 481(a) adjustment is “the LIFO
recapture amount” as defined in § 312(n)
(4)(B) and (C) . A taxpayer computing the
§ 481(a) adjustment under this special
rule must then compute its ending inven-
tory value for the year of change using
the proposed method (that is, treat the
deemed change from the first-in, first-out
(FIFO) method to the proposed method
on a cut-off basis) .
(8) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .01 is “56 .”
(9) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.02 Determining current-year cost un-
der the LIFO inventory method .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer using the LIFO inventory
method that wants to change its method of
determining current-year cost to:

November 25, 2019 1196 Bulletin No. 2019–48
(i) the actual cost of the goods most
recently purchased or produced (most-re-
cent-acquisitions method);
(ii) the actual cost of the goods pur-
chased or produced during the taxable
year in the order of acquisition (earli-
est-acquisitions method);
(iii) the average unit cost equal to the
aggregate actual cost of all the goods pur-
chased or produced throughout the taxable
year divided by the total number of units
so purchased or produced . See § 1 .472-
8(e)(2)(ii);
(iv) the specific identification method;
or
(v) a rolling-average method if the tax-
payer uses that rolling-average method
in accordance with Rev . Proc . 2008-43,
2008-30 I.R.B. 186, as modified by Rev.
Proc . 2008-52, 2008-36 I .R .B . 587 (see
section 13) .
(b) Inapplicability . This change does
not apply to a taxpayer using the lower of
cost or market method to determine cur-
rent-year cost . A taxpayer using the lower
of cost or market method that valued in-
ventory below cost may not change to a
proper cost valuation under this section
23 .02 .
(2) Manner of making change . This
change is made using a cut-off basis and
applies only to the computations of cur-
rent-year cost after the beginning of the
year of change . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired .
(3) Concurrent change to a rolling-av-
erage method . A taxpayer making both a
change to a rolling-average method of de-
termining current-year cost for its LIFO
inventory under this section 23 .02 and a
change to a rolling-average method of ac-
counting for non-LIFO inventories under
Rev . Proc . 2008-43 (see section 22 .14 of
this revenue procedure) should file a single
Form 3115 for both changes, in which case
the taxpayer must enter the designated auto-
matic accounting method change numbers
for both changes on the appropriate line on
that Form 3115 . See section 6 .03(1)(b) of
Rev . Proc . 2015-13, 2015-5 I .R .B . 419, for
information on making concurrent changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .02 is “57 .”
(5) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.03 Alternative LIFO inventory method
for retail automobile dealers .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer engaged in the trade or busi-
ness of retail sales of new automobiles or
new light-duty trucks (“automobile deal-
er”) that wants to change to the “Alterna-
tive LIFO method” described in section 4
of Rev . Proc . 97-36, 1997-2 C .B . 450, as
modified by Rev. Proc. 2008-23, 2008-1
C .B . 664, for its LIFO inventories of new
automobiles and new light-duty trucks .
Light-duty trucks are trucks with a gross
vehicle weight of 14,000 pounds or less,
which also are referred to as class 1, 2, or
3 trucks .
(b) Inapplicability . This change does
not apply to an automobile dealer that
uses the inventory price index computa-
tion (IPIC) method for goods other than
new automobiles, new light-duty trucks,
parts and accessories, used automobiles,
and used trucks .
(2) Manner of making change .
(a) Cut-off basis . This change is made
using a cut-off basis and applies only to
the computation of ending inventories af-
ter the beginning of the year of change .
See section 5 .03(6) of Rev . Proc . 97-36
for more information regarding a cut-off
basis . Accordingly, a § 481(a) adjustment
is neither permitted nor required .
(b) Concurrent change from IPIC
method . An automobile dealer using the
IPIC method that also has parts and ac-
cessories, used automobiles, or used
light-duty trucks (other goods) inventory
may incorporate a change, using a cut-
off basis, from IPIC to another accept-
able LIFO method for those other goods
into this change . When changing from
IPIC to a dollar-value LIFO method for
its other goods, the automobile dealer
must establish separate inventory pools
for new automobiles and new light-duty
trucks, unless the automobile dealer also
concurrently changes to the Vehicle-Pool
Method (see section 23 .08 of this revenue
procedure) . Further, the automobile dealer
must establish a separate inventory pool
for the parts and accessories . See section
6 .03(1)(b) of Rev . Proc . 2015-13, 2015-
5 I .R .B . 419, for information on making
concurrent changes .
(c) Additional requirements . An auto-
mobile dealer also must comply with the
following:
(i) the conditions in section 5 .03 of
Rev . Proc . 97-36; and
(ii) for an automobile dealer changing
from the IPIC method under this section
23 .03, the automobile dealer also must at-
tach to its Form 3115 a schedule setting
forth the classes of goods for which the
automobile dealer has elected to use the
LIFO method and the accounting method
changes being made under this section
23 .03 for each class of goods .
(3) Concurrent change to the Vehi-
cle-Pool Method . A taxpayer making both
a change to the Alternative LIFO Method
under this section 23 .03 and a change to
the Vehicle-Pool Method under Rev . Proc .
2008-23 (see section 23 .08 of this reve-
nue procedure) should file a single Form
3115 for both changes, in which case the
taxpayer must enter the designated auto-
matic accounting method change numbers
for both changes on the appropriate line
on that Form 3115 . See section 6 .03(1)(b)
of Rev . Proc . 2015-13 for information on
making concurrent changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .03 is “58 .”
(5) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.04 Used vehicle alternative LIFO
method .
(1) Description of change . This change
applies to a taxpayer that sells used auto-
mobiles and used light-duty trucks (“used
vehicle dealers”) that wants to change
to the “Used Vehicle Alternative LIFO
Method” as described in Rev . Proc . 2001-
23, 2001-1 C.B. 784, as modified by An-
nouncement 2004-16, 2004-1 C .B . 668,
and Rev . Proc . 2008-23, 2008-1 C .B . 664 .
(2) Additional requirements . A taxpay-
er making this change must comply with
the additional conditions set forth in sec-
tion 5 .04 of Rev . Proc . 2001-23 .
(3) Manner of making change .
(a) Cut-off basis . This change is made
on a cut-off basis, which requires that the

Bulletin No. 2019–48 1197 November 25, 2019
value of the taxpayer’s used automobile
and used light-duty truck inventory at the
beginning of the year of change must be
the same as the value of that inventory
at the end of the preceding taxable year,
plus cost restorations, if any, required by
section 5 .04(5) of Rev . Proc . 2001-23 . Ac-
cordingly, a § 481(a) adjustment is neither
permitted nor required .
(b) Bargain purchase . If the taxpayer
has previously improperly accounted for a
bulk bargain purchase, the taxpayer must,
as part of this change, first change its meth-
od of accounting to comply with Hamilton
Industries, Inc. v. Commissioner, 97 T .C .
120 (1991), and compute a § 481(a) ad-
justment for that part of the change . See
Announcement 91-173, 1991-47 I .R .B .
29 . Upon examination, if a taxpayer has
properly changed under this section 23 .04
except for complying with this section
23 .04(3)(b), an examining agent may not
deny the taxpayer the change . However,
the taxpayer does not receive audit pro-
tection under section 8 .01 of Rev . Proc .
2015-13, 2015-5 I .R .B . 419, with respect
to the improper method of accounting for
the bargain purchase . See section 8 .02(2)
of Rev . Proc . 2015-13 . Accordingly, the
examining agent may make any necessary
adjustments in any year for which the pe-
riod of limitations on assessment and col-
lection of tax is open to effect compliance
with Hamilton Industries, Inc .
(c) New base year . In effecting a
change to the Used Vehicle Alternative
LIFO Method under this revenue proce-
dure, the taxpayer must retain any LIFO
inventory cost increments previously
determined and the value of those incre-
ments . Instead of using the earliest taxable
year for which the taxpayer adopted LIFO
as the base year, the taxpayer must use the
year of change as the new base year in de-
termining the value of all existing LIFO
cost increments for the year of change and
later taxable years . (The cumulative index
at the beginning of the year of change is
1 .00) . The taxpayer must restate the base-
year cost of all LIFO cost increments at
the beginning of the year of change in
terms of new base-year costs, using the
year of change as the new base year, and
must recompute the indexes for previ-
ously determined inventory increments
accordingly . The new base-year cost of a
pool is equal to the total current-year cost
of all the vehicles in the pool .
(d) Form 3115 . A completed Form
3115 includes the completion of Part I of
Schedule C .
(4) Concurrent change from IPIC meth-
od . A used vehicle dealer using the IPIC
method that also has parts and accessories,
new automobiles, or new light-duty trucks
(other goods) inventory may incorpo-
rate a change, using a cut-off basis, from
IPIC to another acceptable LIFO method
for those other goods into this change .
When changing from IPIC to a dollar-val-
ue LIFO method for its other goods, the
used vehicle dealer must establish sepa-
rate inventory pools for new automobiles
and new light-duty trucks, unless the used
vehicle dealer also concurrently changes
to the Vehicle-Pool Method (see section
23 .08 of this revenue procedure) . Further,
the used vehicle dealer must establish a
separate inventory pool for the parts and
accessories . See section 6 .03(1)(b) of Rev .
Proc . 2015-13 for information on making
concurrent changes .
(5) Concurrent change to the Vehi-
cle-Pool Method . A taxpayer making both
a change to the Used Vehicle Alternative
LIFO Method under this section 23 .04
and a change to the Vehicle-Pool Meth-
od under Rev . Proc . 2008-23 (see section
23 .08 of this revenue procedure) should
file a single Form 3115 for both changes,
in which case the taxpayer must enter the
designated automatic accounting method
change numbers for both changes on the
appropriate line on that Form 3115 . See
section 6 .03(1)(b) of Rev . Proc . 2015-13
for information on making concurrent
changes .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .04 is “59 .”
(7) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.05 Determining the cost of used vehi-
cles purchased or taken as a trade-in .
(1) Description of change .
(a) Applicability . This change applies
to a taxpayer using the LIFO inventory
method that wants to:
(i) determine the cost of used vehicles
acquired by trade-in using the average
wholesale price listed by an official used
vehicle guide on the date of the trade-in .
See Rev . Rul . 67-107, 1967-1 C .B . 115 .
The taxpayer must consistently use the
official used vehicle guide selected unless
the taxpayer receives permission to use a
different guide;
(ii) use a different official used vehicle
guide for determining the cost of used ve-
hicles acquired by trade-in;
(iii) determine the cost of used vehicles
purchased for cash using the actual pur-
chase price of the vehicle; or
(iv) reconstruct the beginning-of-the-
year cost of used vehicles purchased for
cash using values computed by national
auto auction companies based on vehicles
purchased for cash . The national auto auc-
tion company selected must be consistent-
ly used .
(b) Inapplicability . This change does
not apply to a taxpayer that adopted or
changed to the Used Vehicle Alternative
LIFO Method (see section 23 .04 of this
revenue procedure) .
(2) Manner of making change . This
change is made on a cut-off basis and ap-
plies only to used vehicles acquired on or
after the beginning of the year of change .
Accordingly, a § 481(a) adjustment is nei-
ther permitted nor required .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .05 is “60 .”
(4) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.06 Change to the inventory price index
computation (IPIC) method .
(1) Description of change . This change
applies to a taxpayer that wants to change:
(a) from a non-IPIC LIFO inventory
method to the IPIC method in accordance
with all relevant provisions of § 1 .472-
8(e)(3); or
(b) from the IPIC method as described
in T .D . 7814, 1982-1 C .B . 84, (March 15,
1982) (the old IPIC method) to the IPIC
method as described in § 1 .472-8(e)(3)
(see T .D . 8976, 2002-1 C .B . 421, (January
8, 2002)) (the new IPIC method), which

November 25, 2019 1198 Bulletin No. 2019–48
includes the following required changes
(if applicable):
(i) from using 80% of the inventory
price index (IPI) to using 100% of the IPI
to determine the base-year cost and dol-
lar-value of a LIFO pool(s);
(ii) from using a weighted arithme-
tic mean to using a weighted harmonic
mean to compute an IPI for a dollar-value
pool(s); and
(iii) from using a components-of-cost
method to define inventory items to using
a total-product-cost method to define in-
ventory items .
(2) Manner of making change . This
change is made on a cut-off basis and ap-
plies only to the computation of ending
inventories after the beginning of the year
of change . Accordingly, a § 481(a) adjust-
ment is neither permitted nor required .
(3) Bargain purchase . If the taxpay-
er has previously improperly accounted
for a bulk bargain purchase, the taxpayer
must, as part of this change, first change
its method of accounting to comply with
Hamilton Industries, Inc. v. Commission-
er, 97 T .C . 120 (1991), and compute a
§ 481(a) adjustment for that part of the
change . See Announcement 91-173,
1991-47 I .R .B . 29 . Upon examination,
if a taxpayer has properly changed under
this section 23 .06 except for complying
with section 23 .06(3) of this revenue
procedure, an examining agent may not
deny the taxpayer the change . However,
the taxpayer does not receive audit pro-
tection under section 8 .01 of Rev . Proc .
2015-13, 2015-5 I .R .B . 419, with respect
to the improper method of accounting for
the bargain purchase . See section 8 .02(2)
of Rev . Proc . 2015-13 . Accordingly, the
examining agent may make any neces-
sary adjustments in any year for which
the period of limitations on assessment
and collection of tax is open to effect
compliance with Hamilton Industries,
Inc.
(4) Concurrent automatic changes .
(a) A taxpayer making this change and
to change its method of determining cur-
rent-year cost under section 23 .02 of this
revenue procedure for the same year of
change may file a single Form 3115 for
both changes, provided the taxpayer en-
ters the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes .
(b) A taxpayer making this change
and to change its method of pooling to
IPIC-method pools described in § 1 .472-
8(b)(4) or § 1 .472-8(c)(2) under section
23 .07 of this revenue procedure for the
same year of change may file a single
Form 3115, provided the taxpayer en-
ters the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes .
(c) A taxpayer making this change and
to change its method of pooling under sec-
tion 23 .10 of this revenue procedure for
the same year of change may file a sin-
gle Form 3115, provided the taxpayer en-
ters the designated automatic accounting
method change numbers for both changes
on the appropriate line on that Form 3115 .
See section 6 .03(1)(b) of Rev . Proc . 2015-
13 for information on making concurrent
changes .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .06 is “61 .”
(6) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.07 Changes within the inventory price
index computation (IPIC) method .
(1) Description of change . This change
applies to a taxpayer using the IPIC meth-
od described in § 1 .472-8(e)(3) as revised
by T .D . 8976, 2002-1 C .B . 421, (new IPIC
method) that wants to make one or more
of the following changes:
(a) change from the double-extension
IPIC method to the link-chain IPIC meth-
od, or vice versa . See § 1 .472-8(e)(3)(iii)
(E) for principles concerning the compu-
tation of the inventory price index under
the double-extension IPIC method and the
link-chain IPIC method;
(b) change to or from the 10 percent
method . See § 1 .472-8(e)(3)(iii)(C) for
principles concerning the assignment of
inventory items to Bureau of Labor Sta-
tistics (BLS) categories under the IPIC
method;
(c) change to IPIC-method pools de-
scribed in § 1 .472-8(b)(4) or § 1 .472-8(c)
(2), including a change to begin or discon-
tinue applying one or both of the 5 percent
pooling rules;
(d) change to combine or separate
pools as a result of the application of a 5
percent pooling rule described in § 1 .472-
8(b)(4) or § 1 .472-8(c)(2);
(e) change its selection of BLS table
from Table 3 (Consumer Price Index for
All Urban Consumers (CPI-U): U .S . city
average, detailed expenditure categories)
of the monthly CPI Detailed Report to
Table 9 (Producer price indexes (PPI) and
percent changes for commodity and ser-
vice groupings and individual items, not
seasonally adjusted) of the monthly PPI
Detailed Report (formerly, Table 6), or
vice versa . See § 1 .472-8(e)(3)(iii)(B)(2)
for principles concerning the selection of
a BLS table under the IPIC method;
(f) change the assignment of one or
more inventory items to BLS categories
under either Table 3 (CPI-U): U .S . City
average, detailed expenditure categories)
of the monthly CPI Detailed Report or Ta-
ble 9 (PPI and percent changes for com-
modity and service groupings and individ-
ual items, not seasonally adjusted) of the
monthly PPI Detailed Report (formerly,
Table 6) . See § 1 .472-8(e)(3)(iii)(C) for
principles concerning the assignment of
inventory items to BLS categories under
the IPIC method . As part of this change,
a taxpayer may separate a reassigned item
from an inappropriate pool and combine
the reassigned item with items in an ap-
propriate pool . See § 1 .472-8(g)(2) for
principles concerning the manner of com-
bining and separating dollar-value pools;
(g) change the representative month
when necessitated because of a change
in taxable year or a change in method of
determining current-year cost made pur-
suant to section 23 .02 of this revenue
procedure . See § 1 .472-8(e)(3)(iii)(B)
for principles concerning the determina-
tion of a representative month under the
IPIC method . A change in method of de-
termining current-year cost and a change
of the representative month may be made
using a single Form 3115, provided the
taxpayer enters the designated automatic
accounting method change numbers for
both changes on the appropriate line on
that Form 3115;

Bulletin No. 2019–48 1199 November 25, 2019
(h) change from using preliminary BLS
price indexes to using final BLS price in-
dexes to compute an inventory price in-
dex, or vice versa . See § 1 .472-8(e)(3)(iii)
(D)(2) for principles concerning the selec-
tion of BLS price indexes under the IPIC
method; and
(i) change from using a representative
appropriate month to using an appropriate
month . See § 1 .472-8(e)(3)(iii)(B)(3) for
principles concerning the selection of an
appropriate month .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to the changes de-
scribed in sections 23 .07(1)(d), (f) in the
case of a taxpayer using the 10 percent
method described in § 1 .472-8(e)(3)(iii)
(C)(2), and (g) of this revenue procedure .
(3) Manner of making change .
(a) Cut-off basis . These changes are
made on a cut-off basis and apply only
to the computation of ending inventories
after the beginning of the year of change .
Accordingly, a § 481(a) adjustment is nei-
ther permitted nor required .
(b) New base year . A taxpayer that
changes pursuant to sections 23 .07(1)(a),
(b), and (e) of this revenue procedure must
establish a new base year in the year of
change .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .07 is “62 .”
(5) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.08 Changes to the Vehicle-Pool Meth-
od .
(1) Description of change . This change
applies to a retail dealer or wholesale dis-
tributor (“reseller”) of cars and light-duty
trucks that wants to change to the “Ve-
hicle-Pool Method” as described in Rev .
Proc . 2008-23, 2008-1 C .B . 664 .
(2) Manner of making change .
(a) Cut-off basis . This change is made
on a cut-off basis and applies only to the
computation of ending inventories after
the beginning of the year of change . Ac-
cordingly, a § 481(a) adjustment is nei-
ther permitted nor required . A reseller that
changes its method of pooling under Rev .
Proc . 2008-23 and this section 23 .08 must
comply with § 1 .472-8(g) .
(b) New base year . Instead of using the
earliest taxable year for which the reseller
adopted the LIFO method for any items in
a pool, the reseller must use the year of
change as the base year when determining
the LIFO value of that pool for the year of
change and subsequent taxable years (that
is, the cumulative index at the beginning
of the year of change is 1 .00) . The reseller
must restate the base-year cost of all lay-
ers of increment in a pool at the beginning
of the year of change in terms of new
base-year cost . For an example of estab-
lishing a new base year, see § 1 .472-8(e)
(3)(iv)(B)(1)(ii) .
(3) Concurrent change to the Alterna-
tive LIFO Method or the Used Vehicle Al-
ternative LIFO Method . A reseller making
both a change to the Vehicle-Pool Method
under this section 23 .08 and a change to
the Alternative LIFO Method under Rev .
Proc . 97-36 (see section 23 .03 of this rev-
enue procedure) or the Used Vehicle Al-
ternative LIFO Method under Rev . Proc .
2001-23 (see section 23 .04 of this reve-
nue procedure) should file a single Form
3115 for both changes, in which case the
taxpayer must enter the designated auto-
matic accounting method change numbers
for both changes on the appropriate line
on that Form 3115 . See section 6 .03(1)(b)
of Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
for information on making concurrent
changes .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .08 is “112 .”
(5) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.09 Changes within the used vehicle al-
ternative LIFO method .
(1) Description of change . This change
applies to a taxpayer using the “Used
Vehicle Alternative LIFO Method” as
described in Rev . Proc . 2001-23, 2001-1
C.B. 784, as modified by Announcement
2004-16, 2004-1 C .B . 668, and Rev . Proc .
2008-23, 2008-1 C .B . 664, that wants to
change the particular “official used vehi-
cle guide” utilized by the taxpayer in con-
nection with the Used Vehicle Alternative
LIFO Method or any change in the precise
manner of its utilization (for example, a
change in the specific guide category that
a taxpayer uses to represent vehicles of
average condition for purposes of section
4 .02(5)(a) of Rev . Proc . 2001-23) .
(2) Manner of making change .
(a) Cut-off basis . This change is made
on a cut-off basis and applies only to the
computation of ending inventories after
the beginning of the year of change . Ac-
cordingly, a § 481(a) adjustment is neither
permitted nor required .
(b) New base year . A taxpayer that
changes its method pursuant to this sec-
tion 23 .09 must establish a new base year
in the year of change .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .09 is “140 .”
(4) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
.10 Changes to dollar-value pools of
manufacturers .
(1) Description of change . This change
applies to a manufacturer that:
(a) purchases goods for resale (resale
goods) and, thus, must reassign resale
goods from the pool(s) it maintains for the
goods it manufactures to one or more re-
sale pools;
(b) wants to change from using multi-
ple pools described in § 1 .472-8(b)(3) to
using natural business unit (NBU) pools
described in § 1 .472-8(b)(1), or vice ver-
sa; or
(c) wants to reassign items in NBU
pools described in § 1 .472-8(b)(1) into the
same number or a greater number of NBU
pools .
(2) Manner of making change . This
change is made on a cut-off basis and ap-
plies only to the computation of ending
inventories after the beginning of the year
of change . Accordingly, a § 481(a) adjust-
ment is neither permitted nor required . A
taxpayer that changes its method of pool-
ing pursuant to this section 23 .10 must
combine or separate pools as required by
§ 1 .472-8(g) . If a taxpayer splits a pool
into two or more permissible pools pursu-
ant to this section 23 .10, which must be
implemented on a cut-off basis, the tax-

November 25, 2019 1200 Bulletin No. 2019–48
payer then may file a separate Form 3115
to change from the LIFO inventory meth-
od for one or more of the resulting pools
pursuant to section 23 .01 of this revenue
procedure, which must be implemented
with a § 481(a) adjustment .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
23 .10 is “141 .”
(4) Contact information . For further
information regarding a change under this
section, contact Andrew Braden at (202)
317-7007 (not a toll-free number) .
SECTION 24 . MARK-TO-MARKET
ACCOUNTING METHODS (Including
§ 475 )
.01 Commodities dealers, securities
traders, and commodities traders electing
to use the mark-to-market method of ac-
counting under § 475(e) or (f) .
(1) Description of change . This change
applies to certain taxpayers that have
elected to use the mark-to-market method
of accounting under § 475(e) or (f) . Un-
der § 475(e) and (f) and Rev . Proc . 99-17,
1999-1 C .B . 503, if a taxpayer makes an
election under § 475(e) or (f), then be-
ginning with the first taxable year for
which the election is effective (election
year), mark to market is the only permis-
sible method of accounting for securities
or commodities subject to the election .
Thus, if the electing taxpayer’s method
of accounting for its taxable year imme-
diately preceding the election year is in-
consistent with § 475, the taxpayer is re-
quired to change its method of accounting
to comply with the election . A taxpayer
that makes a § 475(e) or (f) election but
fails to change its method of accounting to
comply with that election is using an im-
permissible method . See section 4 of Rev .
Proc . 99-17 .
(2) Applicability . This change applies
to a taxpayer if all of the following condi-
tions are satisfied:
(a) the taxpayer is a commodities deal-
er, securities trader, or commodities trad-
er that has made a valid election under
§ 475(e) or (f) (see section 5 .03(1) of Rev .
Proc . 99-17) and that is required to change
its method of accounting to comply with
the election;
(b) the method of accounting to which
the taxpayer changes is in accordance
with its election under § 475(e) or (f); and
(c) the year of change is the election
year .
(3) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(4) Election under Rev. Proc. 99-17 . In
accordance with section 5 .03(1) of Rev .
Proc . 99-17, to make a § 475(e) or (f)
election, a taxpayer must file a statement
satisfying the requirements in section 5 .04
of Rev . Proc . 99-17 . The taxpayer must
file the statement not later than the due
date (without regard to any extension) of
the original federal income tax return for
the taxable year immediately preceding
the election year and must attach the state-
ment either to that return or, if applicable,
to a request for an extension of time to
file that return. For example, if a calendar
year individual taxpayer wants to make a
§ 475(e) or (f) election for 2018 (the elec-
tion year), the taxpayer must file the state-
ment on or before April 18, 2018, with the
taxpayer’s timely filed (without regard to
any extension) federal income tax return
for 2017 or the taxpayer’s timely filed re-
quest for an extension of time to file the
2017 federal income tax return . On the
Form 3115 filed for the year of change, a
taxpayer should indicate that the taxpayer
has filed the statement in compliance with
section 5 .03(1) of Rev . Proc . 99-17 .
(5) Limited § 301.9100 relief . Section
301 .9100-3 relief for failure to comply
with the requirements of this section 24 .01
will be granted only in unusual and com-
pelling circumstances .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
24 .01 is “64 .”
(7) Contact information . For further
information regarding a change under this
section, contact Marsha Sabin at (202)
317-6945 (not a toll-free number) .
.02 Taxpayers requesting to change
their method of accounting from the mark-
to-market method of accounting described
in § 475 to a realization method .
(1) Description of change . This
change applies to any taxpayer request-
ing permission to change its method of
accounting for securities or commodities
as defined in § 475 from the mark-to-
market method of accounting described
in § 475 to a realization method of ac-
counting . For example, this section 24 .02
applies when a taxpayer is required to
change its method of accounting to a re-
alization method after revoking an elec-
tion under § 475(e), (f)(1), or (f)(2) . This
change is not limited to a change required
by § 475 (for example, this section 24 .02
applies to a change from a mark-to-mar-
ket method of accounting for notional
principal contracts providing for nonpe-
riodic payments even if the taxpayer is
not subject to § 475) and, in such a case,
references to § 475 in this section 24 .02
are interpreted accordingly . For purposes
of this section 24 .02, a change to a re-
alization method of accounting includes
a change in which the taxpayer also is
required to use a mark-to-market meth-
od of accounting under a specific Code
section to account for all or some of the
taxpayer’s securities or commodities (for
example, § 1256 for commodities) .
(2) Exclusive procedure . The procedure
set forth in this section 24 .02 is the exclu-
sive procedure for changing a taxpayer’s
method of accounting from the mark-to-
market method described in § 475 to a
realization method. Thus, filing the No-
tification Statement described in section
24 .02(6) of this revenue procedure is the
exclusive manner of revoking a § 475(e),
(f)(1), or (f)(2) election . Moreover, any
taxpayer requesting permission to change
to a realization method must follow the
procedures described in this section
24 .02 and other applicable provisions of
Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
to request consent to change its method
of accounting for securities described in
§ 475(c)(2) (Section 475 Securities), com-
modities described in § 475(e)(2) (Section
475 Commodities), or both .
(3) Applicability. This change applies
to a taxpayer if all of the following condi-
tions in paragraphs (a) through (c) below
are satisfied:
(a) the taxpayer is using, properly or
improperly, the mark-to-market method
of accounting described in § 475;
(b) the taxpayer is requesting permis-
sion to change to a realization method of
accounting and report gains or losses from
the disposition of Section 475 Securities,

Bulletin No. 2019–48 1201 November 25, 2019
Section 475 Commodities, or both, under
§ 1001; and
(c) the taxpayer meets the require-
ments of this section 24 .02, including the
requirement that it timely file the Noti-
fication Statement described in section
24 .02(6) of this revenue procedure .
(4) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(d) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(5) Manner of making change . This
change is made using a cut-off basis and
applies only to Section 475 Securities,
Section 475 Commodities, or both, that
are accounted for using the mark-to-mar-
ket method of accounting described in
§ 475 and for which a change in method
is requested under this section 24 .02 . Ac-
cordingly, a § 481(a) adjustment is neither
permitted nor required .
Under the cut-off basis, a taxpayer must
make a final mark of all Section 475 Secu-
rities, Section 475 Commodities, or both,
that are being marked to market and that
are the subject of the accounting method
change being requested, on the last busi-
ness day of the year preceding the year of
change. As a result of the final mark, gain
or loss attributable to those securities and
commodities is also recognized on the last
business day of the year preceding the year
of change . In the case of any Section 475
Security or Section 475 Commodity that a
taxpayer holds on the first day of the year
of change, the taxpayer must make proper
adjustment in the amount of any subse-
quently realized gain or loss to take into
account adjustments for the gain or loss
recognized prior to the first day of the year
of change pursuant to the use of the mark-
to-market method of accounting described
in § 475 in order to prevent amounts from
being duplicated or omitted . Any change
in value on or after the first day of the year
of change will be taken into account using
a realization method of accounting unless
section 24 .02(7) of this revenue procedure
permits the taxpayer to resume a mark-to-
market method and the taxpayer resumes
a mark-to-market method .
(6) Notification Statement required . In
addition to filing the Form 3115 required
under section 6 .03(1) of Rev . Proc . 2015-
13, to change to a realization method of
accounting under this section 24 .02, a tax-
payer must also file a Notification State-
ment that satisfies the requirements in sec-
tion 24 .02(6) of this revenue procedure .
The Notification Statement must be filed
not later than the due date (without regard
to any extension) of the original feder-
al income tax return for the taxable year
immediately preceding the year of change
and must be attached either to that return
or, if applicable, to a request for an exten-
sion of time to file that return.
(a) Notification Statement contents .
The Notification Statement must contain
(1) the name of the taxpayer that will
change its method of accounting (that is,
the applicant), and, if applicable, the filer
(for example, its parent corporation); (2)
a statement that the taxpayer is requesting
to change its method of accounting from
the mark-to-market method of accounting
described in § 475 to a realization method;
(3) the year of change (both the beginning
and ending dates); and (4) the types of in-
struments subject to the method change,
that is, Section 475 Securities, Section 475
Commodities, or both . If a taxpayer has
made an election under § 475(e), (f)(1),
or (f)(2), the taxpayer must also include a
statement revoking the taxpayer’s section
475 election or elections for the Section
475 Securities, Section 475 Commodities,
or both, for which a change in accounting
method is sought .
(b) Effect of filing Notification State-
ment. Once the taxpayer files a Notifica-
tion Statement for the year of change, a
realization method of accounting is the
only permissible method of accounting
for Section 475 Securities, Section 475
Commodities, or both, described in the
Notification Statement for the entire year
of change and all subsequent years (unless
section 24 .02(7)(a) of this revenue proce-
dure applies). A taxpayer that files the No-
tification Statement described in this sec-
tion 24 .02 but fails to change its method of
accounting using the procedures described
in Rev . Proc . 2015-13 and this section
24 .02 is using an impermissible method .
(c) Limited § 301.9100 relief . Section
301 .9100 relief for failure to comply with
the requirements of this section 24 .02(6)
will be granted only in unusual and com-
pelling circumstances .
(7) Additional requirements .
(a) Resuming the mark-to-market
method of accounting . A taxpayer may
not use the automatic change procedures
in Rev . Proc . 2015-13 and section 24 .01
of this revenue procedure to resume using
the mark-to-market method of accounting
described in § 475 for the Section 475
Securities, Section 475 Commodities, or
both, that are the subject of the method
change being requested using this section
24.02 during any of the five taxable years
beginning with the year of change . To re-
sume using the mark-to-market method
of accounting described in § 475 during
this 5-year period, a taxpayer must: (i) re-
quest the change using the non-automatic
change procedures in Rev . Proc . 2015-13,
(ii) request the change by the date an elec-
tion for the year of change would be due
under section 5 .03 of Rev . Proc . 99-17,
1999-1 C .B . 503, and (iii) include a state-
ment that satisfies all applicable require-
ments of section 5 .04 of Rev . Proc . 99-17 .
(b) Copy of Notification Statement . A
taxpayer must attach a copy of the No-
tification Statement required in section
24 .02(6) of this revenue procedure to its
Form 3115 filed under this section 24.02.
(c) No audit protection for valuation .
A taxpayer does not receive audit pro-
tection under section 8 .01 of Rev . Proc .
2015-13 for the method of valuation used
by the taxpayer to determine the fair mar-
ket value of the taxpayer’s Section 475
Securities, Section 475 Commodities, or
both, for a taxable year prior to the year of
change, or for a failure to comply with the
requirements in Rev . Proc . 99-17 to prop-
erly elect the mark-to-market method . See
section 8 .02(2) of Rev . Proc . 2015-13 .
(8) Designated automatic accounting
method change number. The designat-
ed automatic accounting method change
number for a change under this section
24 .02 is “218” .
(9) Contact information. For further
information regarding a change under this
section, contact Marsha Sabin at (202)
317-6945 (not a toll-free number) .
SECTION 25 . BANK RESERVES FOR
BAD DEBTS (§ 585)
.01 Changing from the § 585 reserve
method to the § 166 specific charge-off
method .
(1) Description of change .
(a) Applicability . This change applies
to a bank (as defined in § 581, including
a bank for which a qualified subchapter

November 25, 2019 1202 Bulletin No. 2019–48
S subsidiary (Qsub) election is filed) that
wants to change its method of accounting
for bad debts from the § 585 reserve meth-
od to the § 166 specific charge-off method.
(b) Inapplicability . This change does
not apply to a large bank as defined in
§ 585(c)(2) .
(2) Certain eligibility rule inapplica-
ble . A bank that changed from the § 593
reserve method under § 593(g) to the
§ 585 reserve method is not prohibited un-
der section 5 .01(1)(f) of Rev . Proc . 2015-
13, 2015-5 I .R .B . 419, from changing its
method of accounting for bad debts under
this section 25 .01 solely because of the
§ 593(g) change . A bank for which a Qsub
election is filed will not be prohibited un-
der section 5 .01(1)(f) of Rev . Proc . 2015-
13 from changing its method of account-
ing for bad debts under this section 25 .01
solely because of the deemed liquidation
of the bank arising from a Qsub election .
(3) Section 481(a) adjustment . Gener-
ally, the amount of the § 481(a) adjustment
for a change in method of accounting un-
der this section 25 .01 is the amount of the
bank’s reserve for bad debts as of the close
of the taxable year immediately before the
year of change . However, the amount of
the § 481(a) adjustment does not include
the amount of a bank’s pre-1988 reserves
(as described in § 593(g)(2)(A)(ii), with-
out taking into account § 593(g)(2)(B))
if the bank changed in a prior year from
the § 593 reserve method to the § 585 re-
serve method and § 593(g) applied to that
change . The deemed liquidation of a bank
occurring solely because its parent makes
a Qsub election does not accelerate the
§ 481(a) adjustment . In accordance with
section 7 .03(4)(a) of Rev . Proc . 2015-13, a
bank that ceases to be a bank under § 581
must accelerate its § 481(a) adjustment .
(4) Change from § 585 required when
electing S corporation status .
(a) General rule . A bank electing S
corporation status (or a bank for which
a Qsub election is filed) cannot use the
§ 585 reserve method. The filing by a bank
of a Form 2553, Election by a Small Busi-
ness Corporation, or the filing by a bank’s
parent of Form 8869, Qualified Subchap-
ter S Subsidiary Election, with respect to
the bank will constitute an agreement by
the bank to change its method of account-
ing for bad debts from the § 585 reserve
method to the § 166 specific charge-off
method effective as of the taxable year for
which the S corporation election or Qsub
election is effective (year of change) in ac-
cordance with all of the automatic change
procedures of Rev . Proc . 2015-13 and this
section 25 .01 . The resulting § 481(a) ad-
justment is recognized built-in gain un-
der § 1374, unless the bank elects under
§ 1361(g) and section 25 .01(4)(b) of this
revenue procedure to take the § 481(a)
adjustment into account in determining
taxable income for the taxable year imme-
diately preceding the year of change . See
§ 1 .1374-4(d) .
(b) Election to include § 481(a) adjust-
ment in taxable year immediately preced-
ing the year of change .
(i) Election requirements . A bank that
changes its method of accounting for bad
debts under this section 25 .01, from the
§ 585 reserve method to the § 166 specif-
ic charge-off method for the first taxable
year for which the bank’s S corporation
election is effective (year of change) may
elect under § 1361(g) to take into account
the amount of the resulting § 481(a) ad-
justment in determining taxable income
for the taxable year immediately preced-
ing the year of change . To make this elec-
tion, a bank must (1) file an original and
copy of Form 3115 under section 6 .03(1)
of Rev . Proc . 2015-13 (and any other copy
required under section 6 .03) for the year
of change, (2) file an additional copy of
the Form 3115 with its original (or amend-
ed) federal income tax return for the tax-
able year immediately preceding the year
of change filed no later than the date the
original Form 3115 is properly filed un-
der section 6 .03(1) of Rev . Proc . 2015-13
(and any other copy required under sec-
tion 6 .03) and (3) include the amount of
the § 481(a) adjustment in gross income
for the taxable year immediately preced-
ing the year of change . The bank must at-
tach a statement to the original and both
copies of Form 3115 stating that the bank
elects under § 1361(g) to take the § 481(a)
adjustment into account in determining
taxable income for the taxable year imme-
diately preceding the year of change .
(ii) Special rule for Qsub banks . In the
case of a Qsub bank, the S corporation
parent must file an original and copy of
Form 3115 under section 6 .03(1) of Rev .
Proc . 2015-13 for the year of change . The
Qsub bank must file an additional copy of
the Form 3115 with its original (or amend-
ed) federal income tax return for the tax-
able year immediately preceding the year
of change filed no later than the date the
original Form 3115 is properly filed under
section 6 .03(1) of Rev . Proc . 2015-13, and
include the amount of the § 481(a) adjust-
ment in gross income for the taxable year
immediately preceding the year of change .
In the case of a Qsub bank, the Form 3115
should indicate that the “filer” is the S cor-
poration parent and the “applicant” is the
Qsub bank .
(iii) The following example illustrates
the principles of section 25 .01(4)(b) of
this revenue procedure .
Example . X, a calendar year taxpayer, is a calen-
dar year bank as defined in § 581 and is not a large
bank as defined in § 585(c)(2). For taxable years be-
fore 2015, X accounted for its bad debts under the
§ 585 reserve method . By March 15, 2015, X prop-
erly filed a Form 2553 electing to be an S corpora-
tion effective January 1, 2015 . Pursuant to section
25.01(4)(a) of this revenue procedure, the filing of
the Form 2553 constituted an agreement by X to
change from the § 585 reserve method to the § 166
specific charge-off method for 2015 in accordance
with all of the automatic change procedures of Rev .
Proc . 2015-13, and the applicable provisions of this
section 25 .01 . Thus, for example, X must file a Form
3115 for this 2015 change in duplicate, in accordance
with section 6 .03(1) of Rev . Proc . 2015-13, by at-
taching the original Form 3115 to X’s timely filed
(including any extension) original federal income
tax return for 2015 and filing a copy of the Form
3115 with the Ogden, UT, office. The amount of X’s
§ 481(a) adjustment for the change is the amount of
X’s bad debt reserve as of the close of December 31,
2014 . X wishes to elect under § 1361(g) to include
the § 481(a) adjustment in income in the taxable year
ending December 31, 2014, the taxable year imme-
diately preceding the year of change . To make this
election, X must (1) file an original and copy of Form
3115 for the 2015 change under section 6 .03(1) of
Rev. Proc. 2015-13, (2) file an additional copy of that
Form 3115 with its original (or amended) federal in-
come tax return for 2014 filed no later than the date
the original Form 3115 is properly filed under sec-
tion 6 .03(1) of Rev . Proc . 2015-13, and (3) include
the amount of its § 481(a) adjustment in gross in-
come in its return for 2014 . X must attach a statement
to the original and both copies of Form 3115 stating
that X elects under § 1361(g) to take the § 481(a) ad-
justment into account in determining taxable income
for 2014, the taxable year immediately preceding the
year of change .
(5) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
25 .01 is “66 .”
(6) Contact information . For further
information regarding a change under this
section, contact K . Scott Brown at (202)

Bulletin No. 2019–48 1203 November 25, 2019
317-6945, Laura Fields at (202) 317-
6850, or Adrienne Mikolashek at (202)
317-6850 (not toll-free numberss) .
SECTION 26 . INSURANCE
COMPANIES (§§ 807, 816, 832, 833)
.01 Safe harbor method of accounting
for premium acquisition expenses .
(1) Description of change . Rev . Proc .
2002-46, 2002-2 C .B . 105, sets forth
a safe harbor method of accounting for
premium acquisition expenses of certain
non-life insurance companies . Under this
method, an insurance company is per-
mitted to treat as premium acquisition
expenses incurred for the taxable year
an amount equal to the sum of (a) the
amount of premium acquisition expens-
es paid during the taxable year; (b) the
difference between the unpaid premium
acquisition expenses shown on the com-
pany’s annual statement for the taxable
year and the unpaid premium acquisi-
tion expenses shown on the company’s
annual statement for the preceding tax-
able year; and (c) the difference between
the amount of the insurance company’s
pro forma premium acquisition expens-
es at the end of the taxable year and the
company’s pro forma premium acquisi-
tion expenses at the end of the preceding
taxable year . The amount taken into ac-
count as a net increase in the pro forma
premium acquisition expenses, however,
cannot exceed the insurance company’s
unearned premium reserve offset amount
for that year . A special rule applies to pre-
mium acquisition expenses with respect
to certain contracts with installment pre-
miums . See Rev . Proc . 2002-46 .
(2) Applicability . The automatic
change in this section 26 .01 applies to any
insurance company that is subject to tax
under § 831(a) and determines its premi-
ums earned for insurance contracts during
the taxable year under § 832(b)(4) in ac-
cordance with the provisions of § 1 .832-4 .
The automatic change does not apply to an
existing Blue Cross or Blue Shield organi-
zation or any other organization to which
§ 833 applies .
(3) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(d) and (f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, do not apply to this
change .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
26 .01 is “67 .”
(5) Contact information . For further
information regarding a change under
this section, contact Rebecca L . Baxter at
(202) 317-6995 (not a toll-free number) .
.02 Certain changes in method of ac-
counting for organizations to which § 833
applies
(1) Description of change . This change
applies to an existing Blue Cross or Blue
Shield organization within the meaning of
§ 833(c)(2), or an organization described
in § 833(c)(3), that is required to change
its method of accounting for unearned
premiums by reason of failing to meet the
Medical Loss Ratio (MLR) requirements
of § 833(c)(5), or by reason of meeting
the MLR requirements of § 833(c)(5) af-
ter failing to meet those requirements in
a prior year . See Notice 2011-4, 2011-2
I .R .B . 282 .
(2) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(d) and (f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, do not apply to this
change .
(3) Accelerated § 481(a) adjustment
period in certain situations . In addition
to the circumstances set forth in section
7 .03(4) of Rev . Proc . 2015-13, the § 481
adjustment period provided in section
7 .03 of Rev . Proc . 2015-13 will be accel-
erated in the event a taxpayer with a re-
maining balance of a § 481(a) adjustment
that arose by reason of a change in meth-
od of accounting described in this section
26 .02 is required to effect another change
in method of accounting described in this
section 26 .02 . Thus, for example, a tax-
payer that fails to satisfy the requirements
of § 833(c)(5) and as a result has a positive
§ 481(a) adjustment, is required to accel-
erate the remaining balance, if any, of that
adjustment in a subsequent taxable year
in which the taxpayer meets the require-
ments of § 833(c)(5) .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
26 .02 is “155 .”
(5) Contact information . For further in-
formation regarding this section, contact
Rebecca L . Baxter at (202) 317-6995 (not
a toll-free number) .
.03 Change in qualification as life/non-
life insurance company under § 816 .
(1) Description of change . This change
applies to an insurance company that
changes from being taxed as a life insur-
ance company under part I of subchapter
L to being taxed as a non-life insurance
company under part II of subchapter L, or
vice versa . Whether an insurance compa-
ny is taxed under § 801 as a life insurance
company under part I of subchapter L is
determined under § 816 .
(2) Certain eligibility rules inappli-
cable . The eligibility rules in sections
5 .01(1)(d) and (f) of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, do not apply to this
change .
(3) No audit protection or ruling on
qualification as a life insurance company .
The taxpayer does not receive either: (a)
any audit protection under section 8 .01 of
Rev . Proc . 2015-13 or (b) ruling reliance
under section 10 of Rev . Proc . 2015-13 in
connection with the consent granted un-
der section 9 of Rev . Proc . 2015-13 for a
change under this section 26 .03 regarding
whether the taxpayer qualifies as a life in-
surance company . The director will ascer-
tain whether the taxpayer qualifies as a life
insurance company .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
26 .03 is “219 .”
(5) Contact information . For further
information regarding a change under
this section, contact Rebecca L . Baxter at
(202) 317-6995 (not a toll-free number) .
.04 Changes in basis of computing re-
serves under § 807(f) .
(1) Description of change and appli-
cability . This automatic change applies
to a change in basis for determining any
item referred to in § 807(c), as described
in § 807(f), by a life insurance company or
by an insurance company that is not a life
insurance company . However, this sec-
tion 26 .04 does not apply to any change
in method of accounting to which Rev .
Proc . 2019-30, 2019-33 I .R .B . 638, or
Rev . Proc . 2019-34, 2019-35 I .R .B . 669,
applies .
(2) Manner of making change .

November 25, 2019 1204 Bulletin No. 2019–48
(a)(i) In general . If the basis of com-
puting any item referred to in § 807(c)
is changed during a taxable year (year
of change), then for purposes of apply-
ing § 807(a) and (b) with respect to con-
tracts issued before the year of change,
the amount of the item at the close of the
year of change attributable to those con-
tracts is determined on the old basis and
the amount of the item at the opening of
the succeeding taxable year attributable to
those contracts is determined on the new
basis . The amount of such item attribut-
able to contracts issued during the year of
change and thereafter must be computed
on the new basis .
(ii) Requirement to file Form 3115 . A
taxpayer that changes its basis of com-
puting any item referred to in § 807(c)
is subject to the procedures that apply to
obtain the automatic consent of the Com-
missioner to change a method of account-
ing . Under these procedures, (A) the tax-
payer must file Form 3115 as provided in
this section 26 .04, (B) the taxpayer will
receive audit protection for taxable years
prior to the year of change provided the
requirements in section 8 .01 of Rev . Proc .
2015-13, 2015-5 I.R.B. 419, are satisfied
in connection with the change, and (C) the
§ 481(a) adjustment period generally will
be one taxable year (year of change) for
a negative § 481(a) adjustment, and four
taxable years (year of change and the next
three taxable years) for a positive § 481(a)
adjustment in accordance with section
7 .03(1) of Rev . Proc . 2015-13 .
(iii) Example . The following example illus-
trates the rules of sections 26 .04(2)(a)(i) and (ii)
of this revenue procedure in two situations: (A) the
change in basis in computing life insurance reserves
(reserves) for contracts issued prior to the year of
change results in an increase in the reserves at the
end of the year of change (negative § 481(a) adjust-
ment) and (B) the change in basis in computing re-
serves for contracts issued prior to the year of change
results in a decrease in the reserves at the end of the
year of change (positive § 481(a) adjustment) . The
following table summarizes the reserve amounts for
contracts issued before the year of change .
Old BasisNew Basis
(Negative § 481(a) Adjustment)
New Basis
(Positive § 481(a) Adjustment)
End of Year Prior to Year of Change100
End of Year of Change105109101
End of Year Following Year of Change112104
Section 481(a) Adjustment105-109=(4)105-101=4
Under section 26 .04(2)(a)(i) of this revenue pro-
cedure, reserves for contracts issued before the year
of change are reported under the old basis at the
close of the year of change and under the new ba-
sis at the beginning of the year following the year of
change; reserves for contracts issued during the year
of change and thereafter are computed under the new
basis . The remainder of this example describes only
the deductions and income inclusions relating to re-
serves for contracts issued before the year of change .
Deduction for a net increase in reserves for the
year of change . In both the negative and positive §
481(a) adjustment situations, the company must take
$105 of reserves into account (on the old basis) at
the end of the year of change, resulting in a $5 in-
crease in reserves ($105 - $100) and a corresponding
deduction for a net increase in reserves for the year
of change .
Negative § 481 adjustment situation . As de-
scribed in section 26 .04(2)(a)(ii) of this revenue
procedure, the negative § 481(a) adjustment of $4
($109-$105) is taken into account in the year of
change, such that the company recognizes a deduc-
tion for an increase in reserves under § 807(f) of $4
in the year of change . This results in total deductions
in the year of change of $9 ($5 + $4) .
At the beginning of the following year, the com-
pany must take $109 of reserves into account (new
basis) and the deduction for the net increase in re-
serves for that year is $3 ($112 - $109) .
Positive § 481 adjustment situation . As described
in section 26 .04(2)(a)(ii) of this revenue procedure,
the positive § 481(a) adjustment of $4 ($101-$105)
is taken into account over four years, such that the
company recognizes additional income from a de-
crease in reserves under § 807(f) of $1 (1/4th of the §
481(a) adjustment) in the year of change . This results
in a net reduction in taxable income in the year of
change of $4 ($5 - $1) .
At the beginning of the following year, the com-
pany takes $101 of reserves into account (new ba-
sis), and the deduction for the net increase in reserves
for that year is $3 ($104 - $101) . The company also
recognizes another 1/4th of the § 481(a) adjustment,
resulting in a $1 increase in income due to a decrease
in reserves under § 807(f) and a net reduction in tax-
able income of $2 ($3 - $1) in that year . The remain-
ing $2 of the § 481(a) adjustment is recognized as a
$1 increase in income due to a decrease in reserves
under § 807(f) in each of the two remaining years of
the § 481(a) adjustment period .
(b) Section 481(a) adjustment .
(i) Computation of § 481(a) adjust-
ment at end of year . In general, a change
in basis of computing any item referred to
in § 807(c), as described in § 807(f), re-
quires an adjustment under § 481(a) . The
§ 481(a) adjustment is computed as of the
end of the year of change and is only with
respect to contracts issued before the year
of change .
(ii) Number of § 481(a) adjustments .
Multiple changes during the same taxable
year in methods, assumptions, or factors,
each of which alone would constitute a
change in basis of computing any item
referred to in § 807(c), as described in §
807(f), for the same type of contract, are
considered a single change in basis, and
the effects of such multiple changes are
netted and treated as a single net nega-
tive § 481(a) adjustment or net positive
§ 481(a) adjustment . A separate § 481(a)
adjustment must be determined for each
type of contract, and each such § 481(a)
adjustment must be taken into account
separately .
(iii) Termination of life insurance
company status . Except as provided in
§ 381(c)(22), if for any taxable year a tax-
payer that was a life insurance company
for the year of change is no longer a life in-
surance company, the taxpayer must take
into account the balance of any § 481(a)
adjustment in the preceding taxable year .
See § 807(f)(2) .
(c) No ruling protection for year of
change or subsequent years . The consent
granted under section 9 of Rev . Proc .
2015-13 for a change under this section
26 .04 is not a determination by the Com-
missioner that the new basis of comput-
ing any item referred to in § 807(c) is a
permissible basis of computing such item
and does not create any presumption that
the new basis is a permissible basis of
computing such item . The director may
ascertain whether the new method of ac-
counting is a permissible method of ac-
counting . Thus, a taxpayer that changes
its basis of computing any item referred

Bulletin No. 2019–48 1205 November 25, 2019
to in § 807(c) under this section 26 .04
may be required to change or modify that
basis of computing such item for the year
of change or any subsequent year if it is
determined by the Commissioner that the
basis to which the taxpayer changed does
not meet the requirements of federal in-
come tax law .
(d) Information required to be fur-
nished .
(i) In view of the amendment of §
807(f) by section 13513 of the Tax Cuts
and Jobs Act, Pub . L . No . 115-97 (Decem-
ber 22, 2017) and the information required
in section 26 .04(2)(d)(ii) of this revenue
procedure, the information required un-
der § 1 .801-5(c) is not required to be fur-
nished with the taxpayer’s return or on
Form 3115 .
(ii) A taxpayer that files a Form 3115
under this section 26 .04 is required to
complete or provide only the following
information on Form 3115:
A. The identification section of page 1
(above Part I);
B . The signature section at the bottom of
page 1;
C . Part I;
D . Part II, lines 4, 5, 6a-d, 7a-b, 8a-d, 9,
11a-c, 12, 17, and 18;
E . The following information, in lieu of
completing Part II, line 14:
• The item in § 807(c) to which the
change in basis relates,
• The type of contract to which the
change relates,
• If a life insurance reserve, a descrip-
tion of the applicable tax reserve
method (e .g ., Commissioners’
Reserve Valuation Method or
Commissioners’ Annuity Re-
serve Valuation Method),
• A description of the change in basis,
• A description of the reason for the
change in basis, including (i)
whether the change results from
a change in the method pre-
scribed by the National Associa-
tion of Insurance Commissioners
or from another change (such as
a change in assumption for mor-
tality, morbidity, or interest rate),
regardless of whether the change
is reflected on an annual state-
ment and (ii) whether the change
results from a prior incorrect ap-
plication of federal income tax
law and the nature of such incor-
rect application .
F . Part IV . (The taxpayer may indicate
that the § 481(a) adjustment is an es-
timate or is to be determined .)
(e) Concurrent automatic changes . A
taxpayer that makes multiple changes in
basis under this section 26.04 may file
a single Form 3115 that includes all the
changes in basis for the year of change .
Likewise, a single Form 3115 may be filed
for all changes in basis for members of a
group filing a consolidated return. The in-
formation required by section 26 .04(2)(d)
(ii) of this revenue procedure is required
for each separate change for each member
of the group .
(f) Certain eligibility rule inapplicable .
The eligibility rule in section 5 .01(1)(f)
of Rev . Proc . 2015-13 does not apply to a
change under this section 26 .04 .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
26 .04 is “240 .”
(4) Contact information . For further
information regarding a change under this
section, contact Dan Phillips at (202) 317-
6995 (not a toll-free number) .
SECTION 27 . DISCOUNTED UNPAID
LOSSES (§ 846)
.01 Composite method for discounting
unpaid losses .
(1) Description of change . Section
846 defines “discounted unpaid losses”
for purposes of computing the insurance
company taxable income of certain insur-
ance companies . Notice 88-100, 1988-2
C .B . 439, section V, sets forth a composite
method for computing unpaid losses with
respect to accident years not separately
stated on the NAIC annual statement . Rev .
Proc . 2002-74, 2002-2 C .B . 980, section
3.01, clarifies that the composite method
of Notice 88-100, section V, is permitted,
but not required; section 3 .02 sets forth an
alternative method for those taxpayers that
do not use the composite method of sec-
tion 3 .01 . An insurance company using a
method provided in section 3 .01 or 3 .02 of
Rev . Proc . 2002-74 to compute discounted
unpaid losses, must use the same method
to compute discounted estimated salvage
recoverable . An insurance company that
currently uses a permissible method of
accounting for discounted unpaid losses
may change its method of accounting to
or from the composite method of Notice
88-100, section V, without the consent of
the Commissioner . This change applies to
insurance companies that are required to
discount unpaid losses under § 846 . See
Rev . Proc . 2002-74 .
(2) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
27 .01 is “68 .”
(3) Contact information . For further
information regarding a change under
this section, contact Rebecca L . Baxter at
(202) 317-6995 (not a toll-free number) .
SECTION 28 . REAL ESTATE
MORTGAGE INVESTMENT
CONDUIT (REMIC) (§§ 860A-860G)
.01 REMIC inducement fees .
(1) Description of change . A taxpayer
that receives an inducement fee in connec-
tion with becoming the holder of a noneco-
nomic residual interest in a REMIC must
take that fee into account over the remain-
ing expected life of the applicable REMIC
in accordance with § 1 .446-6 . This change
applies to a taxpayer that seeks to change
from any method of accounting for such
inducement fees to one of the safe harbor
methods provided under § 1 .446-6(e)(1)-
(2) . See Rev . Proc . 2004-30, 2004-1 C .B .
950, for additional guidance relating to
this change .
(2) Manner of making change . A tax-
payer making this change must identify
the specific safe harbor method under
§ 1 .446-6(e) to which the taxpayer is
changing .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
28 .01 is “79 .”
(4) Contact information . For further
information regarding a change under this
section, contact John W . Rogers, III at
(202) 317-6895 (not a toll-free number) .
SECTION 29 . FUNCTIONAL
CURRENCY (§ 985)
.01 Change in functional currency .

November 25, 2019 1206 Bulletin No. 2019–48
(1) Description of change . This change
applies to a taxpayer that wants to change
its functional currency or the function-
al currency of a qualified business unit
(QBU) of the taxpayer . The preceding
sentence does not apply to a QBU of a
taxpayer described in § 1 .985-1(b)(1)(iii) .
(2) Manner of making change . A tax-
payer making this change must make all
necessary adjustments required by such
change . See §§ 1 .985-5, 1 .985-8(c) . A tax-
payer must attach a statement to the Form
3115 representing that it has made the ad-
justments set forth in § 1 .985-5 or § 1 .985-
8(c) . The statement must also provide the
amount of any unrealized exchange gain or
loss required to be taken into account pur-
suant to § 1 .985-5 or § 1 .985-8(c) and the
date on which a taxpayer took such amount
into account . Finally, the statement must
provide a detailed and complete descrip-
tion of any other adjustments required pur-
suant to § 1 .985-5 or § 1 .985-8(c) .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
29 .01 is “70 .”
(4) Contact information . For further
information regarding a change under
this section, contact Peter Merkel at (202)
317-4919 (not a toll-free number) .
SECTION 30 . ORIGINAL ISSUE
DISCOUNT (§§ 1272, 1273)
.01 De minimis original issue discount
(OID) .
(1) Description of change . This change
applies to a taxpayer that wants to change
to the principal-reduction method of ac-
counting described in section 5 of Rev .
Proc . 97-39, 1997-2 C .B . 485 . The prin-
cipal-reduction method of accounting is
an aggregate method of accounting for de
minimis OID (discount) on certain loans
originated by the taxpayer .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(3) Description . The principal-reduc-
tion method of accounting is a permissible
method for use by taxpayers to account
for discount on one or more categories of
loans described in section 4 .02 or 4 .03 of
Rev . Proc . 97-39 . If the principal-reduc-
tion method is used to account for any
loans in a category of loans, the method
must be used for the entire category of
loans . The principal-reduction method ap-
plies only to loans described in section 3
of Rev . Proc . 97-39 .
(4) Manner of making change .
(a) This change is made on a cut-off
basis and applies only to loans described
in section 3 of Rev . Proc . 97-39 that were
acquired on or after the beginning of the
year of change . Accordingly, a § 481(a)
adjustment is neither permitted nor re-
quired .
(b) The taxpayer must maintain books
and records sufficient to satisfy the direc-
tor that old and new loans have been ade-
quately segregated .
(5) Additional requirements . On a
statement attached to the Form 3115, the
taxpayer must:
(a) identify the categories of loans to
which the proposed method will apply;
and
(b) describe any “additional catego-
ries” permitted under section 4 .03 of Rev .
Proc . 97-39 .
(6) No audit protection . A taxpayer
does not receive audit protection under
section 8 .01 of Rev . Proc . 2015-13 in
connection with this change . See section
8 .02(2) of Rev . Proc . 2015-13 .
(7) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
30 .01 is “72 .”
(8) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
.02 Proportional method of accounting
for OID on a pool of credit card receiv-
ables .
(1) Description of change . This change
applies to a taxpayer that wants to change
to the proportional method of accounting
for OID on a pool of credit card receiv-
ables as described in Rev . Proc . 2013-26,
2013-22 I .R .B . 1160 .
(2) Manner of making change . This
change is made on a cut-off basis . Accord-
ingly, a § 481(a) adjustment is neither re-
quired nor permitted . The unaccrued OID
for the pool as of the beginning of the first
period in the year of change is equal to the
unaccrued OID for the pool as of the end
of the preceding year under the taxpayer’s
previous method of accounting for the
pool .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
30 .02 is “183 .”
(4) Contact information . For further
information regarding this section, please
contact Charles W . Culmer at (202) 317-
6945 (not a toll-free number) .
SECTION 31 . MARKET DISCOUNT
BONDS (§ 1278)
.01 Revocation of § 1278(b) election .
(1) Description of change . This change
applies to a taxpayer that wants to change
its method of accounting for market dis-
count bonds by revoking its § 1278(b)
election . Under § 1278(b), a taxpayer
may elect a method of accounting un-
der which market discount is currently
included in gross income for the tax-
able years to which the discount is at-
tributable . See Rev . Proc . 92-67, 1992-2
C .B . 429, for the procedures to make a
§ 1278(b) election (including a deemed
§ 1278(b) election for certain taxable
years) . For purposes of this section 31 .01,
a taxpayer also is treated as having made
a deemed § 1278(b) election for a taxable
year if, for one or more market discount
bonds that were acquired by the taxpayer
during that taxable year, the taxpayer in-
cludes in gross income on the tax return
for that taxable year and on the tax return
for the following taxable year the market
discount attributable to each taxable year,
other than as a result of a disposition of
the bond or a partial principal payment on
the bond . The procedures for revoking a
§ 1278 election were formerly provided
in section 7 of Rev . Proc . 92-67 .
(2) Revocation of election . The revoca-
tion of a § 1278(b) election (or a deemed
§ 1278(b) election) applies to all market
discount bonds that are held by the tax-
payer on the first day of the first taxable
year for which the revocation is effec-
tive (year of change), and to all market
discount bonds that are subsequently ac-
quired by the taxpayer . If a § 1278(b) elec-
tion (or a deemed § 1278(b) election) is
revoked, then for purposes of § 1278(a),
accrued market discount with respect to

Bulletin No. 2019–48 1207 November 25, 2019
any bond previously subject to the elec-
tion means accrued market discount as
defined in § 1276(b) less any market dis-
count included in income while the bond
was subject to the § 1278(b) election (or
the deemed § 1278(b) election) .
(3) Manner of making change . This
change is made on a cut-off basis and
applies only to market discount accruing
on or after the beginning of the year of
change . Accordingly, a § 481(a) adjust-
ment is neither permitted nor required .
Market discount accruing on a bond pri-
or to the year of change was currently
included in income and market discount
accruing on the bond on and after the first
day of the year of change is included in
income generally upon disposition of the
bond . See § 1276(a) . Because a cut-off
basis is prescribed for this change, the
basis of any bond, adjusted for amounts
previously included in income during the
period of the election, is not affected by
the revocation .
(4) Additional requirements . On a
statement attached to the Form 3115, the
taxpayer must provide:
(a) the reason(s) for revoking the
§ 1278(b) election (or deemed § 1278(b)
election);
(b) a description of the method by
which, and the date on which, the taxpay-
er made the § 1278(b) election (or deemed
§ 1278(b) election) that is being revoked;
and
(c) a statement that, after the revoca-
tion, the taxpayer will not make a constant
interest rate election for any bond that has
been subject to the § 1278(b) election (or
deemed § 1278(b) election) being revoked
and for which a constant interest rate elec-
tion was not effective in the year of ac-
quisition .
(5) Audit protection . A taxpayer may
receive audit protection, as provided
in section 8 .01 of Rev . Proc . 2015-13,
2015-5 I .R .B . 419, in connection with
this change . Any audit protection appli-
cable to this change under section 8 .01 of
Rev . Proc . 2015-13 does not preclude the
Commissioner from examining the meth-
od used by the taxpayer to determine the
amount of accrued market discount under
§ 1276(b) for a taxable year prior to the
year of change .
(6) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
31 .01 is “73 .”
(7) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
SECTION 32 . SHORT-TERM
OBLIGATIONS (§ 1281)
.01 Interest income on short obliga-
tions .
(1) Description of change .
(a) This change applies to a taxpayer
that wants to change its method of ac-
counting to comply with § 1281 for inter-
est income on short-term obligations .
(b) Under § 1281, a holder of certain
short-term obligations, including a bank as
defined in § 581, must include in gross in-
come any accrued interest income on such
obligations, regardless of the holder’s over-
all method of accounting . Section 1281
applies to all types of interest income, in-
cluding acquisition discount, original issue
discount (OID), and stated interest . See S .
Rep . No . 99-313, 99
th
Cong ., 2d Sess . 903
(1986), 1986-3 (Vol . 3) C .B . 903 .
(c) Section 1283(a)(1) generally de-
fines a short-term obligation as any bond,
debenture, note, certificate, or other evi-
dence of indebtedness that matures in one
year or less from its issue date .
(d) Under §§ 1281(a) and 1283(c), a
holder of a short-term obligation subject
to § 1281 must include in gross income an
amount equal to the sum of the daily por-
tions of the acquisition discount or OID,
whichever is applicable, on the obligation
for each day during the taxable year that
the obligation is held by the holder . See
§ 1283(b), as modified by § 1283(c), to
determine the daily portions of acquisition
discount or OID . In addition, § 1281(a)
requires the holder to include in gross in-
come any stated interest that is payable on
the short-term obligation (other than stat-
ed interest taken into account to determine
the amount of the acquisition discount or
OID) as it accrues .
(2) Section 481(a) adjustment period .
A taxpayer must take the entire § 481(a)
adjustment into account in computing tax-
able income for the year of change .
(3) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
32 .01 is “74 .”
(4) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
.02 Stated interest on short-term loans
of cash method banks .
(1) Description of change . This change
applies to a bank that uses the cash re-
ceipts and disbursements (cash) method of
accounting as its overall accounting meth-
od and that wants to change its method of
accounting from accruing stated interest
on short-term loans made in the ordinary
course of business to using the cash meth-
od for that interest . For example, see Se-
curity State Bank v. Commissioner, 214
F .3d 1254 (10
th
Cir . 2000), aff ’g 111 T .C .
210 (1998), acq ., 2001-1 C .B . xix; and Se-
curity Bank Minnesota v. Commissioner,
994 F .2d 432 (8
th
Cir . 1993), aff ’g 98 T .C .
33 (1992), in which the courts held that
§ 1281 does not apply to short-term loans
made by a cash method bank in the ordi-
nary course of its business .
(2) Certain eligibility rule inapplica-
ble . The eligibility rule in section 5 .01(1)
(f) of Rev . Proc . 2015-13, 2015-5 I .R .B .
419, does not apply to this change .
(3) Section 481(a) adjustment period .
A taxpayer making this change must take
the entire § 481(a) adjustment into ac-
count in computing taxable income for the
year of change .
(4) Designated automatic accounting
method change number . The designat-
ed automatic accounting method change
number for a change under this section
32 .02 is “75 .”
(5) Contact information . For further
information regarding a change under this
section, contact William E . Blanchard at
(202) 317-3900 (not a toll-free number) .
EFFECTIVE DATE
.01 In general . Except as otherwise
provided under this EFFECTIVE DATE
section, this revenue procedure is effective
for a Form 3115 filed on or after Novem-
ber 8, 2019, for a year of change ending on
or after March 31, 2019, that is filed under
the automatic change procedures of Rev .
Proc . 2015-13, 2015-5 I .R .B . 419, as clar-
ified and modified by Rev. Proc. 2015-33,

November 25, 2019 1208 Bulletin No. 2019–48
2015-24 I.R.B. 1067, and as modified by
Rev . Proc . 2017-59, 2017-48 I .R .B . 543,
and by section 17 .02(b) and (c) of Rev .
Proc . 2016-1, 2016-1 I .R .B . 1 .
.02 Transition rules . The following
transition rules apply:
(1) Limited time period to convert a
Form 3115 filed under the non-auto-
matic change procedures in Rev. Proc.
2015-13 . If before November 8, 2019,
a taxpayer properly filed a Form 3115
under the non-automatic change proce-
dures in Rev . Proc . 2015-13 requesting
the Commissioner’s consent for a change
in method of accounting described in
this revenue procedure, and the Form
3115 is pending with the national office
on November 8, 2019, the taxpayer may
choose to make the change in method of
accounting under the automatic change
procedures in Rev . Proc . 2015-13 if the
taxpayer is otherwise eligible to use this
revenue procedure and the automatic
change procedures in Rev . Proc . 2015-
13 . The taxpayer must notify the national
office contact person (if unknown, see
section 9 .08(6) of Rev . Proc . 2019-1,
2019-1 I .R .B . 1, 50-51 (or successor))
for the Form 3115 of the taxpayer’s in-
tent to make the change in method of
accounting under the automatic change
procedures in Rev . Proc . 2015-13 before
the later of (a) December 9, 2019, or (b)
the issuance of a letter ruling granting or
denying consent for the change . The no-
tification should indicate that the taxpay-
er chooses to convert the Form 3115 to
the automatic change procedures in Rev .
Proc . 2015-13 . If the taxpayer timely no-
tifies the national office that it chooses to
convert the Form 3115 to the automatic
change procedures in Rev . Proc . 2015-
13, the national office will send a letter
to the taxpayer acknowledging its request
and will return the user fee submitted
with the Form 3115 .
A taxpayer converting a Form 3115 to
the automatic change procedures in Rev .
Proc . 2015-13 for a change in method
of accounting described in this revenue
procedure must resubmit a Form 3115
that conforms to the automatic change
procedures, with a copy of the nation-
al office letter sent acknowledging the
taxpayer’s request attached, to the IRS
in Ogden, UT by the earlier of (a) the
30
th
calendar day after the date of the na-
tional office’s letter acknowledging the
taxpayer’s request, or (b) the date the
taxpayer is required to file the duplicate
copy of the Form 3115 under SECTION
6 .03(1)(a)(i)(B) of Rev . Proc . 2015-13 .
See SECTION 6 .03(3) of Rev . Proc .
2015-13 regarding additional required
copies of Form 3115 .
For purposes of the eligibility rules in
SECTION 5 of Rev . Proc . 2015-13, the
duplicate copy of the timely resubmitted
Form 3115 will be considered filed as of
the date the taxpayer originally filed the
converted Form 3115 under the non-au-
tomatic change procedures in Rev . Proc .
2015-13 . This paragraph (1) does not ex-
tend the date the taxpayer must file the
original (converted) Form 3115 under
SECTION 6 .03(1)(a)(i)(A) of Rev . Proc .
2015-13 .
A Form 3115 filed under the non-au-
tomatic change procedures in Rev . Proc .
2015-13 before November 8, 2019, for a
change in method of accounting described
in this revenue procedure, will be disre-
garded for purposes of the prior five year
change rules in SECTIONS 5 .04 and 5 .05
of Rev . Proc . 2015-13 if the taxpayer con-
verts the Form 3115 pursuant to this para-
graph (1) .
(2) Forms 3115 for changes in methods
of accounting that can no longer be filed
under the automatic change procedures .
Except as provided in subsection .02(2)
(a) of this EFFECTIVE DATE section,
the following transition rules apply to the
changes in methods of accounting that
can no longer be filed under the automatic
change procedures in Rev . Proc . 2015-13
because of changes made in this revenue
procedure . Examples of such changes in
methods of accounting are described in
subsection .01(3), (4), and (7) of the SIG-
NIFICANT CHANGES section of this
revenue procedure .
(a) If before November 8, 2019, a tax-
payer properly filed the original, or the
duplicate copy, of a Form 3115 under
the automatic change procedures in Rev .
Proc . 2015-13 for a change in method of
accounting that can no longer be filed
under the automatic change procedures
in Rev . Proc . 2015-13, the taxpayer may
make that change in method of account-
ing under the automatic change proce-
dures in Rev . Proc . 2015-13 for the year
of change .
(b) If before November 8, 2019, a tax-
payer did not properly file the original, or
the duplicate copy, of a Form 3115 under
the automatic change procedures in Rev .
Proc . 2015-13 for a change in method
of accounting that can no longer be filed
under the automatic change procedures
in Rev . Proc . 2015-13, the taxpayer must
make that change in method of account-
ing under the non-automatic change pro-
cedures in Rev . Proc . 2015-13 . Notwith-
standing § 1 .446-1(e)(3)(i), the taxpayer
may file a Form 3115 to request the Com-
missioner’s consent to change the method
of accounting under the non-automatic
change procedures in Rev . Proc . 2015-13
for the taxpayer’s last taxable year ending
before November 8, 2019, on or before the
due date of the federal income tax return
for that taxable year . Solely for purposes
of this paragraph (2)(b), the due date of
the taxpayer’s federal income tax return
includes extensions, notwithstanding that
the taxpayer may not have extended the
due date .
EFFECT ON OTHER DOCUMENTS
.01 This revenue procedure amplifies
and modifies Rev. Proc. 2018-31, 2018-22
I .R .B . 637 . Rev . Proc . 2018-31, as ampli-
fied and modified is superseded in part.
The second sentence in the subsection .01
under the EFFECT ON OTHER DOCU-
MENTS section of Rev . Proc . 2018-31
remains in effect (that is, the second sen-
tences in sections 14 .01 and 14 .02, and
sections 14 .04, 14 .05, 14 .06, and 14 .07 of
Rev . Proc . 2011-14, 2011-4 I .R .B . 330, re-
main in effect) . All other sections of Rev .
Proc . 2018-31 are superseded .
.02 Rev . Proc . 2011-46, 2011-42 I .R .B .
518, is modified as follows:
(1) Section 5.02(3)(a) is modified to
remove the first two sentences in the Man-
ner of Making Change section and to sub-
stitute the following three new sentences
in its place:
(a) In accordance with § 1 .446-1(e)(3)
(ii), the requirement under § 1 .446-1(e)
(3)(i) to file a Form 3115 is waived and
a statement in lieu of a Form 3115 is au-
thorized for this change . Notwithstanding
the definition of Form 3115 in section 3.07

Bulletin No. 2019–48 1209 November 25, 2019
of Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
the statement in lieu of a Form 3115 that
is permitted under this paragraph 5 .02(3)
(a) is considered a Form 3115 for purpos-
es of the automatic consent procedures in
Rev . Proc . 2015-13 . However, the require-
ment to file the Duplicate copy, under sec-
tion 6 .03(1)(a) of Rev . Proc . 2015-13, is
waived .
(2) Section 5.03(2)(a) is modified to
remove the first two sentences in the Man-
ner of Making Change section and to sub-
stitute the following three new sentences
in its place:
(a) In accordance with § 1 .446-1(e)(3)
(ii), the requirement under § 1 .446-1(e)
(3)(i) to file a Form 3115 is waived and
a statement in lieu of a Form 3115 is au-
thorized for this change . Notwithstand-
ing the definition of Form 3115 in section
3 .07 of Rev . Proc . 2015-13, the state-
ment in lieu of a Form 3115 that is per-
mitted under this paragraph 5 .03(2)(a) is
considered a Form 3115 for purposes of
the automatic consent procedures in Rev .
Proc . 2015-13 . However, the requirement
to file the Duplicate copy, under section
6 .03(1)(a) of Rev . Proc . 2015-13, is
waived .
.03 Rev . Rul . 2004-62, 2004-1 C .B .
1072, is modified to remove the second
sentence in the CHANGE IN METHOD
OF ACCOUNTING section and to substi-
tute the following new two sentences in its
place:
A taxpayer that wants to change its
method of accounting to comply with
this revenue ruling must follow the au-
tomatic change procedures in Rev . Proc .
2015-13, 2015-5 I .R .B . 419, (or succes-
sor) if the taxpayer is eligible to request
such consent under the automatic change
procedures therein . The eligibility rules in
section 5 .01(1) of Rev . Proc . 2015-13 (or
successor) apply to a change in method of
accounting described in section 3 .04 of
Rev . Proc . 2019-43, 2019-48 I .R .B . 1107
(or successor) .
.04 Rev . Rul . 2000-7, 2000-9 C .B . 712,
is modified to remove the fourth sentence
of the paragraph in the APPLICATION
section and to substitute the following
new fourth sentence:
A taxpayer that wants to change its
method of accounting to conform with
the holding in this revenue ruling must
follow the automatic change procedures
in Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
(or successor) if the taxpayer is eligible to
request such consent under the automat-
ic change procedures therein, except that
the eligibility rule in section 5 .01(1)(f) of
Rev . Proc . 2015-13 (or successor) does
not apply to a change described in sec-
tion 11 .03 of Rev . Proc . 2019-43, 2019-48
I .R .B . 1107 (or successor) .
.05 Rev . Rul . 2000-4, 2000-1 C .B . 331,
is modified to remove the second sentence
of the paragraph in the APPLICATION
section, and to substitute the following
two new sentences in that paragraph in its
place:
A taxpayer that wants to change its
method of accounting to conform with the
holding in this revenue ruling must follow
the automatic change procedures in Rev .
Proc . 2015-13, 2015-5 I .R .B . 419, (or suc-
cessor) if the taxpayer is eligible to request
such consent under the automatic change
procedures therein . The eligibility rules in
section 5 .01(1) of Rev . Proc . 2015-13 (or
successor) apply to a change in method
of accounting under section 3 .02 of Rev .
Proc . 2019-43, 2019-48 I .R .B . 1107 (or
successor) .
.06 Rev . Proc . 2007-48, 2007-2 C .B .
110, is modified to remove section 5.06(1)
and to substitute it with the following sen-
tence:
The eligibility rule in section 5 .01(1)(f)
of Rev . Proc . 2015-13, 2015-5 I .R .B . 419,
(or successor) does not apply to a change
in method of accounting described in sec-
tion 5 .06 of Rev . Proc . 2007-48, and made
under section 22 .09 of Rev . Proc . 2019-
43, 2019-48 I .R .B . 1107 (or successor) .
. 07 Rev . Proc . 2007-16, 2007-1 C .B .
358, is modified as follows:
(1) The second sentence in section 4 .01
is modified by substituting “and Rev. Proc.
2015-13, 2015-5 I .R .B . 419” for “and, as
applicable, Rev . Proc . 97-27 or Rev . Proc .
2002-9 .”
(2) The first sentence in section 4.02 is
modified by:
(a)Substituting “the non-automatic
change or automatic change procedures of
Rev . Proc . 2015-13” for “Rev . Proc . 97-27
or Rev . Proc . 2002-9, as applicable,”; and
(b) Substituting “(as defined in section
3 .19 of Rev . Proc . 2015-13)” for “(as de-
fined in section 5.02(2) of Rev. Proc. 97-
27 or section 5 .02 of Rev . Proc . 2002-9, as
applicable)” .
(c) Section 4.03 is modified by sub-
stituting “Rev . Proc . 2015-13,” for “Rev .
Proc . 97-27 or Rev . Proc . 2002-9, as ap-
plicable,” .
PAPERWORK REDUCTION ACT
The collection of information con-
tained in this revenue procedure has been
reviewed and approved by the Office of
Management and Budget in accordance
with the Paperwork Reduction Act (44
U .S .C . 3507) under control number 1545-
1551 . An agency may not conduct or
sponsor, and a person is not required to
respond to, a collection of information un-
less the collection of information displays
a valid OMB control number .
The collections of information in this
revenue procedure are in sections 3, 5, 6,
7, 8, 9, 11, 12, 15, 16, 17, 18, 20, 21, 22,
23, 24, 25, 26, 29, 30, and 31 . This infor-
mation is necessary and will be used to
determine whether the taxpayer properly
changed to a permitted method of account-
ing . The collections of information are re-
quired for the taxpayer to obtain consent
to change its method of accounting . The
likely respondents are the following: indi-
viduals, farms, business or other for-prof-
it institutions, nonprofit institutions, and
small businesses or organizations .
The estimated total annual reporting
and/or recordkeeping burden is 34,279
hours .
The estimated annual burden per re-
spondent/recordkeeper varies from 1/6
hour to 8 ½ hours, depending on individu-
al circumstances, with an estimated aver-
age of 1 ¼ hours . The estimated number
of respondents is 28,046 . The estimated
annual frequency of responses is on occa-
sion .
SIGNIFICANT CHANGES
.01 Significant changes made by this
revenue procedure to the List of Automat-
ic Changes in Rev . Proc . 2018-31 include:
(1) Section 6 .03, relating to a change
for sale, lease, or financing transactions, is
modified to provide that a change in meth-
od of accounting for a transaction entered
into before the beginning of the year of

November 25, 2019 1210 Bulletin No. 2019–48
change is eligible to be made under the au-
tomatic change procedures of Rev . Proc .
2015-13 with a § 481(a) adjustment and
a statement with the name of the counter-
party instead of the counterparty repre-
sentation is required to be attached to the
Form 3115. Section 6.03 also is modified
to provide that the audit protection rules
in section 8 of Rev . Proc . 2015-13 apply,
but ruling protection is not provided on
the characterization of any transaction as
a lease, sale, or financing transaction;
(2) Section 6 .08, relating to a change
for tenant construction allowances, is
modified to provide that a change in meth-
od of accounting for an existing lease is
eligible to be made under the automatic
change procedures of Rev . Proc . 2015-13
with a § 481(a) adjustment and a state-
ment with the name of the counterparty in-
stead of the counterparty representation is
required to be attached to the Form 3115 .
Section 6.08 also is modified to provide
that the audit protection rules in section
8 of Rev . Proc . 2015-13 apply, but ruling
protection is not provided on whether the
taxpayer has, or does not have, a deprecia-
ble interest in the property subject to the
tenant construction allowances for federal
income tax purposes;
(3) The following sections are modified
to remove both paragraph (2)(b)(i), relat-
ing to the temporary waiver of the eligibil-
ity rule in section 5 .01(1)(f) of Rev . Proc .
2015-13, and paragraph (2)(b)(ii), relating
to the temporary waiver of the eligibility
rules in section 5 .01(1)(d) and (f) of Rev .
Proc . 2015-13 for a taxpayer making both
a change under section 6 .12, 6 .13, 6 .14,
or 6 .15, as applicable, and a change under
section 6 .01 of Rev . Proc . 2018-31 on a
single Form 3115 for the same asset for
the same year of change, because these
paragraphs are obsolete:
(a) Section 6 .12, relating to a change
from a permissible to a permissible meth-
od of accounting for depreciation of
MACRS property;
(b) Section 6 .13, relating to a change
for disposing of a building or a structural
component or disposing of a portion of a
building (including its structural compo-
nents) to which the partial disposition rule
in § 1 .168(i)-8(d)(1) applies;
(c) Section 6 .14, relating to a change
for disposing of § 1245 property or a de-
preciable land improvement or disposing
of a portion of § 1245 property or a de-
preciable land improvement to which the
partial disposition rule in § 1 .168(i)-8(d)
(1) applies; and
(d) Section 6 .15, relating to a change
for disposing of an asset subject to a gen-
eral asset account election under § 168(i)
(4) and the regulations thereunder .
(4) Section 11 .08, relating to a change
under §§ 1 .162-3, 1 .162-4, 1 .263(a)-1,
1.263(a)-2, or 1.263(a)-3, is modified
to remove paragraph (2), relating to the
temporary waiver of the eligibility rules
in section 5 .01(1)(d) and (f) of Rev . Proc .
2015-13, because this paragraph is obso-
lete;
(5) Section 16 .07, relating to changes
for advance payments, and section 20 .10,
relating to changes for gift cards issued as
a refund for returned goods, are modified
to remove changes in methods of account-
ing under § 1 .451-5 because § 1 .451-5
was removed by T .D . 9870;
(6) Section 16 .12, relating to changes
in the timing of income recognition, is
modified to permit taxpayers without an
applicable financial statement to: (a) use
the streamlined method change proce-
dures in section 16 .12(4)(c)(i)(B) to make
a change in method of accounting to com-
ply with proposed § 1 .451-8(d) when the §
481(a) adjustment required by the change
is zero; and (b) make a change under this
section to defer income based on earned
income under proposed § 1 .451-8(d)(4)
(ii) determined using a straight line ratable
basis over the term of the agreement;
(7) Section 22 .16, relating to certain
changes made by a taxpayer using the
retail inventory method, is modified to
remove the language in paragraph (2), re-
lating to the temporary waiver of the eli-
gibility rule in section 5 .01(1)(f) of Rev .
Proc . 2015-13, because it is obsolete; and
(8) Section 26 .04, relating to a change
in basis of computing reserves under §
807(f), is modified to make several chang-
es in response to comments and to include
a reference to § 807(f)(2), which generally
provides that if a taxpayer is no longer a
life insurance company, the taxpayer must
include the remaining balance of any §
481(a) adjustment in the preceding tax-
able year .
DRAFTING INFORMATION
The principal author of this revenue
procedure is Charles Magee of the Office
of Associate Chief Counsel (Income Tax
and Accounting) . For further information
regarding this revenue procedure, contact
Bruce Chang at (202) 317-7005 (not a
toll-free number) .
For further information regarding a
specific change in method of accounting
in this revenue procedure, contact the in-
dividual listed in the “Contact Person(s)”
section located at the end of each section
of the revenue procedure (numbers are
not toll-free) or see the CONTACT LIST
at the end of this revenue procedure . The
contact person is with one of the follow-
ing Offices of Associate Chief Counsel:
Corporate (CORP), Financial Institutions
and Products (FI&P), Income Tax & Ac-
counting (IT&A), International (INTL),
Passthroughs and Special Industries
(P&SI), or Employee Benefits, Exempt
Organizations, and Employment Taxes
(EEE) .

Bulletin No. 2019–48 1211 November 25, 2019
LIST OF AUTOMATIC CHANGES CONTACT LIST
Section Number
Designated Automatic
Accounting Change
NumberContact NameTelephone NumberOffice
1 .0191William E . Blanchard(202) 317-3900FI&P
2 .011William Ruane(202) 317-4718IT&A
3 .012Joanna Trebat(202) 317-7003IT&A
Alicia Lee-Won(202) 317-7003IT&A
3 .023Justin Grill(202) 317-7003IT&A
3 .034Renay France(202) 317-7003IT&A
3 .0486Alexa Dubert(202) 317-7003IT&A
3 .05See § 11 .08See § 11 .08See § 11 .08IT&A
3 .06See § 11 .08See § 11 .08See § 11 .08IT&A
3 .07158Ian Heminsley(202) 317-5100IT&A
3 .08159Sophia Wang(202) 317-5100IT&A
3 .09160Natasha Mulleneaux(202) 317-5100IT&A
3 .10182Richard Gano(202) 317-7011IT&A
3 .11208, 209Merrill Feldstein(202) 317-5100IT&A
4 .015Renay France(202) 317-7003IT&A
4 .02211K . Scott Brown(202) 317-6945FI&P
5 .0116William E . Blanchard(202) 317-3900FI&P
5 .02212Michael Kaercher(202) 317-6934INTL
6 .017James Liechty(202) 317-7005IT&A
6 .028Bruce Chang(202) 317-7005IT&A
6 .0310Edward Schwartz(202) 317-7006IT&A
6 .0487Elizabeth Binder(202) 317-7005IT&A
6 .0588Elizabeth Binder(202) 317-7005IT&A
6 .0689Bernard Harvey(202) 317-7005IT&A
6 .07107James Liechty(202) 317-7005IT&A
6 .08145Elizabeth Binder(202) 317-7005IT&A
6 .09157Charles Magee(202) 317-7005IT&A
6 .10198Patrick Clinton(202) 317-7005IT&A
6 .11199Patrick Clinton(202) 317-7005IT&A
6 .12200Patrick Clinton(202) 317-7005IT&A
6 .13205Patrick Clinton(202) 317-7005IT&A
6 .14206Patrick Clinton(202) 317-7005IT&A
6 .15207Patrick Clinton(202) 317-7005IT&A
6 .16
Summary of changes related to
dispositions of MACRS property
6 .17210Charles Magee(202) 317-7005IT&A
6 .18241Elizabeth Binder(202) 317-7005IT&A
7 .0117Elizabeth Binder(202) 317-7005IT&A
8 .01152Jennifer Bernardini(202) 317-6853P&SI
9 .0118Bruce Chang(202) 317-7005IT&A
10 .01223Elizabeth Binder(202) 317-7005IT&A

November 25, 2019 1212 Bulletin No. 2019–48
Section Number
Designated Automatic
Accounting Change
NumberContact NameTelephone NumberOffice
10 .02228Sharon Horn(202) 317-7003IT&A
10 .03229Meghan Howard(202) 317-5055P&SI
11 .0119Alexa Dubert(202) 317-7003IT&A
11 .0220Douglas Kim(202) 317-7003IT&A
11 .0321Douglas Kim(202) 317-7003IT&A
11 .0447Alexa Dubert(202) 317-7003IT&A
11 .0578Joanna Trebat(202) 317-7003IT&A
Alicia Lee-Won(202) 317-7003IT&A
11 .06109Stephen Rothandler(202) 317-7003IT&A
11 .07121Stephen Rothandler(202) 317-7003IT&A
11 .08184-193Douglas Kim(202) 317-7003IT&A
11 .09213Douglas Kim (202) 317-7003IT&A
11 .10222Merrill Feldstein(202) 317-5100IT&A
12 .0122Kari Fisher(202) 317-7007IT&A
12 .0223Kari Fisher(202) 317-7007IT&A
12 .0325Steven Gee(202) 317-7007IT&A
12 .0477Steven Gee(202) 317-7007IT&A
12 .0592Steven Gee(202) 317-7007IT&A
12 .06150, 151Kari Fisher(202) 317-7007IT&A
12 .07181Patrick Clinton(202) 317-7005IT&A
12 .08194Steven Gee(202) 317-7007IT&A
12 .09195Roy Hirschhorn(202) 317-7007IT&A
12 .10201Andrew Braden(202) 317-7007IT&A
12 .11202Andrew Braden(202) 317-7007IT&A
12 .12214Evan Hewitt(202) 317-7007IT&A
12 .13215Andrew Braden(202) 317-7007IT&A
12 .14224Steven Gee(202) 317-7007IT&A
12 .15232Megan McLaughlin(202) 317-7007IT&A
12 .16234Anna Gleysteen(202) 317-7007IT&A
12 .17237Evan Hewitt(202) 317-7007IT&A
12 .18238Steven Gee(202) 317-7007IT&A
13 .0126Steven Gee(202) 317-7007IT&A
Michael Kaercher(202) 317-6934INTL
14 .0128Thomas Scholz(202) 317-5600EEE
14 .0229John Ricotta (202) 317-4102EEE
Joyce Kahn (202) 317-4148EEE
15 .01122, 123Evan Hewitt(202) 317-7007IT&A
15 .0231Adam Kobler(202) 317-7011IT&A
15 .0332,33Evan Hewitt(202) 317-7007IT&A
15 .0434, 35Roy Hirschhorn(202) 317-7007IT&A
15 .0571William E . Blanchard(202) 317-3900FI&P
15 .0685Bernard Harvey(202) 317-7005IT&A
15 .0790Rebecca L . Baxter(202) 317-6995FI&P

Bulletin No. 2019–48 1213 November 25, 2019
Section Number
Designated Automatic
Accounting Change
NumberContact NameTelephone NumberOffice
15 .08108K . Scott Brown(202) 317-6945FI&P
15 .09124Douglas Kim(202) 317-7003IT&A
15 .10125Dave Christensen(202) 317-7011IT&A
15 .11126Evan Hewitt(202) 317-7007IT&A
15 .12127K . Scott Brown(202) 317-6945FI&P
15 .13128Mon Lam(202) 317-5100IT&A
15 .14129David H . McDonnell(202) 317-4137P&SI
15 .15148Charles W . Culmer(202) 317-6945FI&P
15 .16226Barbara Campbell(202) 317-4137P&SI
15 .17227Grace Cho(202) 317-6945FI&P
15 .18233Anna Gleysteen(202) 317-7007IT&A
16 .0136K . Scott Brown(202) 317-6945FI&P
16 .0237Daniel Cassano(202) 317-7011IT&A
16 .0338Daniel Cassano(202) 317-7011IT&A
16 .0439Bill Ruane(202) 317-4718IT&A
16 .0580, 81Kate Sleeth(202) 317-7053FI&P
16 .0682Kate Sleeth(202) 317-7053FI&P
16 .0783, 84Peter E . Ford(202) 317-7003IT&A
Jo Lynn Ricks(202) 317-7003IT&A
16 .0894Kate Sleeth(202) 317-7053FI&P
16 .09130, 217Peter Cohn(202) 317-7011IT&A
16 .10153Justin Grill(202) 317-7003IT&A
Peter E . Ford(202) 317-7003IT&A
16 .11231Peter E . Ford(202) 317-7003IT&A
Jo Lynn Ricks(202) 317-7003IT&A
16 .12239, 242Peter E . Ford(202) 317-7003IT&A
Jo Lynn Ricks(202) 317-7003IT&A
Charles W . Culmer(202) 317-4528FI&P
17 .01131William E . Blanchard(202) 317-3900FI&P
18 .01132Patrick Clinton(202) 317-7005IT&A
19 .01236Innessa Glazman(202) 317-7006IT&A
20 .0142, 133, 134Alicia Lee-Won(202) 317-7003IT&A
Joanna Trebat(202) 317-7003IT&A
20 .0243Christine Merson(202) 317-5100IT&A
20 .0344Christine Merson(202) 317-5100IT&A
20 .0445, 113Mon Lam(202) 317-5100IT&A
20 .0546Mon Lam(202) 317-5100IT&A
20 .06106Sharon Horn(202) 317-7003IT&A
20 .07135Mon Lam(202) 317-5100IT&A
20 .08149Daniel Cassano(202) 317-7011IT&A
20 .09154Sharon Horn(202) 317-7003IT&A
20 .10156Alicia Lee-Won(202) 317-7003IT&A
20 .11161Justin Grill(202) 317-7003IT&A

November 25, 2019 1214 Bulletin No. 2019–48
Section Number
Designated Automatic
Accounting Change
NumberContact NameTelephone NumberOffice
20 .12220David Christensen(202) 317-7011IT&A
21 .01136William Ruane(202) 317-4718IT&A
22 .0148Steven Gee(202) 317-7007IT&A
22 .0249Steven Gee(202) 317-7007IT&A
22 .0350, 51Anna Gleysteen(202) 317-7007IT&A
22 .0453Steven Gee(202) 317-7007IT&A
22 .0554Andrew Braden(202) 317-7007IT&A
22 .0655Andrew Braden(202) 317-7007IT&A
22 .0763Andrew Braden(202) 317-7007IT&A
22 .0896Andrew Braden(202) 317-7007IT&A
22 .09110Stephen Rothandler(202) 317-7003IT&A
22 .10111Steven Gee(202) 317-7007IT&A
22 .11137Steven Gee(202) 317-7007IT&A
22 .12138Andrew Braden(202) 317-7007IT&A
22 .13139Andrew Braden(202) 317-7007IT&A
22 .14114Andrew Braden(202) 317-7007IT&A
22 .15203Andrew Braden(202) 317-7007IT&A
22 .16204Andrew Braden(202) 317-7007IT&A
22 .17225Andrew Braden(202) 317-7007IT&A
22 .18230Andrew Braden(202) 317-7007IT&A
22 .19235Andrew Braden(202) 317-7007IT&A
23 .0156Andrew Braden(202) 317-7007IT&A
23 .0257Andrew Braden(202) 317-7007IT&A
23 .0358Andrew Braden(202) 317-7007IT&A
23 .0459Andrew Braden(202) 317-7007IT&A
23 .0560Andrew Braden(202) 317-7007IT&A
23 .0661Andrew Braden(202) 317-7007IT&A
23 .0762Andrew Braden(202) 317-7007IT&A
23 .08112Andrew Braden(202) 317-7007IT&A
23 .09140Andrew Braden(202) 317-7007IT&A
23 .10141Andrew Braden(202) 317-7007IT&A
24 .0164Marsha Sabin(202) 317-6945FI&P
24 .02218Marsha Sabin(202) 317-6945FI&P
25 .0166K . Scott Brown(202) 317-6945FI&P
Laura Fields(202) 317-6850P&SI
Adrienne Mikolashek(202) 317-6850P&SI
26 .0167Rebecca L . Baxter(202) 317-6995FI&P
26 .02155Rebecca L . Baxter(202) 317-6995FI&P
26 .03219Rebecca L . Baxter(202) 317-6995FI&P
26 .04240Dan Phillips(202) 317-6995FI&P
27 .0168Rebecca L . Baxter(202) 317-6995FI&P
28 .0179John W . Rogers, III(202) 317-6895FI&P
29 .0170Peter Merkel(202) 317-4919INTL

Bulletin No. 2019–48 1215 November 25, 2019
Section Number
Designated Automatic
Accounting Change
NumberContact NameTelephone NumberOffice
30 .0172William E . Blanchard(202) 317-3900FI&P
30 .02183Charles W . Culmer(202) 317-6945FI&P
31 .0173William E . Blanchard(202) 317-3900FI&P
32 .0174William E . Blanchard(202) 317-3900FI&P
32 .0275William E . Blanchard(202) 317-3900FI&P

26 CFR 601.105: Examination of returns and claims
for refund, credit, or abatement; determination of
correct tax liability
(Also: Part I, § 42; § 1.42-14.)
Rev. Proc. 2019-45
SECTION 1. PURPOSE
This revenue procedure provides guid-
ance to qualified states regarding how to
request an allocation of unused housing
credit carryover under § 42(h)(3)(D)(iii)
of the Internal Revenue Code (Code) . This
revenue procedure modifies and super-
sedes Rev . Proc . 92-31, 1992-1 C .B . 775 .
SECTION 2. CHANGES
Rev . Proc . 92-31 required a request for
an allocation of unused housing credit car-
ryover to be made by mailing a hard copy
of the request to the Internal Revenue Ser-
vice (Service) . This revenue procedure
instead requires allocation requests to be
made electronically .
SECTION 3. BACKGROUND
.01 Section 42(h)(3)(D)(i) provides
generally that the unused housing credit
carryover of a state for any calendar year
shall be assigned to the Secretary of the
Treasury or his delegate (Secretary) for
allocation among qualified states for the
succeeding calendar year . The allocation
of credits to qualified states is to be made
from a national pool of unused credit au-
thority (National Pool) consisting of all of
the unused housing credit carryovers as-
signed to the Secretary .
.02 Section 42(h)(3)(D)(ii) provides
that the unused housing credit carryover
of a state for any calendar year is the ex-
cess (if any) of—
(I) the unused state housing credit ceil-
ing for the preceding calendar year (as ref-
erenced in § 42(h)(3)(C)(i) and defined in
the flush language of § 42(h)(3)(C)); over
(II) the aggregate housing credit dollar
amount allocated for the calendar year .
.03 Section 42(h)(3)(D)(iv) provides
generally that the term “qualified state”
means, with respect to the current calen-
dar year, any state that has allocated its
entire state housing credit ceiling for the
preceding calendar year and for which a
request is made (not later than May 1 of
the current calendar year) to receive an al-
location of credit from the National Pool
for the current calendar year .
.04 Section 42(h)(3)(D)(iii) describes
the formula for allocation of unused hous-
ing credit carryovers from the National
Pool to qualified states. The amount to
be allocated to a qualified state for any
calendar year must bear the same ratio
to the aggregate unused housing credit
carryovers of all states for the preceding
calendar year as that state’s population for
the calendar year bears to the population
of all qualified states for the calendar year.
A state’s population, for this purpose, is
determined in accordance with § 146(j) of
the Code .
.05 Section 146(j) provides generally
that determinations of the population of
any state are made with respect to any cal-
endar year on the basis of the most recent
census estimate of the resident population
of that state released by the Bureau of the
Census before the beginning of that cal-
endar year .
.06 Section 1 .42-1T(b) of the Tempo-
rary Income Tax Regulations provides that
a state’s population for any calendar year
is determined by reference to the most re-
cent census estimate of the resident popu-
lation of the state released by the Bureau
of the Census before the beginning of the
calendar year for which the state’s hous-
ing credit ceiling is set .
.07 Section 42(l)(3) provides that
each state or local housing credit agency
(Agency) that allocates a housing cred-
it dollar amount to any building for any
calendar year shall submit to the Sec-
retary (at the time and in the manner as
the Secretary shall prescribe) an annual
report specifying the housing credit dol-
lar amount allocated to each building for
that year and sufficient information to
identify each building and the taxpay-
er(s) associated with the building . Agen-
cies file Form 8610, Annual Low-Income
Housing Credit Agencies Report, with
the Service to fulfill their obligations un-
der § 42(l)(3) .
.08 The general instructions to Form
8610 require that if a state has multiple
Agencies, the Agencies must coordinate
to file with the Service a single Form 8610
for the state . For each state, there is one
Agency responsible for filing the Form
8610 with the Service (Filing Agency) .
Section 1 .42-1T(d)(8)(ii) provides that
this single completed Form 8610, with the
appropriate attachments, must be filed not
later than the 28th day of the second cal-
endar month after the close of the calen-
dar year in which a housing credit dollar
amount was allocated .
.09 The information provided on Form
8610 is used to determine the prior cal-
endar year’s unused housing credit car-

November 25, 2019 1216 Bulletin No. 2019–48
ryovers that are available for allocation
to qualified states from the current year
National Pool .
SECTION 4. SCOPE
This revenue procedure applies to the
Filing Agency of any qualified state that
requests an allocation of credit from the
National Pool of unused housing credit
carryovers .
SECTION 5. PROCEDURE—
METHOD FOR REQUESTING
CREDIT FROM THE NATIONAL
POOL
.01 Only the Filing Agency of a qual-
ified state may request, on behalf of that
state, to receive an allocation of credit
from the National Pool .
.02 Not later than May 1 of the calendar
year in which the allocation is requested,
the Filing Agency must attach a portable
document format (pdf) copy of the request
to an email that the Filing Agency sends to
the following email address:
CC .PSI .Stakeholder@irscounsel .treas .
gov
The pdf-format copy of the request at-
tached to the email must briefly explain
that a request for allocation of credit from
the National Pool is being made under
section 42(h)(3)(D), and must be signed
by an authorized official of the Filing
Agency .
.03 A pdf-format copy of the state’s
Form 8610 (or most recently amended
Form 8610) for the preceding calendar
year must also be attached to the email .
.04 If there are any requests for alloca-
tions of credit from the National Pool, the
Service will publish in the Internal Reve-
nue Bulletin the amounts of unused hous-
ing credit carryovers assigned to qualified
states from the National Pool for that cal-
endar year .
SECTION 6. EFFECT ON OTHER
DOCUMENTS
Rev. Proc. 92-31 is modified and super-
seded .
SECTION 7. EFFECTIVE DATE
This revenue procedure is effective be-
ginning with assignments of 2019 calen-
dar year unused housing credit carryovers
to the National Pool and 2020 calendar
year requests on behalf of qualified states
for allocations of credit from the National
Pool .
SECTION 8. DRAFTING
INFORMATION
The principal author of this revenue
procedure is YoungNa Lee of the Office
of Associate Chief Counsel (Passthroughs
and Special Industries) . For further infor-
mation regarding this revenue procedure
contact Ms . Lee on (202) 317-4137 (not a
toll-free number) .
Section 42.—Low-Income
Housing Credit
26 CFR 1 .42-14 . Allocation rules for post-2000
State housing credit ceiling amounts . Guidance is
provided to qualified states that request an alloca-
tion of unused housing credit carryover under sec-
tion 42(h)(3)(D) of the Internal Revenue Code . See
Rev . Proc . 2019-45 .

Bulletin No. 2019–48 1217 November 25, 2019
Part IV
Notice of Proposed
Rulemaking
Eligible Terminated S
Corporations
REG-131071-18
AGENCY: Internal Revenue Service
(IRS), Treasury .
ACTION: Notice of proposed rulemaking .
SUMMARY: This notice of proposed
rulemaking provides rules regarding the
definition of an eligible terminated S cor-
poration (ETSC) . In addition, these pro-
posed regulations provide rules relating
to distributions of money by an ETSC af-
ter the post-termination transition period
(PTTP) . Finally, these proposed regula-
tions revise current regulations to extend
the treatment of distributions of money
during the PTTP to all shareholders of the
corporation and to update and clarify the
allocation of current earnings and profits
to distributions of money and other prop-
erty . These proposed regulations would
affect certain C corporations and the
shareholders of such corporations .
DATES: Comments and requests for a
public hearing must be received by De-
cember 23, 2019 .
ADDRESSES: Submit electronic submis-
sions via the Federal Rulemaking Portal at
https://www .regulations .gov (indicate IRS
and REG-131071-18) by following the on-
line instructions for submitting comments .
The Department of the Treasury (Treasury
Department) and the IRS will publish for
public availability any comment received
to its public docket, whether submitted
electronically or in hard copy . Send hard
copy submissions to: CC:PA:LPD:PR
(REG-131071-18), Room 5203, Internal
Revenue Service, P .O . Box 7604, Ben
Franklin Station, Washington, DC 20044 .
Submissions may be hand-delivered Mon-
day through Friday between the hours
of 8 a .m . and 4 p .m . to CC:PA:LPD:PR
(REG-131071-18), Courier’s Desk, Inter-
nal Revenue Building, 1111 Constitution
Avenue NW, Washington, DC, 20224 .
FOR FURTHER INFORMATION CON-
TACT: Concerning proposed regula-
tions §§ 1 .481-5, 1 .481-6, 1 .1377-2, and
1 .1377-3, Margaret Burow or Michael
Gould at (202) 317-5279; concerning pro-
posed regulations §§1 .1371-1 and 1 .1371-
2, Aglaia Ovtchinnikova at (202) 317-
6975, Kevin M . Jacobs at (202) 317-5332,
or Margaret Burow or Michael Gould at
(202) 317-5279; concerning proposed reg-
ulation §1 .316-2, Aglaia Ovtchinnikova
at (202) 317-6975 or Kevin M . Jacobs at
(202) 317-5332; concerning submissions
and the hearing, Regina Johnson at (202)
317-6901 (not toll-free numbers) .
SUPPLEMENTARY INFORMATION:
Background
I. Overview
This document contains proposed
amendments to the Income Tax Regu-
lations (26 CFR part 1) under sections
481 and 1377 of the Internal Revenue
Code (Code) and proposed regulations
under section 1371 of the Code . Section
13543(a) and (b) of the Tax Cuts and Jobs
Act, Public Law 115-97, 131 Stat . 2054,
2155 (2017) (TCJA), amended the Code
to add subsection (d) to section 481, and
subsection (f) to section 1371 . Both sec-
tion 481(d) and section 1371(f) are effec-
tive as of December 22, 2017 .
II. Summary of PTTP and ETSC Period
Generally, a distribution by a C corpo-
ration to its shareholders with respect to
their stock ownership is treated as a taxable
dividend to the extent of the corporation’s
earnings and profits. See sections 301(c) and
316(a) . However, following the termination
of an S corporation’s election made under
section 1362 (S election), section 1371(e) al-
lows shareholders of the resulting C corpo-
ration to benefit from the corporation’s for-
mer status as an S corporation with respect
to distributions of money during the corpo-
ration’s PTTP, which is generally the one-
year period after the S election terminates .
Specifically, during the PTTP, a distribution
of money by the C corporation is character-
ized as a distribution from the corporation’s
accumulated adjustments account (AAA),
as defined in §1.1368-2(a)(1). The receipt of
such a distribution is tax-free to the extent of
the recipient’s basis in its stock with respect
to which it received the distribution, and is
taxed as gain from the sale of property to
the extent the distribution exceeds the recip-
ient’s basis in that stock . If the corporation
exhausts its AAA during the PTTP, then sub-
sequent distributions are subject to treatment
under section 301 . Without section 1371(e),
shareholders of the former S corporation
would be precluded from receiving distribu-
tions allocable to AAA .
Section 1371(f) extends the period
during which the shareholders of a C cor-
poration can benefit from AAA generated
during such corporation’s former status as
an S corporation (ETSC period) by allow-
ing a C corporation’s distribution of money
to which section 301 would otherwise ap-
ply (qualified distribution) to be sourced,
in whole or in part, from AAA. Specifi-
cally, section 1371(f) provides that (i) the
distributing ETSC’s AAA is allocated to a
qualified distribution, and (ii) the qualified
distribution is chargeable to accumulated
earnings and profits (AE&P), in the same
ratio as the amount of such AAA bears
to the amount of such AE&P (clauses (i)
and (ii), collectively, ETSC proration) . In
enacting section 1371(f), Congress deter-
mined that “it is important to provide rules
to ease the transition from S corporation to
C corporation for the affected taxpayers”
because, based on TCJA revisions to the
Code, “taxpayers that previously elected
to be taxed as S corporations may prefer
instead to be taxed as C corporations .”
H . Rept . 115-409, at 245 115
th
Cong . 1
st

Sess ., (Nov . 14, 2017) (House Report) .
Explanation of Provisions
I. Requirements to Qualify for Section
1371(f) Treatment
If a C corporation satisfies the ETSC
qualification requirements, section 1371(f)

November 25, 2019 1218 Bulletin No. 2019–48
provides special treatment for qualified
distributions made by an ETSC during the
ETSC period, which begins with the ex-
piration of the PTTP and ends when the
corporation exhausts its AAA .
A. ETSC Qualification Requirements
1 . In General
In order for section 1371(f) to apply,
the distributing corporation must be an
ETSC . In conjunction with the enactment
of section 1371(f), Congress enacted sec-
tion 481(d), which includes the definition
of an ETSC. Specifically, a C corpora-
tion qualifies as an ETSC if the follow-
ing three requirements are satisfied. First,
the corporation was an S corporation on
December 21, 2017 . Second, during the
two-year period beginning on December
22, 2017, the S corporation revoked its S
election (revocation requirement) . Third,
the owners of the stock of the corporation
are the same owners (and in identical pro-
portions) on December 22, 2017, and the
date that the corporation made a revoca-
tion of its S election (shareholder identity
requirement) .
2 . Revocation Requirement
In contrast to the PTTP, which applies
regardless of how an S corporation’s elec-
tion terminates, section 1371(f) applies
only if the S election is revoked (section
1362(d)(1)), which, under section 1362(d)
(1)(B), requires the consent of sharehold-
ers holding more than 50 percent of the
corporation’s shares in the aggregate . Sec-
tion 1362(d)(1) and its underlying regula-
tions provide the sole means for an S cor-
poration to revoke its S election . Pursuant
to §1 .1362-6(a)(3), a valid revocation re-
quires an S corporation to submit a written
statement that the corporation revokes its
S election . That revocation statement must
set forth the number of shares of stock (in-
cluding non-voting stock) issued and out-
standing at the time of the revocation and
must be accompanied by a separate writ-
ten statement of shareholder consent . See
§1 .1362-6(a)(3)(i), (b) .
Generally, a revocation made on or be-
fore the 15th day of the third month of a
taxable year is effective on the first day of
that year, and an election made after that
date is effective on the first day of the fol-
lowing taxable year . See section 1362(d)
(1)(C) and §1 .1362-2(a)(2)(i) . However,
if the revocation specifies a date for revo-
cation that is on or after the day on which
the revocation is made, the revocation
becomes effective on that specified date.
See section 1362(d)(1)(D) and §1 .1362-
2(a)(2)(ii) . Therefore, under the proposed
regulations, the revocation requirement
would be satisfied if the revocation of
an S election is validly made during the
two-year period beginning on December
22, 2017, even if the effective date for the
revocation occurs after the conclusion of
that two-period .
3 . Shareholder Identity Requirement
For a former S corporation to qualify
as an ETSC, the owners of its stock must
be the same owners (and in identical pro-
portions) on the following two dates: (1)
December 22, 2017, and (2) the date on
which the S corporation made a revoca-
tion of its S election . However, certain
events should not affect the shareholder
identity requirement because such events
would not change in substance the iden-
tity of the subject shareholder. Specifi-
cally, these proposed regulations identify
five categories of stock transfers that do
not result in an ownership change for pur-
poses of section 481(d)(2)(B): (1) trans-
fers of stock between a shareholder and
that shareholder’s trust treated as wholly
owned by that shareholder under subpart
E of subchapter J of chapter 1; (2) trans-
fers of stock between a shareholder and
an entity owned by the shareholder that
is disregarded as separate from its owner
under §301 .7701-2(c)(2)(i) of the Proce-
dure and Administration Regulations; (3)
an election by a shareholder trust to be
treated as part of a decedent’s estate un-
der section 645 or the termination of an
election under that section; (4) a change in
the status of a shareholder trust from one
type of eligible S corporation shareholder
trust described in section 1361(c)(2)(A)
to another type of eligible S corporation
shareholder trust; and (5) a transaction
that includes more than one of the events
described in (1) through (4) .
While specifying transaction catego-
ries provides certainty to taxpayers, the
Treasury Department and the IRS request
comments regarding whether a princi-
ple-based rule would be more effective,
as well as suggestions as to the rule’s pro-
posed operative language .
B . Requirement for Corporation to Have
AAA
Section 1371(f) provides that AAA is
allocated to a qualified distribution based
on the ratio of AAA to AE&P . Thus, if an
ETSC has no AAA, section 1371(f) has
no application . In addition, as evidenced
by the fact that Congress enacted section
1371(f) to ease the transition from S cor-
poration status to C corporation status, the
ETSC period is intended to be transitory
in nature . Consequently, the Treasury De-
partment and the IRS have determined that
such a transition would naturally conclude
once the C corporation’s AAA balance
reaches zero . In other words, an ETSC has
an ETSC period only if the ETSC has a
AAA balance greater than zero at the end
of its PTTP, and the ETSC period ends
immediately after the qualified distribu-
tion that causes the C corporation’s AAA
balance to reach zero .
C . Conclusion of PTTP; Multiple PTTPs
Section 1377(b)(1) provides that a
PTTP occurs in the following three cir-
cumstances . First, a PTTP may occur
during the period starting on the day after
the last day of the corporation’s last tax-
able year as an S corporation and ending
on the later of (i) the day that is one year
later or (ii) the due date for filing the re-
turn for such last year as an S corporation
(including extensions) . Second, a PTTP
may occur during the 120-day period be-
ginning on the date of any determination
pursuant to an audit of a taxpayer that fol-
lows the termination of the corporation’s
election and adjusts a subchapter S item
that arose during the S period (interven-
ing audit PTTP) . Third, a PTTP may occur
during the 120-day period beginning on
the date of a determination that the cor-
poration’s election under section 1362(a)
had terminated for a previous taxable year .
Section 1371(f) applies to certain dis-
tributions “after the post-termination tran-
sition period .” The Treasury Department
and the IRS received a comment regard-
ing intervening audit PTTPs and, accord-

Bulletin No. 2019–48 1219 November 25, 2019
ingly, considered whether the ETSC pe-
riod continues following an intervening
audit PTTP that occurs during the ETSC
period . Based on the overall purpose of
these proposed regulations to ease the
transition from S corporation status to C
corporation status, the Treasury Depart-
ment and the IRS have determined that the
ETSC period should resume immediately
following the conclusion of an intervening
audit PTTP, if the ETSC continues to have
a AAA balance greater than zero .
II. Mechanics of Section 1371(f)
A . Shareholders Eligible to Receive
Qualified Distributions
By its terms, section 1371(f) does not
require the recipients of qualified distri-
butions to have been shareholders of the
S corporation at the time of revocation,
and no part of the House Report indicates
a Congressional intent to impose such a
limitation (no-newcomer rule) on such
distributions . The Treasury Department
and the IRS received a comment request-
ing guidance to clarify which shareholders
are eligible to receive distributions from
a corporation’s AAA during the ETSC
period . A no-newcomer rule would be
inconsistent with Congressional intent to
ease the transition of former S corpora-
tions to full C corporation status because
such a no-newcomer rule would impede
an ETSC’s ability to exhaust its AAA .
A no-newcomer rule also would impose
an administrative burden on ETSCs and
create complexity by requiring ETSCs to
report distributions disparately depending
on the recipient . See House Report at 245 .
Additionally, a rule allowing newcomers
would be more consistent with treating the
AAA as a corporate-level account .
In the absence of a no-newcomer rule,
shareholders that were shareholders on
the date that the corporation’s S election
revocation was made would continue to
receive qualified distributions, whether or
not there are new shareholders or changes
in the historical S corporation sharehold-
ers’ proportionate interests on or after
such date . Moreover, new shareholders,
whether eligible S corporation sharehold-
ers or not, that acquire stock of an ETSC
on or after the date that the revocation was
made may receive qualified distributions,
all or a portion of which may be sourced
from AAA . Such outcomes would best
implement the plain language of section
1371(f) and the policy objective of easing
the transition of affected taxpayers from S
corporation status to C corporation status .
Accordingly, these proposed regulations
do not impose a no-newcomer rule with
respect to the ETSC period .
B . Implementation of ETSC Proration
As discussed in Part II of the Back-
ground, section 1371(f) provides that (i)
the distributing ETSC’s AAA is allocated
to a qualified distribution, and (ii) such
qualified distribution is chargeable to the
ETSC’s AE&P, based on the ETSC pro-
ration . These proposed regulations would
implement this provision in a manner
designed to facilitate the ETSC’s prompt
distribution of AAA and full transition to
C corporation status, and thereby “ease the
transition from S corporation to C corpo-
ration for the affected taxpayers .” House
Report at 245 . Grounded in that policy,
these proposed regulations (i) specify the
time at which amounts of AAA and AE&P
are determined for purposes of the ETSC
proration, (ii) clarify the AAA and AE&P
ratios used to implement the ETSC prora-
tion, and (iii) describe in detail the method
of characterizing qualified distributions.
1 . When to Determine the Amounts of
AAA and AE&P for Purposes of ETSC
Proration
The Treasury Department and the IRS
considered when to measure the AAA and
AE&P for purposes of the ETSC prora-
tion . The Treasury Department and the
IRS considered a “Snapshot Approach,”
under which the amounts of AAA and
AE&P would be determined on a specified
date (historical AAA and historical AE&P,
respectively), resulting in the same ETSC
proration being applied to all qualified
distributions . The Treasury Department
and the IRS also considered a “Dynamic
Approach,” under which the amounts of
AAA and AE&P would be recalculated
before each qualified distribution.
These proposed regulations adopt the
Snapshot Approach, with a special ad-
ditional rule to facilitate distributions of
AAA when the ETSC’s historical AE&P
has been exhausted and the ETSC still
has AAA . See Part II .C .1 of this Expla-
nation of Provisions . The Snapshot Ap-
proach would provide affected taxpayers
with an easier transition to full subchap-
ter C status . Under this approach, ETSCs
generally would be required to calculate
AAA and AE&P for purposes of the ETSC
proration only once, as opposed to numer-
ous times under the Dynamic Approach .
Also, the Dynamic Approach could sig-
nificantly delay shareholder access to the
ETSC’s AAA . While the amount of an
ETSC’s AAA could never increase during
the ETSC period (other than by reason of
a redetermination of AAA), such ETSC’s
AE&P would increase as the amount of
any undistributed current earnings and
profits is carried forward to the next tax-
able year .
For the Snapshot Approach, the Trea-
sury Department and the IRS considered
two possible determination dates: (1) the
beginning of the day for which the revoca-
tion of an election under section 1362(a)
is effective pursuant to section 1362(d)(1),
and (2) immediately after the end of the
PTTP . Under these proposed regulations,
the determination date would be the be-
ginning of the day on which the revoca-
tion of an election under section 1362(a)
is effective . Determining the amount of
AAA on this date, which can be readily
achieved by referencing the ETSC’s final
Form 1120S, would avoid the complexity
of determining the proper amount of his-
torical AAA in the event of an intervening
audit PTTP for distributions made after
the initial PTTP and before the intervening
audit PTTP . In addition, the ETSC and its
shareholders would have greater certainty
during the PTTP as to the tax characteri-
zation of distributions to be made during
the ETSC period under this approach .
Reference to this determination date also
would facilitate the receipt of AAA by the
ETSC’s shareholders as quickly as pos-
sible by maximizing the amount of AAA
factored into the ETSC proration . Since S
corporations with no subchapter C history
will have no AE&P as of the beginning of
the effective date of the revocation, using
this determination date also would min-
imize the AE&P that is factored into the
ETSC proration, as compared to deter-
mining AE&P immediately after the end
of the PTTP . As a result, the use of this

November 25, 2019 1220 Bulletin No. 2019–48
determination date would facilitate the
corporation’s transition to full subchapter
C status .
The Treasury Department and the IRS
request comments regarding the proposed
regulations’ adoption of the Snapshot Ap-
proach, in particular with respect to the
timing of determining an ETSC’s histor-
ical AAA and historical AE&P amounts,
and whether such amounts should be ad-
justed by certain transactions, as well as
any potential alternative approaches for
computing the ETSC proration . For ex-
ample, the Treasury Department and the
IRS acknowledge that not all ETSCs may
favor the approach with respect to timing
that these proposed regulations adopt . In
particular, an ETSC that makes no dis-
tributions of AAA and operates at a loss
during its PTTP may prefer to determine
its AAA and AE&P ratios immediately
after the end of the PTTP . Determining
the ratios on this later date would result
in a lower historical AE&P amount, and
therefore the percentage of the qualified
distribution that could be characterized
as a distribution of AAA would be greater
when compared to the approach adopted
by these proposed regulations .
2 . ETSC Proration Based on Ratios
Composed of Historical AAA and
Historical AE&P
Section 1371(f) provides that AAA is
allocated to a qualified distribution, and
such distribution is chargeable to AE&P,
in the same ratio as the amount of such
AAA bears to the amount of such AE&P .
Therefore, section 1371(f) requires an al-
location of two distinct pools of an ET-
SC’s historical earnings with respect to
a qualified distribution (that is, AAA and
AE&P) . In order to clarify the calculation
of AAA and AE&P allocated to qualified
distributions, these proposed regulations
provide two ratios for purposes of char-
acterizing the portion of a qualified dis-
tribution that is sourced from AAA (AAA
ratio) and from AE&P (AE&P ratio) .
The numerator and denominator of the
AAA ratio and the AE&P ratio are com-
prised of two factors: the ETSC’s histori-
cal AAA and its historical AE&P . An ET-
SC’s AAA ratio would be the fraction of
which the numerator is its historical AAA,
and the denominator is the sum of its his-
torical AAA and its historical AE&P . An
ETSC’s AE&P ratio would be the fraction
of which the numerator is its historical
AE&P, and the denominator is the sum
of its historical AAA and its historical
AE&P . Generally, the amount of a quali-
fied distribution sourced from AAA would
be determined by multiplying the amount
of the qualified distribution by the ETSC’s
AAA ratio . A parallel computation would
be undertaken to determine the amount
that is sourced from AE&P . Part II .C of
this Explanation of Provisions describes
the rules relating to the application of the
ETSC proration to qualified distributions
in greater detail .
3 . Coordinating ETSC Proration with
Sections 301 and 316
In constructing the mechanics of the
ETSC proration, the Treasury Department
and the IRS sought to harmonize the rules
set forth in section 1371(f) with the general
section 301(c) characterization and section
316 allocation rules that govern distribu-
tions by a C corporation with respect to its
stock . Generally, a distribution by a C cor-
poration with respect to its stock is charac-
terized as a dividend (as defined in section
316), then as a return of stock basis, and
finally any remaining amount as gain from
the sale or exchange of property . See sec-
tions 301(a) and (c). In defining a dividend,
section 316 provides that “every distribu-
tion is made out of earnings and profits to
the extent thereof, and from the most re-
cently accumulated earnings and profits.”
Section 316(a)(2) (flush language). Section
1 .316-2(a) provides that “[i]n determining
the source of a distribution, consideration
should be given first[] to the earnings and
profits of the taxable year....” Section
1 .316-2(b) further provides that, if distribu-
tions during the taxable year consist only
of money and exceed the amount of the C
corporation’s current earnings and profits
(CE&P) for the taxable year, CE&P is allo-
cated proportionately to such distributions,
while AE&P is allocated on a “first-come-
first-served” basis.
Section 1371(f), however, provides spe-
cial rules with respect to qualified distribu-
tions that depart from the general section
301(c) characterization and section 316 al-
location rules . From the perspective of sec-
tions 301 and 316, 1371(f) is thus an excep-
tion to those provisions . See section 301(a)
(providing an exception for provisions
contained in chapter 1 of subtitle A of title
26 of the Code); section 316(a) (providing
an exception for provisions contained in
subtitle A of title 26 of the Code). Specifi-
cally, section 1371(f) provides that, instead
of characterizing a qualified distribution as
a dividend as defined in section 316, first
AAA “shall be allocated to such [qualified]
distribution, and the [qualified] distribution
shall be chargeable to [AE&P], in the same
ratio as the amount of such [AAA] bears to
the amount of such [AE&P] .” The alloca-
tion of AAA ahead of CE&P, and the allo-
cation of AE&P to a distribution ahead of
CE&P, depart from the general characteri-
zation rules of section 301 and the general
section 316 allocation rules
The Treasury Department and the IRS
are aware that this special AE&P allo-
cation rule could impact the normal al-
location of AE&P, as well as CE&P, to
non-qualified distributions by an ETSC, if
an ETSC makes non-qualified and quali-
fied distributions during the same taxable
year . For example, the following could
result when an ETSC makes a non-qual-
ified distribution followed by a qualified
distribution during its taxable year . First,
the non-qualified distribution could be al-
located an amount of AE&P less than the
amount that otherwise would be required
under the general section 316 allocation
rules, because section 1371(f) would re-
quire that a portion of the ETSC’s AE&P
be allocated instead to the “later-in-time”
qualified distribution. Second, because
section 1371(f) would cause the “earli-
er-in-time” non-qualified distribution to
be allocated a reduced amount of AE&P,
the non-qualified distribution could be
characterized differently than it otherwise
would have been characterized absent
section 1371(f) (that is, a characterization
described in section 301(c)(2) or section
301(c)(3), rather than section 301(c)(1)) .
With regard to the predictable impacts
on the treatment and characterization of
non-qualified distributions that result from
Congress’ specific inclusion of AE&P in
section 1371(f)’s AAA allocation meth-
odology, the Treasury Department and the
IRS have determined that the exceptions
set forth in sections 301(a) and 316(a)
naturally extend to such consequences as
well . Based on the language of these Code

Bulletin No. 2019–48 1221 November 25, 2019
sections, as well as Congress’ objective to
ease affected taxpayers’ transition from S
corporation status to C corporation status,
the proposed regulations provide a special
sourcing rule (Section 1371(f) Priority
Rule) for qualified distributions, as de-
scribed in detail in Part II .C of this Expla-
nation of Provisions .
C . Character and Effect of Distributions
during the ETSC Period
The Section 1371(f) Priority Rule es-
sentially provides that, during the ETSC
period, the rules of the ETSC proration un-
der section 1371(f) apply before the rules
of section 301 and 316 . Thus, under the
Section 1371(f) Priority rule, the ETSC
proration first applies to qualified distri-
butions during the taxable year . Then, the
rules of section 301 and 316, as incor-
porated into the Section 1371(f) Priority
Rule, apply to any non-qualified distribu-
tions as well as to any qualified distribu-
tions or portions thereof that are not fully
accounted for by the ETSC proration (i .e .,
because the corporation’s AAA or AE&P
are exhausted during the year) .
The Treasury Department and the IRS
acknowledge that the application of the
Section 1371(f) Priority Rule, as set forth
in these proposed regulations, departs
from the allocation and characterization
rules under sections 301 and 316 with
which taxpayers and practitioners are fa-
miliar . The departure is greatest when an
ETSC has both historical AAA and his-
torical AE&P and makes both qualified
and non-qualified distributions during the
same taxable year . For ETSCs with histor-
ical AAA but no historical AE&P, which
the Treasury Department and the IRS be-
lieve will be the most common situation,
the departure is less significant and is the
same as the departure that section 1371(e)
requires for distributions of AAA during
the PTTP . Immediately following the end
of the taxable year in which the ETSC pe-
riod ends, which occurs when the ETSC’s
AAA balance is reduced to zero, the nor-
mal rules of section 301 and section 316
apply as usual to all distributions . These
proposed regulations are expected to gen-
erally reduce the length of the ETSC peri-
od and thus reduce the time during which
the departure from the normal rules of sec-
tions 301 and 316 occurs .
The following summary provides a ref-
erence to taxpayers and practitioners for
applying the Section 1371(f) Priority Rule
to qualified and non-qualified distribu-
tions made during the taxable years of the
ETSC period, including the taxable year
in which the ETSC period ends .
1 . Determination of the AAA Ratio and
the AE&P Ratio
The Section 1371(f) Priority Rule ap-
plies the ETSC proration to each qualified
distribution . To determine the ETSC pro-
ration, the AAA ratio and the AE&P ratio
must first be calculated. An ETSC’s AAA
ratio is the fraction of which the numera-
tor is its historical AAA and the denomi-
nator is the sum of its historical AAA and
historical AE&P . Likewise, an ETSC’s
AE&P ratio is the fraction of which the
numerator is its historical AE&P, and the
denominator is the sum of its historical
AAA and historical AE&P .
In general, the AAA ratio and the
AE&P ratio do not change over the course
of the ETSC period . However, if the ap-
plication of the AE&P ratio to a qualified
distribution reduces the ETSC’s AE&P to
zero, and the ETSC’s historical AAA has
not been exhausted, then the AAA ratio
is one and the AE&P ratio is zero for the
remainder of the year and all subsequent
taxable years of the ETSC period . Addi-
tionally, if the ETSC’s AE&P (which in-
cludes its historical AE&P) is less than or
equal to zero as of the beginning of a tax-
able year (for example, due to non-quali-
fied distributions or losses incurred during
the prior taxable year) and the ETSC’s his-
torical AAA has not been exhausted, then
the AAA ratio is one and the AE&P ratio
is zero for the year and all subsequent tax-
able years of the ETSC period . These me-
chanics are responsive to the exhaustion
of the ETSC’s historical AE&P, and there-
fore accelerate the distribution of AAA by
permitting the entirety of all subsequent
qualified distributions to be sourced from
the ETSC’s AAA .
2. Identification of Qualified and Non-
Qualified Distributions during Taxable
Year
Application of the Section 1371(f) Pri-
ority Rule depends, in part, upon whether
a distribution by an ETSC is a qualified or
non-qualified distribution. As a result, for
each taxable year of an ETSC, each distri-
bution must be characterized as a qualified
distribution or a non-qualified distribution
before determining the characterization
of such distribution under the Section
1371(f) Priority Rule .
3 . Characterization and Consequences of
Qualified Distributions
For each taxable year of the ETSC pe-
riod, including the taxable year in which
the ETSC period ends, the characteriza-
tion of each qualified distribution must be
determined prior to the characterization
of each non-qualified distribution. The
portion of a qualified distribution that is
sourced from AAA is equal to the lesser of
(i) the product of the qualified distribution
and the AAA ratio, and (ii) the ETSC’s
AAA immediately before the qualified
distribution . Such AAA-sourced portion
of the qualified distribution reduces both
the ETSC’s AAA and the shareholder’s
adjusted stock basis, applying the princi-
ples of section 301(c)(2) . If the amount
of that AAA-sourced portion exceeds the
shareholder’s stock basis, the excess is
treated as gain from the sale or exchange
of property, regardless of whether the cor-
poration has CE&P or AE&P available .
If the amount sourced from AAA equals
the balance of the ETSC’s AAA before
the qualified distribution, all subsequent
distributions by the ETSC are treated in
the manner provided in section 301(c) . If
the amount sourced from AAA is less than
that balance, then any remaining AAA is
available to be allocated to later qualified
distributions during the taxable year . If
any AAA remains after all qualified dis-
tributions for the taxable year have been
accounted for, it is carried forward to the
next taxable year of the ETSC .
The portion of a qualified distribution
that is charged to AE&P is equal to the
lesser of (i) the product of the qualified
distribution and the AE&P ratio, and (ii)
the ETSC’s AE&P immediately before
the qualified distribution. The ETSC’s
AE&P is reduced by the charged amount
in accordance with section 312(a)(1) . The
ETSC’s AE&P is reduced by the portion
of the qualified distribution chargeable to
AE&P prior to the application of the rules

November 25, 2019 1222 Bulletin No. 2019–48
of sections 301 and 316, as incorporated
into the Section 1371(f) Priority Rule, to
any non-qualified distribution, regardless
of whether the non-qualified distribution
occurred prior to the qualified distribu-
tion. The amount of the qualified distribu-
tion that is charged to the ETSC’s AE&P
is included in the gross income of the
shareholder as a dividend under section
301(c)(1) .
4 . Application of ETSC proration to
excess qualified distributions
Any portion of a qualified distribu-
tion that is not initially accounted for by
the ETSC proration is referred to as an
“excess qualified distribution.” An ex-
cess qualified distribution arises when
the ETSC no longer has AAA, AE&P,
or both after initially applying the ETSC
proration . If the initial application of the
ETSC proration to a qualified distribution
does not fully account for the amount of
the distribution and the ETSC continues
to have AAA, the Section 1371(f) Priority
Rule requires that the ETSC proration be
reapplied to the excess qualified distribu-
tion as if the excess qualified distribution
were a separate qualified distribution us-
ing a AAA ratio of one and an AE&P ratio
of zero . See Part II .C .1 of this Explanation
of Provisions .
5 . Characterization and Consequences of
Non-Qualified Distributions and Excess
Qualified Distributions
The Section 1371(f) Priority Rule re-
quires non-qualified distributions and
excess qualified distributions (to the ex-
tent not characterized as a distribution
of AAA) to be treated in the manner de-
scribed in section 301(c) . The Section
1371(f) Priority Rule requires that such
treatment take into account the treatment
of each non-qualified distribution and
each excess qualified distribution made by
the ETSC during the same taxable year .
6 . Requests for Comments
The Treasury Department and the IRS
evaluated several other approaches to im-
plementing section 1371(f) and the rules
that would be needed to coordinate those
approaches with the rules of sections 301
and 316 before settling on the approach
adopted in the Section 1371(f) Priority
Rule . The Treasury Department and the
IRS request comments regarding the ad-
vantages and disadvantages of the Section
1371(f) Priority Rule as well as other pro-
posals that would help ease the transition
of S corporation status to C corporation
status . The Treasury Department and the
IRS also request comments regarding the
effect of section 381(a) transactions in
which an ETSC is either the transferor or
the acquiring corporation (including cer-
tain triangular acquisitions) as well as the
effect of an ETSC electing to file a con-
solidated return or joining a consolidated
group . The Treasury Department and the
IRS further request comments on the ef-
fect of subchapter C transactions (includ-
ing section 302(a) redemptions, section
355 transactions, and section 368 reorga-
nizations) and the effect of a deemed dis-
tribution (including forgiveness of share-
holder debt) on the ETSC’s AAA balance .
III. Amendment of §1.316-2 to Clarify
Allocation of CE&P to Non-Cash
Distributions
Section 316(a) provides that a divi-
dend is a distribution of property made
by a corporation to its shareholders out of
its CE&P or AE&P, or both . Pursuant to
§1 .316-2(a), in determining the source of
a distribution under section 316(a), a cor-
poration must first source the distribution
from its CE&P before sourcing such dis-
tribution from AE&P . If the corporation’s
CE&P is sufficient to cover “all the dis-
tributions” made during the taxable year,
then the entirety of each distribution is
taxable as a dividend pursuant to the first
sentence of §1 .316-2(b) . If a corporation’s
distributions during the taxable year con-
sist “only of money” and exceed CE&P,
each distribution is allocated its ratable
share of CE&P pursuant to the second
sentence of §1 .316-2(b) .
The reference to distributions that
“consist only of money” has been in the
second sentence of §1 .316-2(b) since that
regulation was adopted in 1955 . Section
1 .316-2 was adopted shortly after the en-
actment of the Internal Revenue Code of
1954 (1954 Code), which contained sev-
eral provisions relating to distributions of
noncash property . A number of these pro-
visions have since changed . In particular,
section 311 of the 1954 Code provided
that a distributing corporation generally
did not recognize any gain or loss on the
distribution of noncash property, and sec-
tion 312 of the 1954 Code provided that
the distributing corporation generally re-
duced its earnings and profits by the ad-
justed basis of the property distributed . At
the same time, section 301(b) of the 1954
Code provided that the amount of a distri-
bution of noncash property to a sharehold-
er depended on the type of shareholder .
Individual shareholders were treated as
receiving a distribution equal to the fair
market value of the property, while cor-
porate shareholders were generally treat-
ed as receiving a distribution equal to the
lesser of the property’s fair market value
or the distributing corporation’s adjusted
basis in the asset distributed . In light of
these provisions, the 1955 promulgation
of §1 .316-2 illustrated the consequences
of the allocation of CE&P in the simplest
fact pattern — when the distributions con-
sist only of money .
Under current law, however, a dis-
tributing corporation recognizes gain on
a section 301 distribution of appreciat-
ed noncash property . See section 311 .
The amount of a distribution of noncash
property for purposes of shareholder tax-
ation equals the property’s fair market
value, irrespective of whether the share-
holder is an individual or a corporation .
Additionally, section 316(a)(2) makes no
distinction between distributions in cash
and distributions of other property under
section 301 . Section 317(a), which sec-
tion 301 cross-references for purposes of
defining property, includes money, secu-
rities, and any other property, except a
distributing corporation’s own stock . Ac-
cordingly, the Treasury Department and
the IRS do not believe that the language
in the second sentence of §1 .316-2(b)
should be interpreted as implying that
under current law the application of the
pro rata allocation rule for CE&P is lim-
ited to distributions made only in money .
Cf . GCM 36138 (Jan . 15, 1975) (noting
that “[section] 316(a)(2) makes no quali-
tative distinction between distributions in
cash and other distributions of property
under [section] 301,” and “[t]hus, there
is no basis under [section] 316(a)(2) for
limiting the application of the rules under

Bulletin No. 2019–48 1223 November 25, 2019
[§]1 .316-2(b) to distributions made sole-
ly in money”) . Therefore, in order to clar-
ify that the pro rata allocation of CE&P
applies to all section 301 distributions
made during the taxable year, whether in
cash or in kind, the proposed regulations
would remove the words “consist only of
money and” from the second sentence of
paragraph (b) .
IV. Amendment of §1.1377-2 to Allow for
New Shareholders during the PTTP
The last sentence of §1 .1377-2(b) lim-
its the special treatment provided under
section 1371(e)(1) (that is, the PTTP) sole-
ly to those shareholders who were share-
holders of the S corporation at the time of
termination or revocation of its S election .
Because the rules pertaining to the PTTP
and to the ETSC period serve the similar
objective of easing the transition from S
corporation status to C corporation sta-
tus, the Treasury Department and the IRS
have determined that these rules regarding
newcomers should be consistent . There-
fore, based on the rationale for rejecting a
no-newcomer rule for the ETSC period, as
set forth in Part II .A of this Explanation of
Provisions, the Treasury Department and
the IRS have determined that a no-new-
comer rule should also not apply to the
PTTP . The Treasury Department and the
IRS request comments regarding this de-
termination .
Proposed Applicability Dates
The regulations are proposed to apply
to taxable years beginning after the date
of publication of the Treasury decision
adopting these regulations as final regula-
tions in the Federal Register . However,
the proposed regulations provide corpo-
rations with the option to apply the final
rules in §§1 .316-2, 1 .481-5, 1 .1371-1,
1 .1371-2, and 1 .1377-2 in their entirety, to
the extent applicable, to taxable years that
began on or before the date of publica-
tion of a Treasury decision adopting these
rules as final regulations in the Federal
Register and with respect to which the
period described in section 6511(a) has
not expired . If the corporation makes the
choice described in the previous sentence,
all shareholders of the corporation must
report consistently .
Special Analyses
This regulation is not subject to review
under section 6(b) of Executive Order
12866 pursuant to the Memorandum of
Agreement (April 11, 2018) between the
Treasury Department and the Office of
Management and Budget regarding re-
view of tax regulations .
I. Regulatory Flexibility Act
Pursuant to the Regulatory Flexibility
Act (5 U .S .C . chapter 6), it is hereby cer-
tified that these proposed regulations under
sections 481(d), 1371(f), and 1377 of the
Code will not have a significant economic
impact on a substantial number of small en-
tities within the meaning of section 601(6)
of the Regulatory Flexibility Act . Notwith-
standing this certification, the Treasury De-
partment and the IRS invite comments on
the impact that these proposed regulations
would have on small entities .
These proposed regulations generally
affect corporations, and their sharehold-
ers, that convert from being taxed as an
S corporation to being taxed as a C cor-
poration . The Treasury Department and
the IRS acknowledge that there is a sub-
stantial number of small entities that are
S corporations that could convert to being
taxed as a C corporation . According to
the 2013 Corporate Income Tax Returns
Complete Report (https://www .irs .gov/
pub/irs-soi/13coccr .pdf), approximately
83 percent of S corporations had gross
receipts under $1,000,000 . However,
the proposed regulations under section
1371(f) are limited to corporations that:
(i) Revoke their S elections;
(ii) Make their revocations during a spec-
ified two-year period beginning on
December 22, 2017;
(iii) Have positive AAA at the conclusion
of their PTTP; and
(iv) Have the same shareholders (and in
identical proportions) on Decem-
ber 22, 2017, and the date the S elec-
tion revocation is made (shareholder
identity requirement) .
Because these proposed regulations ap-
ply only to those S corporations that satis-
fy the criteria above, only a small subset
of S corporations will be affected .
The U .S . Department of Treasury, In-
ternal Revenue Service, Data Book 2018
(Data Book) (https://www .irs .gov/pub/
irs-soi/18databk .pdf) reports that the IRS
received approximately 5 .1 million S
corporation income tax returns in 2018 .
According to the Compliance Data Ware-
house (CDW), between January 1, 2018,
and December 31, 2018, 4,850 S corpora-
tions terminated their S elections . Of the
4,850 terminated S corporations:
(i) 286 corporations had more than $35
million in gross receipts;
(ii) 81 corporations had between $25-$35
million in gross receipts;
(iii) 161 corporations had between $15-
$25 million in gross receipts; and
(iv) 3,011 corporations had less than $15
million, but at least $1 in gross re-
ceipts .
In addition, of those 4,850 terminated
S corporations:
(i) 694 corporations reported no gross
receipts; and
(ii) The remaining 617 did not file a final
return after terminating their S elec-
tion .
A revocation is one of the three meth-
ods by which a corporation may termi-
nate its S election under section 1362(d) .
Proposed §§1 .481-5, 1371-1, and 1371-2
apply only to those corporations that re-
voke their S election . The CDW does not
identify how many of the 4,850 termi-
nations were revocations . In the unlike-
ly scenario that all 4,850 terminations
were revocations, approximately 0 .0951
percent of the 5 .1 million S corporations
in existence in 2018 may be affected by
these proposed regulations . Extrapolat-
ing from the first-year data (January 1,
2018, to December 31, 2018) to the sec-
ond half of the two-year period (January
1, 2019, to December 21, 2019) during
which these proposed regulations are ef-
fective, it is possible another 4,850 for-
mer S corporations could be affected by
these proposed regulations . Thus, these
proposed regulations might only affect
a total of 9,700 corporations . Assuming
that the IRS again receives 5 .1 million
S corporation income tax returns for the
2019 tax year, these proposed regulations
may affect approximately 0 .1902 percent
of all S corporations in existence in 2018
and 2019 . The exact number may be low-
er because not all terminations are revo-
cations, and a revocation only satisfies
one of several criteria that cause these

November 25, 2019 1224 Bulletin No. 2019–48
proposed regulations to be applicable .
For these proposed regulations to be ap-
plicable, the corporation must also have
a positive AAA balance at the conclusion
of its PTTP and satisfy the sharehold-
er identity requirement . Therefore, the
number of affected corporations is likely
to be lower .
The other proposed regulation in this
notice of proposed rulemaking, proposed
§1 .1377-2(b), generally applies to a cor-
poration that terminates its S election with
a positive AAA balance, regardless of
when or how the termination occurs (see
section 1362(d)) . As a result, the change
made by proposed regulation §1 .1377-
2(b) to allow newcomer shareholders will
affect a greater number of terminating
S corporations than proposed regulation
§§1 .481-5, 1 .1371-1, and 1 .1371-2 . Nev-
ertheless, the number of corporations that
terminate their S election remains min-
imal . According to the CDW, there were
2,798 S corporation terminations in 2015;
2,960 in 2016; 3,125 in 2017; and 4,850
in 2018 . When comparing the number of
terminating S corporations to the number
of S corporation income tax returns filed
each year, only a small fraction of S cor-
porations will be affected .
In addition, based on published in-
formation from the Conference Report
accompanying the Act, H .R . Rep . No .
115-446, at 688 (2017), and Bureau of
Economic Analysis aggregate data, which
were adjusted to reflect the tax burden of
small businesses, the projected net tax
proceeds from sections 481(d), 1371(f),
and 1377 are estimated to affect only a
small fraction of the total number of S
corporations .
The Treasury Department and the IRS
have determined that no additional burden
will be associated with these proposed
regulations . In particular, the collection
of information necessary to comply with
these proposed regulations is already re-
quired to be collected by previously exist-
ing statutory and regulatory requirements .
Additionally, these proposed regulations
apply only if an S corporation revokes its
S election between December 22, 2017
and December 21, 2019, fulfills the share-
holder identity requirement, and has a
positive AAA balance at the conclusion
of its PTTP . The proposed removal of
§1 .1377-2(b)’s last sentence would re-
duce a taxpayer’s compliance burden by
eliminating the need to track shareholders
during the PTTP .
For the reasons explained above, the
Treasury Department and the IRS have
determined that the final regulations will
not have a significant economic impact
on a substantial number of small entities .
Pursuant to section 7805(f), the notice of
proposed rulemaking will be submitted
to the Chief Counsel for Advocacy of the
Small Business Administration for com-
ment on its impact on small business .
II. Paperwork Reduction Act
These proposed regulations do not re-
quire collection of any new or additional
information pursuant to the Paperwork
Reduction Act (PRA) (44 U .S .C . 3501 et
seq .) .
The Treasury Department and the IRS
intend that the information necessary to
apply these proposed regulations will be
collected with the following forms that
have been previously reviewed and ap-
proved by the Office of Management and
Budget (OMB) under the PRA:
(i) Form 1120-S, U .S . Income Tax Re-
turn for an S Corporation (OMB Con-
trol Number 1545-0123);
(ii) Schedule K-1 (Form 1120-S), Share-
holder’s Share of Income, Deduc-
tions, Credits, etc . (OMB Control
Number 1545-0123);
(iii) Form 1120, U .S . Corporation Income
Tax Return (OMB Control Number
1545-0123);
(iv) Form 5452, Corporate Report of Non-
dividend Distributions (OMB Control
Number 1545-0123); and
(v) Form 1099-DIV, Dividends and Dis-
tributions (OMB Control Number
1545-0110) .
Section 1362(e) requires a corporation
that revoked or terminated its S election to
file a return for its last taxable year as an
S corporation on Form 1120-S. This filing
requirement includes an eligible terminat-
ed S corporation (ETSC) . Section 6037(b)
and the regulations thereunder require ev-
ery S corporation to maintain certain infor-
mation, such as its shareholders’ names,
addresses, and other identifying informa-
tion throughout the taxable year, in order
to furnish its shareholders with the infor-
mation necessary to complete their return
(in other words, Schedule K-1) . Because
sections 1366(a) and 1377(a)(1) allocate
an S corporation’s items of income and
loss to shareholders on a per-share, per-
day basis, every S corporation effectively
tracks its shareholders, and their respec-
tive ownership percentages, on a daily ba-
sis . The information that every S corpora-
tion currently collects to comply with the
existing requirements of sections 1366(a),
1377(a)(1), and 6037(b) will be used to
determine whether a corporation satisfies
the shareholder identity requirement of
proposed §1 .481-5(b)(3) .
Any corporation that qualifies as an
ETSC will refer to Schedule M-2 of its
last filed Form 1120-S to calculate each
of its AAA and AE&P ratios, within the
meaning of proposed §1 .1371-1(a)(2)
(vii), to determine its historical AAA and
historical AE&P amounts . If an ETSC
enters a closing agreement pursuant to a
subsequent audit, it will adjust its histor-
ical AAA and historical AE&P amounts
accordingly .
At the beginning of a corporation’s
ETSC period, an ETSC will also refer to
Schedule M-2 of its last filed Form 1120-
S to determine the balance of its accumu-
lated adjustments account (AAA) at the
end of its last tax year as an S corporation .
If an ETSC makes no cash distributions
during its post-termination transition peri-
od (PTTP), within the meaning of section
1377(b)(1)(A), then it will start its ETSC
period with a AAA balance equal to the
amount reported as the AAA balance at the
end of the tax year on Schedule M-2 of its
last filed Form 1120-S. If an ETSC makes
cash distributions during its PTTP, then it
will start its ETSC period with a AAA bal-
ance equal to the difference between the
amount reported as the AAA balance at
the end of the tax year on Schedule M-2 of
its last filed Form 1120-S and the amount
of cash distributions that the ETSC made
during its PTTP .
Every domestic C corporation must
file an income tax return on Form 1120,
and attach Form 5452 if it makes a non-
dividend distribution to its shareholders .
In particular, the instructions for Form
5452 require any corporation that makes
a distribution under section 1371(f) to file
a Form 5452 . In any tax year in which an
ETSC makes a qualified distribution, it is
required to attach Form 5452 and report

Bulletin No. 2019–48 1225 November 25, 2019
its AAA balance, the amount of AE&P at
the beginning of the tax year, the amount
of CE&P for the current tax year, and the
amounts paid during the calendar year
from earnings and profits and from “other
than earnings and profits.” The informa-
tion collected through Form 5452 is suffi-
cient for an ETSC to apply these proposed
regulations . In particular, the information
collected through Form 5452 is sufficient
for an ETSC to determine its AAA balance
both before and after each qualified dis-
tribution, as well as determine the impact
that each qualified distribution has on its
CE&P and AE&P .
With respect to shareholders of ETSC
stock, an ETSC is required (like any C
corporation that makes a distribution to
its shareholders) to provide a statement to
its non-corporate recipient shareholders
that reports the amounts characterized as
a dividend and nondividend distribution
on Form 1099-DIV . Form 1099-DIV will
inform an ETSC’s shareholders of the
amount that constitutes a dividend subject
to section 301(c)(1) and the amount that
constitutes a nondividend distribution .
Distributions allocable to AAA will be re-
ported to recipient shareholders as a non-
dividend distribution .
The Treasury Department and the IRS
do not anticipate modifying the scope of
the information gathered on the aforemen-
tioned forms .
Modest burden estimate revisions are
anticipated for proposed regulations un-
der §1.1377-2. Specifically, the proposed
removal of §1 .1377-2(b)’s last sentence
would reduce a taxpayer’s collection bur-
den by eliminating the need to track share-
holders during the PTTP . Changes to these
burden estimates will be made in accor-
dance with the PRA in the annual review
procedure for information collections un-
der OMB Control Number 1545-0123 .
These proposed regulations are esti-
mated to affect a total of 9,700 corpora-
tions, or 0 .1902% of all S corporations in
existence in 2018 and 2019 . Regarding
proposed regulations §§1 .481-5, 1 .481-6,
1 .1371-2, and 1 .1371-3, the exact num-
ber might be lower because the 9,700 is
extrapolated from data and projections of
S corporation terminations, not the subset
revocations, and to qualify as an ETSC
the corporation must also have a posi-
tive AAA balance at the conclusion of its
PTTP and satisfy the shareholder identity
requirement .
An agency may not conduct or sponsor,
and a person is not required to respond to,
a collection of information unless it dis-
plays a valid control number assigned by
the OMB .
III . Unfunded Mandates Reform Act
Section 202 of the Unfunded Mandates
Reform Act of 1995 requires that agencies
assess anticipated costs and benefits and
take certain other actions before issuing a
final rule that includes any Federal man-
date that may result in expenditures in any
one year by a state, local, or tribal govern-
ment, in the aggregate, or by the private
sector, of $100 million in 1995 dollars, up-
dated annually for inflation. In 2019, that
threshold is approximately $164 million .
This rule does not include any mandate
that may result in expenditures by state,
local, or tribal governments, or by the pri-
vate sector in excess of that threshold .
IV . Executive Order 13132: Federalism
Executive Order 13132 (entitled
“Federalism”) prohibits an agency from
publishing any rule that has federalism
implications if the rule either imposes
substantial, direct compliance costs on
state and local governments, and is not
required by statute, or preempts state law,
unless the agency meets the consultation
and funding requirements of section 6 of
the Executive Order . This rule does not
have federalism implications and does
not impose substantial, direct compliance
costs on state and local governments or
preempt state law within the meaning of
the Executive Order .
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, consideration
will be given to any comments that are
submitted timely to the IRS as prescribed
in this preamble under the ADDRESSES
section . The Treasury Department and the
IRS request comments on all aspects of the
proposed rules, and specifically on the is-
sues identified in Part I.A.3; in Parts II.B.1
and II .C .6; and in Part IV of this Explana-
tions of Provisions section . All comments
will be made available at http://www .
regulations .gov or upon request . A public
hearing will be scheduled if requested in
writing by any person that timely submits
written comments . If a public hearing is
scheduled, then notice of the date, time,
and place for the public hearing will be
published in the Federal Register .
Drafting Information
The principal authors of these proposed
regulations are Margaret Burow and Mi-
chael Gould of the Office of Associate
Chief Counsel (Passthroughs and Special
Industries), and Aglaia Ovtchinnikova and
Kevin M. Jacobs of the Office of Associ-
ate Chief Counsel (Corporate) . Howev-
er, other personnel from the IRS and the
Treasury Department participated in the
development of the proposed regulations .
* * * * *
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 1 is pro-
posed to be amended as follows:
PART 1—INCOME TAXES
Paragraph 1 . The authority citation for
part 1 is amended by adding an entry in
numerical order for § 1 .481-6 to read in
part as follows:
Authority: 26 U .S .C . 7805 * * *
Section 1 .481-6 is also issued under 26
U .S .C . 481 .
* * * * *
§1 .316-2 [Amended]
Par . 2 . Section 1 .316-2 is amended by
removing “consist only of money and”
from the second sentence of paragraph (b) .
§1 .481-5 [Redesignated as §1 .481-6]
Par . 3 . Section 1 .481-5 is redesignated
as §1 .481-6 .
Par . 4 . Add new §1 .481-5 to read as
follows:
§1.481-5 Eligible terminated S corpo-
ration .
(a) Scope. Section 481(d)(2) and this
section provide rules relating to the qual-
ification of a corporation as an eligible
terminated S corporation (ETSC). Para-
graph (b) of this section sets forth the
requirements a corporation must meet to
qualify as an ETSC. Paragraph (c) of this

November 25, 2019 1226 Bulletin No. 2019–48
section describes certain transfers and
other events that are disregarded for pur-
poses of determining whether a corpora-
tion qualifies as an ETSC. Paragraph (d)
of this section contains examples illustrat-
ing the rules of this section.
(b) ETSC qualification. For a C corpo-
ration to qualify as an ETSC, it must satis-
fy the following requirements:
(1) The corporation must have been an
S corporation on December 21, 2017;
(2) During the 2-year period beginning
on December 22, 2017, the corporation
must have made a valid revocation of its S
election under section 1362(d)(1) and the
regulatory provisions in this part under
section 1362 of the Code (Revocation);
and
(3) Except as provided in paragraph (c)
of this section, the owners of the shares of
stock of the corporation must be the same
(and in identical proportions) on both:
(i) December 22, 2017; and
(ii) The day on which the Revocation is
made .
(c) Certain disregarded events. The
following events are disregarded for pur-
poses of determining whether the require-
ment in paragraph (b)(3) of this section is
satisfied:
(1) Transfers of stock between a share-
holder and that shareholder’s trust treated
as wholly owned by that shareholder un-
der subpart E of subchapter J of chapter 1
of the Code;
(2) Transfers of stock between a share-
holder and an entity owned by that share-
holder which is disregarded as separate
from its owner under §301 .7701-2(c)(2)
(i) of this chapter;
(3) An election by a shareholder trust
to be treated as part of a decedent’s estate
under section 645 or the termination of an
election under that section;
(4) A change in the status of a share-
holder trust from one type of eligible S
corporation shareholder trust described in
section 1361(c)(2)(A) to another type of
eligible S corporation shareholder trust;
for example, a trust to which the shares
of stock were transferred pursuant to
the terms of a will (testamentary trust)
described in section 1361(c)(2)(A)(iii)
which elects to become an electing small
business trust described in section 1361(c)
(2)(A)(v) and (e); and
(5) A transaction that includes more
than one of the events described in this
paragraph (c) .
(d) Examples. The following examples
illustrate the rules of this section. For pur-
poses of the examples in this paragraph
(d), as of December 1, 2017, X is a calen-
dar year S corporation with 100 shares of
stock outstanding that is owned equally by
unrelated individuals A and B. Pursuant
to section 1362(d)(1) and §§1.1362-2 and
1.1362-6, X made a valid revocation of its
S election on March 15, 2019, effective
on January 1, 2019. At all times, X has a
single class of stock outstanding. The ex-
amples describe all relevant transactions
involving the X stock from December 1,
2017 until March 15, 2019.
(1) Example 1—(i) Facts . On June 5, 2018, A
contributed 20 of its shares of X stock to Y, a wholly
owned limited liability company that is disregarded
as an entity separate from A pursuant to §301 .7701-
2(c)(2)(i) of this chapter . On June 14, 2018, A con-
tributed all of its interest in Y to Trust, which was
a revocable trust treated as a wholly owned grantor
trust of A pursuant to sections 671 and 676 . On De-
cember 27, 2018, B sold 10 shares of its X stock to
C, an unrelated person .
(ii) Analysis. X is an ETSC if it satisfies the re-
quirements of paragraph (b) of this section .
(A) S corporation . X was an S corporation on
December 21, 2017. Therefore, X satisfies the re-
quirement of paragraph (b)(1) of this section .
(B) Date of revocation . X made a valid revoca-
tion of its S election pursuant to section 1362(d)(1)
on March 15, 2019, which is within the 2-year period
specified in paragraph (b)(2) of this section. There-
fore, X satisfies the requirement of paragraph (b)(2)
of this section .
(C) Ownership . For purposes of the requirement
in paragraph (b)(3) of this section, the relevant dates
are: December 22, 2017, and March 15, 2019 (the
date X made a revocation of its S corporation status) .
(1) A’s ownership interest . As of December 22,
2017, A owned 50 shares of the outstanding shares
of X stock . On June 5, 2018, A contributed 20 of its
shares of X stock to Y (Transfer) . On June 14, 2018,
A contributed all of its interest in Y to Trust (Contri-
bution) . Both the Transfer and the Contribution are
disregarded for purposes of determining whether the
requirement of paragraph (b)(3) of this section is sat-
isfied. See paragraphs (c)(2) and (1) of this section,
respectively . Therefore, A owns 50 shares of the out-
standing stock of X on March 15, 2019 .
(2) B’s ownership interest . As of December 22,
2017, B owned 50 shares of the outstanding shares
of X stock . On December 27, 2018, B sold 10 shares
to C . Therefore, B owns 40 shares of the outstanding
stock of X on March 15, 2019 .
(3) C’s ownership interest . As of December 22,
2017, C owned no shares of X stock . On December
27, 2018, C purchased 10 shares from B . Therefore,
C owns 10 shares of the outstanding stock of X on
March 15, 2019 .
(4) Failure to satisfy the requirement in para-
graph (b)(3) of this section . As described in para-
graphs (d)(1)(ii)(C)(2) and (3) of this section, B’s and
C’s interest in X were not in the same proportions on
December 22, 2017, and March 15, 2019 . Therefore,
X does not satisfy the requirement of paragraph (b)
(3) of this section and does not qualify as an ETSC .
(iii) Restoration of interests prior to end of
PTTP . If C transferred its shares of X stock back to
B on February 1, 2019, then on December 22, 2017,
and March 15, 2019, A and B will have owned 50
shares of the outstanding stock of X . Therefore, X
satisfies the requirement of paragraph (b)(3) of this
section and qualifies as an ETSC.
(2) Example 2—(i) Facts . The facts are the same
as in paragraph (d)(1)(i) of this section (the facts in
Example 1), except that B sold 10 shares of its X
stock to C on December 18, 2017, in addition to the
sale of 10 shares of X stock on December 27, 2018 .
(ii) Analysis . The analysis in paragraphs (d)(1)
(ii)(A) and (B) of this section remains the same re-
garding the requirements of paragraphs (b)(1) and
(2) of this section . With respect to the requirement
of paragraph (b)(3) of this section, on December 22,
2017, A owned 50%, B owned 40%, and C owned
10% of the outstanding stock of X . As in paragraph
(d)(1)(ii)(C)(1) of this section, the Transfer and the
Contribution are disregarded for purposes of deter-
mining whether the requirement of paragraph (b)
(3) of this section is satisfied. Therefore, on March
15, 2019, A owned 50% (50 shares), B owned 30%
(30 shares), and C owned 20% (20 shares) of the
outstanding shares of X . Even though A, B, and C
owned shares of X on December 22, 2017, B’s and
C’s proportionate ownership interest of X stock was
not the same on December 22, 2017 and March 15,
2019 . Therefore, X does not satisfy the requirement
of paragraph (b)(3) of this section and does not qual-
ify as an ETSC .
(3) Example 3—(i) Facts . The facts are the same
as in paragraph (d)(1)(i) of this section (the facts in
Example 1), except that X made a valid revocation
of its S election on November 1, 2019, effective on
January 1, 2020 .
(ii) Analysis . The analysis in paragraphs (d)
(1)(ii)(A) through (C) of this section remains the
same regarding the requirements of paragraphs (b)
(1) through (3) of this section, except that the rele-
vant dates are: December 22, 2017, and November
1, 2019 (the date X made a revocation of its S cor-
poration status) . Although the effective date of X’s
revocation of its S election (January 1, 2020) occurs
after the conclusion of the 2-year period specified in
paragraph (b)(2) of this section, it is irrelevant for
purposes of determining whether the requirements of
paragraphs (b)(2) and (3) of this section are satisfied.
Par . 5 . Newly redesignated §1 .481-6 is
amended by revising the section heading
and adding three sentences at the end of
the paragraph to read as follows:
§1.481-6 Applicability date .
* * * The rules of §1 .481-5 general-
ly apply to taxable years beginning after
[DATE OF PUBLICATION OF THE FI-
NAL RULES IN THE FEDERAL REG-
ISTER] . However, corporations may

Bulletin No. 2019–48 1227 November 25, 2019
choose to apply the rules in §§1 .316-2,
1 .481-5, 1 .1371-1, 1 .1371-2, and 1 .1377-
2 in their entirety, to the extent applicable,
to taxable years that began on or before
[DATE OF PUBLICATION OF THE FI-
NAL RULES IN THE FEDERAL REG-
ISTER] and with respect to which the
period described in section 6511(a) has
not expired . If the corporation makes the
choice described in the previous sentence,
all shareholders of the corporation must
report consistently .
Par . 6 . Sections 1 .1371-1 and 1 .1371-2
are added to read as follows:
§1.1371-1 Distributions of money by
an eligible terminated S corporation .
(a) Scope and definitions—(1) Scope.
This section provides rules relating to
qualified distributions (as defined in para-
graph (a)(2)(xii) of this section) and dis-
tributions to which section 301 applies
during each taxable year of the ETSC
period (as defined in paragraph (a)(2)
(vii) of this section), including the taxable
year in which the ETSC period ends. If the
ETSC (as defined in paragraph (a)(2)(vi)
of this section) does not make any qual-
ified distributions during a taxable year,
then no distribution by the ETSC is gov-
erned by section 1371(f) or this section.
Paragraph (a)(2) of this section contains
definitions that apply for purposes of this
section. Paragraph (b) of this section con-
tains rules regarding the characterization
of a qualified distribution. Paragraph (c)
of this section contains rules regarding the
characterization of any excess qualified
distribution (as defined in paragraph (a)
(2)(viii) of this section) and non-qualified
distribution (as defined in paragraph (a)
(2)(xi) of this section) during each tax-
able year of the ETSC period, including
the taxable year in which the ETSC period
ends. Paragraph (d) of this section con-
tains examples illustrating the rules of this
section. Paragraph (e) of this section con-
tains the applicability date of this section.
(2) Definitions
. The following defini-
tions apply for purposes of this section—
(i) AAA . The term AAA means the accumulated
adjustments account, within the meaning of section
1368(e)(1)(A) and §1 .1368-2(a)(1) .
(ii) AAA ratio . Except as provided in this para-
graph (a)(2)(ii) or paragraph (b)(3)(iv) of this sec-
tion, the term AAA ratio means the fraction of which
the numerator is historical AAA and the denominator
is the sum of historical AAA and historical AE&P .
Notwithstanding the preceding sentence, if the
AE&P of the ETSC is less than or equal to zero as of
the beginning of a taxable year, then the AAA ratio
is one for such year and all subsequent taxable years
of the ETSC period .
(iii) AE&P . The term AE&P means earnings and
profits described in section 316(a)(1).
(iv) AE&P ratio . Except as provided in this
paragraph (a)(2)(iv) or paragraph (b)(3)(iv) of this
section, the term AE&P ratio means the fraction of
which the numerator is historical AE&P, and the de-
nominator is the sum of historical AAA and histori-
cal AE&P . Notwithstanding the preceding sentence,
if the AE&P of the ETSC is less than or equal to zero
as of the beginning of a taxable year, then the AE&P
ratio is zero for such year and all subsequent taxable
years of the ETSC period .
(v) CE&P . The term CE&P means earnings and
profits that are described in section 316(a)(2).
(vi) ETSC . The term ETSC means an eligible ter-
minated S corporation, within the meaning of section
481(d) and §1 .481-5 .
(vii) ETSC period . In general, the term ETSC pe-
riod means any taxable year, or portion thereof, of an
ETSC beginning on the first day after the post-termi-
nation period within the meaning of section 1377(b)
(1)(A) and ending on the date on which the ETSC’s
AAA balance is zero . Additionally, an ETSC does
not have an ETSC period if the ETSC’s AAA bal-
ance is not greater than zero at the end of its post-ter-
mination transition period . See §1 .1371-2 for rules
governing the impact of a post-termination period,
within the meaning of section 1377(b)(1)(B), on the
ETSC period .
(viii) Excess qualified distribution . The term
excess qualified distribution means the portion of a
qualified distribution that is not characterized pursu-
ant to paragraph (b)(2) or (3) of this section .
(ix) Historical AAA . The term historical AAA
means the AAA of the ETSC as of the beginning of
the day on which the revocation of an election un-
der section 1362(a) is effective pursuant to section
1362(d)(1) .
(x) Historical AE&P . The term historical AE&P
means the AE&P of the ETSC as of the beginning of
the day on which the revocation of an election un-
der section 1362(a) is effective pursuant to section
1362(d)(1) . For purposes of the preceding sentence,
if the ETSC’s historical AE&P is less than zero, then
the historical AE&P is treated as zero .
(xi) Non-qualified distribution . The term
non-qualified distribution means a distribution to
which section 301 applies, which is not a qualified
distribution .
(xii) Qualified distribution . The term qualified
distribution means a distribution of money by an
ETSC during the ETSC period to which, absent ap-
plication of section 1371(f) and this section, section
301 would apply .
(b) Characterization of qualified distri-
bution—(1) In general . Paragraph (b)(2)
of this section provides rules regarding the
determination of the amount of a qualified
distribution that is sourced from AAA and
the corollary effects of such a character-
ization . Paragraph (b)(3) of this section
provides rules regarding the determination
of the amount of a qualified distribution
that is sourced from AE&P and the cor-
ollary effects of such a characterization .
Paragraph (b)(4) of this section provides
rules regarding the characterization of an
excess qualified distribution as a separate
qualified distribution. The rules in para-
graphs (b)(2) through (4) of this section
are applied before the application of para-
graph (c) of this section .
(2) Distribution of AAA—(i) Amount .
The portion of a qualified distribution that
is sourced from the ETSC’s AAA is equal
to the lesser of:
(A) The product of the qualified distri-
bution and the AAA ratio; and
(B) The ETSC’s AAA immediately be-
fore the qualified distribution.
(ii) Reduction or elimination of ETSC’s
AAA . The ETSC’s AAA is reduced by
the amount of the distribution described
in paragraph (b)(2)(i) of this section . If,
with respect to a qualified distribution, the
amount described in paragraph (b)(2)(i)
(A) of this section equals or exceeds the
amount described in paragraph (b)(2)(i)
(B) of this section, then the rules in this
paragraph (b) do not apply to any subse-
quent distributions by the ETSC . Instead,
the subsequent distributions are treated in
the manner provided in paragraph (c) of
this section .
(iii) Effect on the shareholder . The
amount described in paragraph (b)(2)(i) of
this section is applied against and reduc-
es the shareholder’s adjusted basis of the
shares of stock with respect to which the
distribution is made under the principles
of section 301(c)(2) . If the application of
the amount described in paragraph (b)(2)
(i) of this section would result in a reduc-
tion of basis that exceeds the shareholder’s
adjusted basis of any share of stock with
respect to which the distribution is made,
such excess is treated as gain from the
sale or exchange of property . The reduc-
tion of the shareholder’s basis described
in this paragraph (b)(2)(iii) with respect to
a qualified distribution occurs prior to the
application of paragraph (c) of this section
to the excess qualified distribution, if any,
with respect to such qualified distribution.
(3) Distribution of AE&P—(i) Amount .
This paragraph (b)(3) applies if the ET-
SC’s AE&P ratio is greater than zero . If
this paragraph (b)(3) applies, the portion
of a qualified distribution that is sourced

November 25, 2019 1228 Bulletin No. 2019–48
from the ETSC’s AE&P is equal to the
lesser of:
(A) The product of the qualified distri-
bution and the AE&P ratio; and
(B) The ETSC’s AE&P immediately
before the qualified distribution. For pur-
poses of the preceding sentence, if the ET-
SC’s AE&P immediately before the quali-
fied distribution is less than zero, then the
ETSC’s AE&P is treated as zero .
(ii) Effect on ETSC’s AE&P . The ET-
SC’s AE&P is reduced, as described in
section 312(a)(1), by the amount of the
distribution described in paragraph (b)(3)
(i) of this section . The AE&P reduction
described in this paragraph occurs prior
to the application of paragraph (c) of this
section, even if a distribution to which
paragraph (c) of this section applies (re-
garding excess qualified distributions and
non-qualified distributions) occurs earlier
in time than the qualified distribution to
which this paragraph (b)(3)(ii) applies .
(iii) Effect on the shareholder . The
amount of the qualified distribution that
is sourced from the ETSC’s AE&P de-
scribed in paragraph (b)(3)(i) of this sec-
tion is included in the gross income of the
shareholder as a dividend under section
301(c)(1) .
(iv) Adjustment to the AAA ratio and
the AE&P ratio . After the application of
paragraph (b)(3)(ii) of this section, if the
ETSC’s AE&P is zero and the ETSC’s
AAA is greater than zero, then the ETSC’s
AAA ratio is one and the ETSC’s AE&P
ratio is zero for all subsequent qualified
distributions during:
(A) That taxable year; and
(B) All subsequent taxable years of the
ETSC period .
(4) Excess qualified distribution treat-
ed as a separate qualified distribution—
(i) In general . After the application of
paragraph (b)(2)(ii) of this section with
respect to a qualified distribution, if the
ETSC has any remaining AAA, then any
amount of excess qualified distribution,
with respect to such qualified distribution,
is treated as a separate qualified distribu-
tion and is analyzed pursuant to paragraph
(b) of this section .
(ii) No change in characterization of
previously characterized portion of qual-
ified distribution . Paragraph (b)(4)(i) will
not change the characterization of any
portion of a qualified distribution that was
previously characterized pursuant to para-
graphs (b)(2) and (3) of this section and
will reflect the application of paragraphs
(b)(2) and (3) of this section to the portion
of the qualified distribution previously
characterized .
(c) Characterization of excess quali-
fied distribution and non-qualified distri-
butions . After application of paragraph (b)
of this section, the excess qualified distri-
butions, if any, and non-qualified distri-
butions, if any, are treated in the manner
provided in sections 301(c) and 316 .
(d) Examples. The following exam-
ples illustrate the rules of this section.
For purposes of the examples in this
paragraph (d), X is a calendar year S
corporation with a single share of stock
outstanding. A, an individual, purchased
its share of X stock prior to December
22, 2017 and, except as otherwise indi-
cated, never contributed any amounts to
X’s capital. A remained the sole share-
holder of X when X made a valid revo-
cation on March 15, 2018, pursuant to
section 1362(d)(1) and §1.1362-2 and
1.1362-6, of its S election and when that
election became effective on January 1,
2018. X qualified as an ETSC pursuant
to §1.481-5(b) and its ETSC period be-
gan on January 1, 2019. Additionally, X
did not make any distributions during its
post-termination transition period, with-
in the meaning of section 1377(b)(1)(A).
Furthermore, A remains the sole share-
holder of X at the time of the distribu-
tion(s) described.
(1) Example 1: Historical AE&P is zero—(i)
Facts . At the beginning of January 1, 2018, X had
AAA of $100 and AE&P of $0 . During 2018, X had
$300 of CE&P and made no distributions . At the be-
ginning of January 1, 2019, X has AAA of $100 and
AE&P of $300, and A’s adjusted basis in its share of
X stock is $460 . During 2019, the only distribution
that X makes is a $60 distribution of money to A on
December 27 . X’s CE&P during 2019 is $150, with-
out diminution by reason of any distributions made
during the taxable year .
(ii) Analysis—(A) Calculation of AAA ratio and
AE&P ratio . Pursuant to paragraphs (a)(2)(ix) and
(x) of this section, respectively, X’s historical AAA
and X’s historical AE&P are determined as of the be-
ginning of January 1, 2018, the beginning of the day
on which the revocation of X’s election under sec-
tion 1362(a) is effective pursuant to section 1362(d)
(1) . Accordingly, X’s historical AAA is $100 and X’s
historical AE&P is $0 . Therefore, X’s AAA ratio is 1
($100/($100 + $0)), and X’s AE&P ratio is zero ($0/
($100 + $0)) .
(B) Characterization of distribution . Pursuant to
paragraph (a)(2)(xii) of this section, the $60 distribu-
tion on December 27, 2019, is a qualified distribu-
tion because it is a distribution of money by an ETSC
during the ETSC period to which section 301 would
apply absent the application of section 1371(f) and
this section .
(C) Analysis of qualified distribution—(1) Dis-
tribution of AAA . Pursuant to paragraph (b)(2)(i) of
this section, the portion of the qualified distribution
that is sourced from AAA is equal to the lesser of:
the product of the qualified distribution and the AAA
ratio ($60 x 1, or $60), and X’s AAA immediately
before the qualified distribution ($100). Therefore,
$60 is sourced from AAA . Pursuant to paragraph (b)
(2)(ii) of this section, after the distribution, X’s AAA
is reduced by $60 to $40 . Pursuant to paragraph (b)
(2)(iii) of this section, A’s basis in its X stock is re-
duced by $60 to $400 .
(2) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, the portion of the distribu-
tion that is sourced from AE&P is equal to the lesser
of: the product of the qualified distribution and the
AE&P ratio ($60 x 0, or $0), and X’s AE&P immedi-
ately before the qualified distribution ($300). There-
fore, $0 is sourced from AE&P .
(2) Example 2: Qualified distributions with both
historical AAA and historical AE&P—(i) Facts . At
the beginning of January 1, 2018, X had AAA of
$200 and AE&P of $100 . During 2018, X had $0 of
CE&P and made no distributions . At the beginning
of January 1, 2019, X has AAA of $200 and AE&P
of $100, and A’s adjusted basis in its share of X stock
is $500 . During 2019, X makes a $90 distribution
of money on February 9 and a $150 distribution of
money on June 5 . X’s CE&P during 2019 is $500,
without diminution by reason of any distributions
made during the taxable year .
(ii) Analysis—(A) Calculation of AAA ratio and
AE&P ratio . Pursuant to paragraphs (a)(2)(ix) and
(x) of this section, respectively, X’s historical AAA
and X’s historical AE&P are determined as of the be-
ginning of January 1, 2018, the beginning of the day
on which the revocation of X’s election under sec-
tion 1362(a) is effective pursuant to section 1362(d)
(1) . Accordingly, X’s historical AAA is $200 and X’s
historical AE&P is $100 . Therefore, X’s AAA ratio
is 0 .67 ($200/($200 + $100)), and X’s AE&P ratio is
0 .33 ($100/($200 + $100)) .
(B) Characterization of distributions . Pursuant
to paragraph (a)(2)(xii) of this section, the $90 dis-
tribution on February 9, 2019, and the $150 distribu-
tion on June 5, 2019, are both qualified distributions
because they are distributions of money by an ETSC
during the ETSC period to which section 301 would
apply absent the application of section 1371(f) and
this section .
(C) Analysis of qualified distributions—(1) Feb-
ruary 9, 2019 distribution—(i) Distribution of AAA .
Pursuant to paragraph (b)(2)(i) of this section, the
portion of the qualified distribution that is sourced
from AAA is equal to the lesser of: the product of the
qualified distribution and the AAA ratio ($90 x 0.67,
or $60), and X’s AAA immediately before the qual-
ified distribution ($200). Therefore, $60 is sourced
from AAA . Pursuant to paragraph (b)(2)(ii) of this
section, after the distribution, X’s AAA is reduced
by $60 to $140 . Pursuant to paragraph (b)(2)(iii) of
this section, A’s basis in its X stock is reduced by
$60 to $440 .

Bulletin No. 2019–48 1229 November 25, 2019
(ii) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, the portion of the distribu-
tion that is sourced from AE&P is equal to the lesser
of: the product of the qualified distribution and the
AE&P ratio ($90 x 0 .33, or $30), and X’s AE&P im-
mediately before the qualified distribution ($100).
Therefore, $30 is sourced from AE&P . Pursuant to
paragraph (b)(3)(ii) of this section, after the distribu-
tion, X’s AE&P is reduced by $30 to $70 . Pursuant
to paragraph (b)(3)(iii) of this section, the $30 distri-
bution is characterized as a dividend .
(2) June 5, 2019 distribution—(i) Distribution
of AAA . Pursuant to paragraph (b)(2)(i) of this sec-
tion, the portion of the qualified distribution that is
sourced from AAA is equal to the lesser of: the prod-
uct of the qualified distribution and the AAA ratio
($150 x 0 .67, or $100), and X’s AAA immediately
before the qualified distribution ($140). Therefore,
$100 is sourced from AAA . Pursuant to paragraph
(b)(2)(ii) of this section, after the distribution, X’s
AAA is reduced by $100 to $40 . Pursuant to para-
graph (b)(2)(iii) of this section, A’s basis in its X
stock is reduced by $100 to $340 .
(ii) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, the portion of the distri-
bution that is sourced from AE&P is equal to the
lesser of: the product of the qualified distribution
and the AE&P ratio ($150 x 0 .33, or $50), and X’s
AE&P immediately before the qualified distribu-
tion ($70) . Therefore, $50 is sourced from AE&P .
Pursuant to paragraph (b)(3)(ii) of this section, af-
ter the distribution, X’s AE&P is reduced by $50 to
$20 . Pursuant to paragraph (b)(3)(iii) of this section,
the $50 distribution is characterized as a dividend .
(3) Example 3: Limitation on amount character-
ized as AAA—(i) Facts . At the beginning of January
1, 2018, X had AAA of $100 and AE&P of $300 .
During 2018, X had $280 of CE&P and made no
distributions . At the beginning of January 1, 2019,
X has AAA of $100 and AE&P of $580, and A’s ad-
justed basis in its share of X stock is $450 . During
2019, the only distribution that X makes is a $500
distribution of money to A on October 5 . X’s CE&P
during 2019 is $150, without diminution by reason
of any distributions made during the taxable year .
(ii) Analysis—(A) Calculation of AAA ratio and
AE&P ratio . Pursuant to paragraphs (a)(2)(ix) and
(x) of this section, respectively, X’s historical AAA
and X’s historical AE&P are determined as of the be-
ginning of January 1, 2018, the beginning of the day
on which the revocation of X’s election under sec-
tion 1362(a) is effective pursuant to section 1362(d)
(1) . Accordingly, X’s historical AAA is $100 and X’s
historical AE&P is $300 . Therefore, X’s AAA ratio
is 0 .25 ($100/($100 + $300)), and X’s AE&P ratio is
0 .75 ($300/($100 + $300)) .
(B) Characterization of distribution . Pursuant to
paragraph (a)(2)(xii) of this section, the $500 distri-
bution on October 5, 2019, is a qualified distribution
because it is a distribution of money by an ETSC
during the ETSC period to which section 301 would
apply absent the application of section 1371(f) and
this section .
(C) Analysis of qualified distribution—(1) Dis-
tribution of AAA . Pursuant to paragraph (b)(2)(i) of
this section, the portion of the qualified distribution
that is sourced from AAA is equal to the lesser of:
the product of the qualified distribution and the
AAA ratio ($500 x 0 .25, or $125), and X’s AAA
immediately before the qualified distribution ($100).
Therefore, $100 is sourced from AAA . Pursuant to
paragraph (b)(2)(ii) of this section, after the distribu-
tion, X’s AAA is reduced by $100 to $0 . Pursuant to
paragraph (b)(2)(iii) of this section, A’s basis in its X
stock is reduced by $100 to $350 .
(2) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, the portion of the distribu-
tion that is sourced from AE&P is equal to the lesser
of: the product of the qualified distribution and the
AE&P ratio ($500 x 0 .75, or $375), and X’s AE&P
immediately before the qualified distribution ($580).
Therefore, $375 is sourced from AE&P . Pursuant to
paragraph (b)(3)(ii) of this section, after the distribu-
tion, X’s AE&P is reduced by $375 to $205 . Pursuant
to paragraph (b)(3)(iii) of this section, the $375 dis-
tribution is characterized as a dividend .
(D) Effect of qualified distribution on ETSC peri-
od . Pursuant to paragraph (a)(2)(vii) of this section,
X’s ETSC period ends because X’s AAA balance is
zero following the October 5, 2019 distribution .
(E) Analysis of excess qualified distribution—(1)
Amount of excess qualified distribution . Pursuant to
paragraph (a)(2)(viii) of this section, the amount of
the excess qualified distribution is $25, the portion
of the qualified distribution ($500) not characterized
pursuant to paragraph (b)(2) or (3) of this section
($100 AAA distribution + $375 AE&P distribution) .
(2) Characterization of excess qualified distribu-
tion . Paragraph (b)(4) of this section does not apply
to the excess qualified distribution because X’s AAA
balance is zero after the application of paragraph (b)
(2)(ii) of this section (see paragraph (d)(3)(ii)(C)
(1) of this section) . Pursuant to paragraph (c) of this
section, section 301(c) applies to the excess qualified
distribution . Pursuant to sections 301(c)(1) and 316,
the $25 excess qualified distribution is sourced from
CE&P .
(iii) Subsequent contribution . The facts are the
same as paragraph (d)(3)(i) of this section, except
that at the time of the October 5, 2019 distribution,
A’s adjusted basis in its X stock is $90 . Further, on
December 27, 2019, A contributes $100 to X in a
transaction described in section 351(a) . The analy-
sis in paragraph (d)(3)(ii) of this section remains the
same, except that, unlike the second to last sentence
of paragraph (d)(3)(ii)(C)(1) of this section, A’s basis
in its X stock is reduced by $90 to $0 and pursuant
to paragraph (b)(2)(iii) of this section, $10 is treated
as gain from the sale or exchange of property . Addi-
tionally, as a result of the December 27, 2019 contri-
bution of $100, A’s basis in its X stock is increased
by $100, so that at the end of 2019, A’s basis in its X
stock is $100 .
(4) Example 4: Limitation on the amount char-
acterized as AE&P—(i) Facts . At the beginning of
January 1, 2018, X had AAA of $100 and AE&P of
$100 . During 2018, X had CE&P of $(75) and made
no distributions . At the beginning of January 1, 2019,
X has AAA of $100 and AE&P of $25, and A’s ad-
justed basis in its share of X stock is $500 . During
2019, the only distributions that X makes are a $100
distribution of money to A on July 9 and a $40 dis-
tribution of money to A on September 27 . X’s CE&P
during 2019 is $20, without diminution by reason of
any distributions made during the taxable year .
(ii) Analysis—(A) Calculation of AAA ratio and
AE&P ratio . Pursuant to paragraphs (a)(2)(ix) and
(x) of this section, respectively, X’s historical AAA
and X’s historical AE&P are determined as of the be-
ginning of January 1, 2018, the beginning of the day
on which the revocation of X’s election under sec-
tion 1362(a) is effective pursuant to section 1362(d)
(1) . Accordingly, X’s historical AAA is $100 and X’s
historical AE&P is $100 . Therefore, X’s AAA ratio is
0 .5 ($100/($100 + $100)), and X’s AE&P ratio is 0 .5
($100/($100 + $100)) .
(B) Analysis of July 9, 2019 distribution—(1)
Characterization of distribution . Pursuant to para-
graph (a)(2)(xii) of this section, the $100 distribution
on July 9, 2019, is a qualified distribution because
it is a distribution of money by an ETSC during the
ETSC period to which section 301 would apply ab-
sent the application of section 1371(f) and this sec-
tion .
(2) Analysis of qualified distribution—(i) Distri-
bution of AAA . Pursuant to paragraph (b)(2)(i) of this
section, the portion of the distribution that is sourced
from AAA is equal to the lesser of: the product of the
qualified distribution and the AAA ratio ($100 x 0.5,
or $50), and X’s AAA immediately before the qual-
ified distribution ($100). Therefore, $50 is sourced
from AAA . Pursuant to paragraph (b)(2)(ii) of this
section, after the distribution, X’s AAA is reduced
by $50 to $50 . Pursuant to paragraph (b)(2)(iii) of
this section, A’s basis in its X stock is reduced by
$50 to $450 .
(ii) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, the portion of the distribu-
tion that is sourced from AE&P is equal to the lesser
of: the product of the qualified distribution and the
AE&P ratio ($100 x 0 .5, or $50), and X’s AE&P
immediately before the qualified distribution ($25).
Therefore, $25 is sourced from AE&P . Pursuant to
paragraph (b)(3)(ii) of this section, after the distribu-
tion, X’s AE&P is reduced by $25 to $0 . Pursuant to
paragraph (b)(3)(iii) of this section, the $25 distribu-
tion is characterized as a dividend .
(3) Recalculation of AAA and AE&P ratios . Pur-
suant to paragraph (b)(3)(iv) of this section, because
the July 9, 2019 distribution caused X’s AE&P to be
reduced to zero, the AAA ratio is one and the AE&P
ratio is zero for all subsequent qualified distributions
during the 2019 taxable year and subsequent taxable
years of the ETSC period .
(4) Excess qualified distribution—(i) Amount of
excess qualified distribution . Pursuant to paragraph
(a)(2)(viii) of this section, the amount of the excess
qualified distribution is $25, the amount of the qual-
ified distribution ($100) not characterized pursuant
to paragraph (b)(2) or (3) of this section ($50 AAA
distribution + $25 AE&P distribution) .
(ii) Characterization of excess qualified distribu-
tion as a separate qualified distribution . Pursuant to
paragraph (b)(4) of this section, because X has AAA
remaining after characterizing the qualified distri-
bution (see paragraph (d)(4)(ii)(B)(2)(i) of this sec-
tion), the $25 excess qualified distribution is treated
as a separate qualified distribution and is analyzed
pursuant to paragraph (b) of this section .
(iii) Analysis of excess qualified distribution that
is treated as a separate qualified distribution . Pursu-
ant to paragraph (b)(2)(i) of this section, the portion
of the distribution that is sourced from AAA is equal

November 25, 2019 1230 Bulletin No. 2019–48
to the lesser of: the product of the excess qualified
distribution and the AAA ratio ($25 x 1, or $25), and
X’s AAA immediately before the excess qualified
distribution ($50) . Therefore, $25 is sourced from
AAA . Pursuant to paragraph (b)(2)(ii) of this sec-
tion, after the distribution, X’s AAA is reduced by
$25 to $25 . Pursuant to paragraph (b)(2)(iii) of this
section, A’s basis in its X stock is reduced by $25 to
$425 . Pursuant to paragraph (b)(3)(i) of this section,
because X’s AE&P ratio is zero, paragraph (b)(3) of
this section does not apply .
(C) Analysis of September 27, 2019 distribu-
tion—(1) Characterization of the distribution . Pur-
suant to paragraph (a)(2)(xii) of this section, the $40
distribution on September 27, 2019, is a qualified
distribution because it is a distribution of money by
an ETSC during the ETSC period to which section
301 would apply absent the application of section
1371(f) and this section .
(2) Analysis of qualified distribution—(i) Distri-
bution of AAA . Pursuant to paragraph (b)(2)(i) of this
section, the portion of the distribution that is sourced
from AAA is equal to the lesser of: the product of the
qualified distribution and the AAA ratio ($40 x 1, or
$40), and X’s AAA immediately before the qualified
distribution ($25) (see paragraph (d)(4)(ii)(B)(4)(iii)
of this section) . Therefore, $25 is sourced from AAA .
Pursuant to paragraph (b)(2)(ii) of this section, after
the distribution, X’s AAA is reduced by $25 to $0 .
Pursuant to paragraph (b)(2)(iii) of this section, A’s
basis in its X stock is reduced by $25 to $400 .
(ii) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, because X’s AE&P ratio is
zero, paragraph (b)(3) of this section does not apply .
(3) Excess qualified distribution—(i) Amount of
excess qualified distribution . Pursuant to paragraph
(a)(2)(viii) of this section, the amount of the excess
qualified distribution is $15, the portion of the qual-
ified distribution ($40) not characterized pursuant to
paragraph (b)(2) or (3) of this section ($25 AAA dis-
tribution + $0 AE&P distribution) .
(ii) Excess qualified distribution not character-
ized as a separate qualified distribution . Pursuant to
paragraph (b)(4) of this section, because X has AAA
of $0 after characterizing the qualified distribution
(see paragraph (d)(4)(ii)(C)(2)(i) of this of this sec-
tion), the $15 excess qualified distribution is not
treated as a separate qualified distribution.
(iii) Analysis of excess qualified distribution that
is not treated as a separate qualified distribution .
Pursuant to paragraph (c) of this section, section
301(c) applies to the excess qualified distribution.
Pursuant to sections 301(c)(1) and 316, the $15 ex-
cess qualified distribution is sourced from CE&P.
(5) Example 5: Distributions include non-qual-
ified distributions—(i) Facts . At the beginning of
January 1, 2018, X had AAA of $100 and AE&P of
$100 . During 2018, X had $0 of CE&P and made no
distributions . At the beginning of January 1, 2019, X
has AAA of $100 and AE&P of $100, and A’s adjusted
basis in its X stock is $200 . During 2019, X makes a
$100 distribution of money on June 14; a $300 distri-
bution of property on November 9; and a $200 distri-
bution of money on December 18 . X’s CE&P during
2019 is $160, without diminution by reason of any
distributions made during the taxable year .
(ii) Analysis—(A) Calculation of AAA ratio and
AE&P ratio
. Pursuant to paragraphs (a)(2)(ix) and
(x) of this section, respectively, X’s historical AAA
is $100 and X’s historical AE&P is $100 . Therefore,
X’s AAA ratio is 0 .5 ($100/($100 + $100)), and X’s
AE&P ratio is 0 .5 ($100/($100 + $100)) .
(B) Characterization of distributions . Pursuant
to paragraph (a)(2)(xii) of this section, the $100 dis-
tribution on June 14, 2019, and the $200 distribution
on December 18, 2019, are both qualified distribu-
tions because they are distributions of money by
an ETSC during the ETSC period to which section
301 would apply absent the application of section
1371(f) and this section . Pursuant to paragraph (a)(2)
(xi) of this section, the $300 distribution of property
on November 9, 2019, is non-qualified distribution.
Pursuant to paragraph (b)(1) of this section, the rules
of paragraphs (b)(2) through (4) of this section apply
to the qualified distributions before the rules of para-
graph (c) of this section apply to the non-qualified
distribution and any excess qualified distributions.
(C) Analysis of qualified distributions—(1) June
14, 2019 distribution—(i) Distribution of AAA . Pur-
suant to paragraph (b)(2)(i) of this section, the por-
tion of the distribution that is sourced from AAA is
equal to the lesser of: the product of the qualified
distribution and the AAA ratio ($100 x 0 .5, or $50),
and X’ s AAA immediately before the qualified distri-
bution ($100) . Therefore, $50 is sourced from AAA .
Pursuant to paragraph (b)(2)(ii) of this section, after
the distribution, X’s AAA is reduced by $50 to $50 .
Pursuant to paragraph (b)(2)(iii) of this section, on
June 14, 2019, A’s basis in its X stock is reduced by
$50 to $150 .
(ii) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, the portion of the distribu-
tion that is sourced from AE&P is equal to the lesser
of: the product of the qualified distribution and the
AE&P ratio ($100 x 0 .5, or $50), and X’s AE&P im-
mediately before the qualified distribution ($100).
Therefore, $50 is sourced from AE&P . Pursuant to
paragraph (b)(3)(ii) of this section, after the distribu-
tion, X’s AE&P is reduced by $50 to $50 . Pursuant
to paragraph (b)(3)(iii) of this section, the $50 distri-
bution is characterized as a dividend .
(iii) Amount of excess qualified distribution . The
amount of the excess qualified distribution is $0, the
amount of the qualified distribution ($100) not char-
acterized pursuant to paragraph (b)(2) or (3) of this
section ($50 AAA distribution + $50 AE&P distri-
bution) .
(2) December 18, 2019 distribution—(i) Distri-
bution of AAA . Pursuant to paragraph (b)(2)(i) of this
section, the portion of the distribution that is sourced
from AAA is equal to the lesser of: the product of the
qualified distribution and the AAA ratio ($200 x 0.5,
or $100), and X’s AAA immediately before the qual-
ified distribution ($50). Therefore, $50 is sourced
from AAA . Pursuant to paragraph (b)(2)(ii) of this
section, after the distribution, X’s AAA is reduced
by $50 to $0 . Pursuant to paragraph (b)(2)(iii) of this
section, A must determine its basis as of December
18, 2019, in order to determine the consequences
of receiving the $50 AAA distribution . Because the
non-qualified distribution on November 9, 2019,
which precedes the December 18, 2019 qualified
distribution, could have the effect of reducing A’s
basis, any effect on A’s basis from that non-qualified
distribution must be analyzed prior to determining
the effect of the December 18, 2019 distribution of
AAA on A’s basis . See paragraphs (d)(5)(ii)(D)(3)
and (4) of this section . Pursuant to paragraph (a)(2)
(vii) of this section, X’s ETSC period ends because
X’s AAA balance is zero following the December 18,
2019 distribution .
(ii) Distribution of AE&P . Pursuant to paragraph
(b)(3)(i) of this section, the portion of the distribu-
tion that is sourced from AE&P is equal to the lesser
of: the product of the qualified distribution and the
AE&P ratio ($200 x 0 .5, or $100), and X’s AE&P
immediately before the qualified distribution ($50).
Therefore, $50 is sourced from AE&P . Pursuant to
paragraph (b)(3)(ii) of this section, after the distribu-
tion, X’s AE&P is reduced by $50 to $0 . Pursuant to
paragraph (b)(3)(iii) of this section, the $50 distribu-
tion is characterized as a dividend .
(iii) Amount of excess qualified distribution . The
amount of the excess qualified distribution is $100,
the amount of the qualified distribution ($200) not
characterized pursuant to paragraph (b)(2) or (3) of
this section ($50 AAA distribution + $50 AE&P dis-
tribution) .
(D) Analysis of non-qualified and excess qualified
distributions—(1) In general . The $300 non-quali-
fied distribution on November 9, 2019, and the $100
excess qualified distribution on December 18, 2019,
are treated in the manner provided in section 301(c) .
(2) Allocation of CE&P . Pursuant to section 316
and §1 .316-2, X’s CE&P is allocated proportionate-
ly among the excess qualified and the non-qualified
distributions . Therefore, the portion of X’s CE&P
that is allocated to the November 9, 2019 distribu-
tion and the December 18, 2019 distribution is $120
($160 X’s CE&P x ($300 distribution / $400 total ex-
cess qualified and non-qualified distributions during
2019) and $40 ($160 X’s CE&P x ($100 distribution
/ $400 total excess qualified and non-qualified distri-
butions during 2019), respectively .
(3) November 9, 2019 distribution . Pursuant to
paragraph (d)(5)(ii)(D)(2) of this section, $120 of
the $300 distribution is characterized as a distribu-
tion of CE&P . Pursuant to paragraph (d)(5)(ii)(C)(2)
(ii) of this section, the amount of X’s AE&P avail-
able to allocate the November 9, 2019 distribution
is $0 . Therefore the remaining $180 is characterized
pursuant to section 301(c)(2) and (3) . Pursuant to
paragraph (d)(5)(ii)(C)(1)(i) of this section, A’s basis
in its X stock prior to the November 9, 2019 distribu-
tion is $150 . Therefore, $150 is applied against basis
pursuant to section 301(c)(2) (reducing A’s basis to
$0) and $30 is treated as gain from the sale or ex-
change of property pursuant to section 301(c)(3) .
(4) December 18, 2019 distribution—(i) Con-
sequences of AAA distribution . As of December 18,
2019, A’s basis in its X stock is $0 . See paragraph
(d)(5)(ii)(D)(3) of this section. Pursuant to paragraph
(d)(5)(ii)(C)(2)(i) of this section, $50 of the distribu-
tion is characterized as a distribution of AAA . Be-
cause the amount of the distribution of AAA ($50)
exceeds A’s basis in its X stock ($0), pursuant to
paragraph (b)(2)(iii) of this section, on December
18, 2019, $50 is treated as gain from the sale or ex-
change of property .
(ii) Characterization of excess qualified distri-
bution . Pursuant to paragraph (d)(5)(ii)(C)(2)(iii) of
this section, $100 of the December 18, 2019 distri-
bution is an excess qualified distribution. Paragraph
(b)(4) of this section does not apply to the excess
qualified distribution because X’s AAA balance is
zero after the application of paragraph (b)(2)(ii) of
this section (see paragraph (d)(5)(ii)(C)(2)(i) of this

Bulletin No. 2019–48 1231 November 25, 2019
section) . Pursuant to paragraph (c) of this section,
section 301(c) applies to the excess qualified distri-
bution . Pursuant to paragraph (d)(5)(ii)(D)(2) of this
section, $40 of the $100 excess qualified distribution
is characterized as a distribution of CE&P . Pursu-
ant to paragraph (d)(5)(ii)(D)(3) of this section, X’s
AE&P as the time of the December 18, 2019 distri-
bution is $0 . Therefore the remaining $60 is char-
acterized pursuant to section 301(c)(2) and (3) . Pur-
suant to paragraph (d)(5)(ii)(D)(4)(i) of this section,
A’s basis in its X stock prior to characterization of the
excess qualified distribution is $0. Therefore, $60 is
treated as gain from the sale or exchange of property
pursuant to section 301(c)(3) .
(e) Applicability date. This section
generally applies to taxable years begin-
ning after [DATE OF PUBLICATION
OF THE FINAL RULES IN THE FED-
ERAL REGISTER]. However, corpo-
rations may choose to apply the rules in
§§1.316-2, 1.481-5, 1.1371-1, 1.1371-2,
and 1.1377-2 in their entirety, to the extent
applicable, to taxable years that began on
or before [DATE OF PUBLICATION OF
THE FINAL RULES IN THE FEDERAL
REGISTER] and with respect to which
the period described in section 6511(a)
has not expired. If the corporation makes
the choice described in the previous sen-
tence, all shareholders of the corporation
must report consistently.
§1.1371-2 Impact of Audit PTTP on
ETSC Period .
(a) Definitions. For purposes of this sec-
tion, the definitions used in §1.1371-1(a)
(2) are applicable. Additionally, the fol-
lowing definitions apply for purposes of
this section—
(1) Audit PTTP . The term audit PTTP
means a post-termination transition period
described in section 1377(b)(1)(B) .
(2) Initial PTTP . The term initial PTTP
means a post-termination transition period
described in section 1377(b)(1)(A) .
(3) Intervening audit PTTP . The term
intervening audit PTTP means an audit
PTTP arising during the ETSC period .
(b) In general. If an intervening au-
dit PTTP arises, the ETSC period shall
immediately stop. Immediately following
the end of the intervening audit PTTP, the
ETSC period will resume if the ETSC’s
AAA balance is greater than zero. Other-
wise, any subsequent distributions by the
ETSC are treated in the manner provided
in section 301(c).
(c) Examples. The following examples
illustrate the rules of this section. For pur-
poses of the examples in this paragraph
(c), X is a calendar year S corporation.
A, an individual, purchased all of the
outstanding shares of X in a single trans-
action at the same price per share prior
to December 22, 2017, and was the sole
shareholder of X at all times. Pursuant to
section 1362(d)(1) and §§1.1362-2 and
1.1362-6, X made a valid revocation of its
S election on March 15, 2019, that became
effective on January 1, 2019. No amount
distributed by X is an extraordinary divi-
dend within the meaning of section 1059.
(1) Example 1: No ETSC period following ini-
tial PTTP—(i) Facts . At the beginning of January 1,
2019, X had AAA of $49,000 and AE&P of $2,000,
and A’s adjusted basis in its shares of X stock was
$50,000 . During 2019, the only distribution that X
made was a $49,000 distribution of money to A on
March 13, 2019 . X’s CE&P during 2019 was $0,
without regard to any diminution by reason of any
distributions made during the taxable year .
(ii) Analysis—(A) Distribution during initial
PTTP . Pursuant to sections 1371(e) and 1377(b)(1)
(A), the $49,000 distribution of money on March 13,
2019, is characterized as a distribution of AAA be-
cause it was made during the initial PTTP .
(B) Effect on corporation . Pursuant to §1 .1368-
2(a)(3)(iii), X’s AAA is reduced by $49,000 to $0 .
Following the initial PTTP, even if X satisfies the
requirements of section 481(d)(2) and §1 .481-5(b) to
be an ETSC, X does not have an ETSC period be-
cause its AAA balance is zero at the end of its initial
PTTP . Therefore, section 1371(f) and §1 .1371-1 will
not apply to any subsequent distributions by X .
(C) Effect on shareholder . Pursuant to section
1371(e)(1), A reduces its basis in its X stock by
$49,000 to $1,000 .
(2) Example 2: Intervening audit PTTP—(i)
Facts . The facts are the same as the facts in para-
graph (c)(1) of this section . On May 20, 2020, which
is after X’s initial PTTP, the IRS begins an audit of
X’s 2018 return . During the audit it is agreed that
X overstated its advertising expense deduction by
$10,000 . On July 6, 2020, A signs a closing agree-
ment whereby X’s overstatement results in an addi-
tional tax on A’s 2018 individual return . As a result,
at the beginning of January 1, 2019, X had AAA of
$59,000 ($49,000 + $10,000) and AE&P of $2,000 .
Additionally, at the beginning of January 1, 2019, A’s
adjusted basis in its shares of X stock was $60,000
($50,000 + $10,000) . During 2020, the only distribu-
tion X makes is a $6,000 distribution of money to A
on September 1, 2020 . X’s CE&P during 2020 was
$0, without regard to any diminution by reason of
any distributions made during the taxable year .
(ii) Analysis—(A) Analysis of March 15, 2019
distribution . The treatment of the March 15, 2019,
distribution is the same as described in paragraph (c)
(1)(ii)(A) of this section, because the amount of the
distribution ($49,000) does not exceed X’s AAA bal-
ance at the beginning of January 1, 2019 ($59,000),
and so the entirety of the $49,000 distribution is
properly characterized as a distribution of AAA .
(1) Effect on corporation . As described in paragraph
(c)(1)(ii)(B) of this section, X’s AAA ($59,000 at the
beginning of January 1, 2019) is reduced by $49,000 to
$10,000 . At the conclusion of X’s initial PTTP (ending
on December 31, 2019), X’s AAA balance is $10,000 .
Pursuant to §1 .1371-1(a)(2)(vii), X has an ETSC peri-
od . Therefore, section 1371(f) and §1 .1371-1 will apply
to any subsequent qualified distributions by X.
(2) Effect on shareholder . As described in para-
graph (c)(1)(ii)(C) of this section, A reduces its basis
in its X stock ($60,000 at the beginning of January 1,
2019) by $49,000 to $11,000 .
(B) Intervening audit PTTP . Pursuant to section
1377(b)(1)(B), X enters an intervening audit PTTP
that begins on July 6, 2020, and ends on November
2, 2020 . The application of section 1371(f) and the
regulatory provisions in this part under section 1371
of the Code to distributions during the intervening
audit PTTP is stopped . Instead, sections 1371(e) and
1377(b)(1)(B), and the regulatory provisions in this
part under sections 1371 and 1377 of the Code, ap-
ply for the duration of the intervening audit PTTP .
During the intervening audit PTTP, the only distribu-
tion X made is a $6,000 distribution of money to A
on September 1, 2020 . Pursuant to sections 1371(e)
and 1377(b)(1)(B), the $6,000 distribution is charac-
terized as a distribution of AAA because it was made
during the intervening audit PTTP .
(1) Effect on corporation . Pursuant to §1 .1368-
2(a)(3)(iii), X’s AAA is reduced by $6,000 to
$4,000 . Beginning on November 3, 2020, pursuant
to §1 .1371-1(a)(2)(vii), X’s ETSC period resumes
(after the intervening audit PTTP’s conclusion) be-
cause its AAA balance is greater than zero .
(2) Effect on shareholder . Pursuant to section
1371(e)(1), A reduces its basis in its X stock by
$6,000 to $5,000 .
(C) ETSC period . Beginning on November 3,
2020, X’s ETSC period resumes, and distributions of
money are subject to section 1371(f) and the regula-
tory provisions in this part under section 1371 of the
Code until X’s AAA balance is zero . For purposes of
calculating each of X’s AAA and AE&P ratios, X’s
historical AAA is $59,000 (at the beginning of Janu-
ary 1, 2019, which includes the $10,000 increase as a
result of the July 6, 2020, closing agreement) .
(d) Applicability date. This section
generally applies to taxable years begin-
ning after [DATE OF PUBLICATION
OF THE FINAL RULES IN THE FED-
ERAL REGISTER]. However, corpo-
rations may choose to apply the rules in
§§1.316-2, 1.481-5, 1.1371-1, 1.1371-2,
and 1.1377-2 in their entirety, to the extent
applicable, to taxable years that began on
or before [DATE OF PUBLICATION OF
THE FINAL RULES IN THE FEDERAL
REGISTER] and with respect to which
the period described in section 6511(a)
has not expired. If the corporation makes
the choice described in the previous sen-
tence, all shareholders of the corporation
must report consistently.
§1 .1377-2 [Amended]
Par . 7 . Section 1 .1377-2 is amended by
removing the last sentence of paragraph
(b) .

November 25, 2019 1232 Bulletin No. 2019–48
Par . 8 . Section 1 .1377-3 is amended by:
a . Removing “and 1 .1377-2 apply” and
adding “applies” in its place; and
b . Adding three sentences at the end of
the paragraph .
The addition reads as follows:
§1.1377-3 Effective dates .
* * * Section 1 .1377-2 generally ap-
plies to taxable years beginning after
[DATE OF PUBLICATION OF THE FI-
NAL RULES IN THE FEDERAL REG-
ISTER], however, corporations may
choose to apply the rules in §§1 .316-2,
1 .481-5, 1 .1371-1, 1 .1371-2, and 1 .1377-
2 in their entirety, to the extent appli-
cable, to taxable years that began on or
before [DATE OF PUBLICATION OF
THE FINAL RULES IN THE FEDER-
AL REGISTER] and with respect to
which the period described in section
6511(a) has not expired . If the corpora-
tion makes the choice described in the
previous sentence, all shareholders of
the corporation must report consistently .
For taxable years beginning on or before
[DATE OF PUBLICATION OF THE FI-
NAL RULES IN THE FEDERAL REG-
ISTER], see §1 .1377-2(b) as contained
in 26 CFR part 1, revised April 1, 2019 .
Sunita Lough,
Deputy Commissioner for Services
and Enforcement .
(Filed by the Office of the Federal Register on No-
vember 4, 2019, 4:15 p .m ., and published in the is-
sue of the Federal Register for November 7, 2019,
84 F .R . 60011)
Notice of Proposed
Rulemaking
Updated Life Expectancy
and Distribution Period
Tables Used for Purposes
of Determining Minimum
Required Distributions.
REG-132210-18
AGENCY: Internal Revenue Service
(IRS), Treasury .
ACTION: Notice of proposed rulemak-
ing; notice of public hearing .
SUMMARY: This document sets forth
proposed regulations providing guidance
relating to the life expectancy and distri-
bution period tables that are used to calcu-
late required minimum distributions from
qualified retirement plans, individual re-
tirement accounts and annuities, and cer-
tain other tax-favored employer-provided
retirement arrangements . These regula-
tions affect participants, beneficiaries, and
plan administrators of these qualified re-
tirement plans and other tax-favored em-
ployer-provided retirement arrangements,
as well as owners, beneficiaries, trustees
and custodians of individual retirement
accounts and annuities . This document
also provides a notice of a public hearing
on these proposed regulations .
DATES: Written or electronic comments
must be received by January 7, 2020 . Out-
lines of topics to be discussed at the public
hearing scheduled for January 23, 2020,
must be received by January 7, 2020 .
ADDRESSES: Submit electronic sub-
missions via the Federal eRulemaking
Portal at www .regulations .gov (indicate
IRS and REG–132210–18) by follow-
ing the online instructions for submitting
comments . Once submitted to the Federal
eRulemaking Portal, comments cannot be
edited or withdrawn . The Department of
the Treasury (Treasury Department) and
the IRS will publish for public availability
any comment received to its public dock-
et, whether submitted electronically or in
hard copy . Send hard copy submissions
to: CC:PA:LPD:PR (REG-132210-18),
Room 5203, Internal Revenue Service,
P .O . Box 7604, Ben Franklin Station,
Washington, DC 20044 . Submissions may
be hand-delivered Monday through Friday
between the hours of 8 a .m . and 4 p .m . to
CC:PA:LPD:PR (REG-132210-18), Cou-
rier’s Desk, Internal Revenue Service,
1111 Constitution Avenue NW, Washing-
ton, DC 20224 .
FOR FURTHER INFORMATION CON-
TACT: Concerning the proposed reg-
ulations, Arslan Malik or Linda S . F .
Marshall, (202) 317-6700; concerning
submissions of comments and requests to
speak at the public hearing, Regina John-
son, (202) 317-6901 (not toll-free num-
bers) .
SUPPLEMENTARY INFORMATION
Background
This document includes proposed
amendments to the Income Tax Regula-
tions (26 CFR part 1) under section 401(a)
(9) of the Internal Revenue Code (Code)
regarding the requirement to take required
minimum distributions from qualified
trusts . These proposed regulations also
apply with respect to the corresponding
requirements for individual retirement ac-
counts and annuities described in section
408(a) and (b), and eligible deferred com-
pensation plans under section 457, as well
as section 403(a) and 403(b) annuity con-
tracts, custodial accounts, and retirement
income accounts .
Section 401(a)(9) provides rules re-
garding minimum required distributions
from qualified retirement plans. The pur-
pose of section 401(a)(9) is to ensure
that the favorable tax treatment afforded
a qualified plan is used primarily to pro-
vide retirement income to a participant
and a designated beneficiary, rather than
to increase the estate of a participant . Ac-
cordingly, section 401(a)(9) provides that
a qualified plan must commence benefits
to an employee no later than a specified
age (or within a specified number of years
after the employee’s death) and, under
the regulations, once benefits commence,
the pattern of payment must meet certain
standards to ensure that distributions are
not unduly deferred .
Section 401(a)(9)(A) provides rules
for distributions during the life of the em-
ployee . Section 401(a)(9)(A)(ii) provides
that the entire interest of an employee in
a qualified plan must be distributed, be-
ginning not later than the employee’s re-
quired beginning date, in accordance with
regulations, over the life of the employee
or over the lives of the employee and a
designated beneficiary (or over a period
not extending beyond the life expectancy
of the employee and a designated benefi-
ciary) .
Section 401(a)(9)(B) provides rules for
distributions that are made after the death
of the employee . Section 401(a)(9)(B)(i)

Bulletin No. 2019–48 1233 November 25, 2019
provides that, if the employee dies after
distributions have begun, the employee’s
interest must be distributed at least as rap-
idly as under the method used by the em-
ployee . Section 401(a)(9)(B)(ii) and (iii)
provide that, if the employee dies before
distributions have begun, the employee’s
interest must be either (1) Distributed (in
accordance with regulations) over the life
or life expectancy of the designated ben-
eficiary with the distributions beginning
no later than 1 year after the date of the
employee’s death, or (2) distributed with-
in 5 years after the death of the employee .
However, under section 401(a)(9)(B)(iv),
a surviving spouse may wait until the date
the employee would have attained age
70½ to begin receiving required minimum
distributions .
Section 401(a)(9)(C) defines the term
required beginning date for employees
(other than 5-percent owners and IRA
owners) as April 1 of the calendar year
following the later of the calendar year in
which the employee attains age 70½ or the
calendar year in which the employee re-
tires . For 5-percent owners and IRA own-
ers, the required beginning date is April 1
of the calendar year following the calen-
dar year in which the employee attains age
70½, even if the employee has not retired .
Section 401(a)(9)(D) provides that, ex-
cept in the case of a life annuity, the life
expectancy of an employee and the em-
ployee’s spouse that is used to determine
the period over which payments must be
made may be re-determined, but not more
frequently than annually .
Section 401(a)(9)(E) provides that the
term designated beneficiary means any
individual designated as a beneficiary by
the employee .
Section 401(a)(9)(G) provides that any
distribution required to satisfy the inci-
dental death benefit requirement of sec-
tion 401(a)
1
is a required minimum distri-
bution .
Under sections 403(b)(10), 408(a)(6),
2

and 457(d)(2), requirements similar to the
requirements of section 401(a)(9) apply to
a number of types of retirement arrange-
ments other than qualified plans. Pursuant
to sections 403(a)(1) and 404(a)(2), qual-
ified annuity plans must also comply with
the requirements of section 401(a)(9) .
Comprehensive rules regarding the ap-
plication of section 401(a)(9) are set forth
in §§1 .401(a)(9)-1 through 8 . In the case
of a defined contribution plan, §1.401(a)
(9)-5 provides generally that an individu-
al’s required minimum distribution for a
distribution calendar year is determined
by dividing the individual’s account bal-
ance determined under §1 .401(a)(9)-5,
Q&A-3, by the applicable distribution
period . Under §1 .401(a)(9)-5, Q&A-1(b),
a distribution calendar year is a calendar
year for which a minimum distribution
is required . For example, if a 5-percent
owner participating in a qualified plan
attained age 70½ during August of 2018
(so that the required beginning date was
April 1, 2019), then the first distribution
calendar year was 2018, and the required
minimum distribution for that year was
based on the applicable distribution peri-
od for a 70-year-old individual for 2018
(even though it could have been paid at
any time from January 1, 2018 through
April 1, 2019) .
Pursuant to §1 .401(a)(9)-5, Q&A-
4(a), for required minimum distributions
during the employee’s lifetime (including
the year in which the employee dies), the
applicable distribution period for an em-
ployee is the distribution period for the
employee’s age under the Uniform Life-
time Table (which is equal to the joint
and last survivor life expectancy for the
employee and a hypothetical beneficiary
10 years younger) . However, pursuant to
§1 .401(a)(9)-5, Q&A-4(b), if an employ-
ee’s sole beneficiary is the employee’s
surviving spouse and the spouse is more
than 10 years younger than the employee,
then the applicable distribution period is
the joint and last survivor life expectan-
cy of the employee and spouse under the
Joint and Last Survivor Table (which is
longer than the distribution period that
would apply for the employee under the
Uniform Lifetime Table) .
Pursuant to §1 .401(a)(9)-5, Q&A-5,
for distribution calendar years after the
calendar year of the employee’s death, the
applicable distribution period generally is
the remaining life expectancy of the desig-
nated beneficiary, subject to certain excep-
tions . Two of these exceptions, which ap-
ply if the employee dies after the required
beginning date, substitute the employee’s
remaining life expectancy for the benefi-
ciary’s remaining life expectancy . These
two exceptions apply to an employee who
does not have a designated beneficiary
or is younger than the designated benefi-
ciary .
3
Section 1 .401(a)(9)-5, Q&A-5(c)
(1) provides that the remaining life ex-
pectancy of the designated beneficiary is
calculated as the life expectancy under the
Single Life Table for the designated bene-
ficiary’s age in the calendar year following
the calendar year of the employee’s death,
reduced by 1 for each subsequent year .
However, if one of the two exceptions
applies (so that the relevant life expectan-
cy is the remaining life expectancy of the
employee), then, pursuant to §1 .401(a)
(9)-5, Q&A-5(c)(3), the remaining life ex-
pectancy of the employee is calculated as
the life expectancy under the Single Life
Table for the employee’s age in the calen-
dar year of the employee’s death, reduced
by 1 for each subsequent year .
A special rule applies to determine the
designated beneficiary’s remaining life
expectancy if the employee’s surviving
spouse is the employee’s sole beneficiary.
In that case, pursuant to §1 .401(a)(9)-5,
Q&A-5(c)(2), the designated beneficia-
ry’s remaining life expectancy is recalcu-
lated each calendar year as the life expec-
tancy under the Single Life Table for the
designated beneficiary’s age in that year.
For calendar years after the year of the
spouse’s death, the distribution period that
applies for the spouse’s beneficiary is the
spouse’s remaining life expectancy from
the Single Life Table for the spouse’s age
for the calendar year of the spouse’s death,
reduced by 1 for each subsequent year .
Consistent with the policy of section
401(a)(9) to limit deferral of retirement
1
The incidental death benefit requirement, which is set forth in §1.401-1(b)(1), provides that although a qualified pension or profit-sharing plan may provide for incidental death (or life
insurance) benefits, such a plan must be established and maintained primarily for the purpose of providing retirement benefits or deferred compensation.
2
However, pursuant to section 408A(a) and (c)(5), the minimum required distribution rules of section 401(a)(9) apply to a Roth IRA only after the death of the IRA owner .
3
Another exception applies if the employee dies before the required beginning date and has no designated beneficiary. In that case, the employee’s entire interest must be distributed by the
end of the calendar year that includes the fifth anniversary of the date of the employee’s death.

November 25, 2019 1234 Bulletin No. 2019–48
income, §1 .401(a)(9)-6, Q&A-1(a) pro-
vides that, except as otherwise provided in
§1.401(a)(9)-6, payments from a defined
benefit plan must be non-increasing in
order to satisfy section 401(a)(9) .
4
Sec-
tion 1 .401(a)(9)-6, Q&A-14(c) provides
that, in the case of annuity payments paid
from an annuity contract purchased from
an insurance company, certain types of
increasing payments will not cause an
annuity payment stream to fail to satisfy
this non-increasing payment requirement .
These exceptions apply only if the total
future expected payments under the an-
nuity contract (determined in accordance
with §1 .401(a)(9)-6, Q&A-14(e)(3)) ex-
ceed the total value being annuitized (de-
termined in accordance with §1 .401(a)(9)-
6, Q&A-14(e)(1)) .
Section 1 .401(a)(9)-9 provides life
expectancy and distribution period ta-
bles that are used to apply the rules of
§1 .401(a)(9)-5 and to make the calcula-
tions in §1 .401(a)(9)-6, Q&A-14 . Section
1 .401(a)(9)-9 was issued in 2002 (67 FR
18988), and the tables in that section were
developed using mortality rates for 2003 .
These mortality rates were derived by
applying mortality improvement through
2003 to the mortality rates from the Annu-
ity 2000 Basic Table (which was the most
recent individual annuity mortality table
available in 2002) .
5
The rates of mortality
improvement used for this purpose were
the ones that were used in developing that
mortality table . The resulting separate
mortality rates for males and females were
blended using a fixed 50 percent male/50
percent female blend .
Section 72(t) imposes an additional
income tax on early distributions from
qualified retirement plans (including plans
qualified under section 401(a) or sec-
tion 403(a), annuity contracts and other
arrangements described in section 403(b),
and individual retirement arrangements
described in section 408(a) or section
408(b)) . However, section 72(t)(2)(A)
(iv) provides an exception for a series of
substantially equal periodic payments
made for the life (or life expectancy) of
the employee or the joint lives (or joint
life expectancies) of the employee and
the designated beneficiary. Revenue Rul-
ing 2002-62, 2002-2 C .B . 710, provides
that the life expectancy tables set forth in
§1 .401(a)(9)-9 may be used for purposes
of determining payments that satisfy the
exception under section 72(t)(2)(A)(iv) .
Rev. Rul. 2002-62 also provides a fixed
annuitization method of determining pay-
ments that satisfy this exception . Under
the fixed annuitization method, the annual
payment for each year (which is deter-
mined only for the first year and not reset
for subsequent years) is determined by di-
viding the account balance by an annuity
factor that is the present value of an annu-
ity of $1 per year beginning at the taxpay-
er’s age and continuing for the life of the
taxpayer (or the joint lives of the taxpayer
and his or her beneficiary). The annuity
factor is derived using the mortality table
used to develop the life expectancy tables
set forth in §1 .401(a)(9)-9 .
Executive Order 13847, 83 FR 45321,
which was signed on August 31, 2018, di-
rects the Secretary of the Treasury to ex-
amine the life expectancy and distribution
period tables in the regulations on required
minimum distributions from retirement
plans and determine whether they should
be updated to reflect current mortality data
and whether such updates should be made
annually or on another periodic basis . The
purpose of any such updates would be to
increase the effectiveness of tax-favored
retirement programs by allowing retirees
to retain sufficient retirement savings in
these programs for their later years .
Explanation of Provisions
I . Overview
In accordance with Executive Order
13847, the Department of the Treasury
(Treasury Department) and the IRS have
examined the life expectancy and distri-
bution period tables in §1 .401(a)(9)-9,
and have reviewed currently available
mortality data . As a result of this review,
the Treasury Department and the IRS have
determined that those tables should be up-
dated to reflect current life expectancies.
Accordingly, these proposed regulations
would update those tables .
The life expectancy tables and appli-
cable distribution period tables in the pro-
posed regulations reflect longer life ex-
pectancies than the tables in the existing
regulations . For example, a 70-year old
IRA owner who uses the Uniform Life-
time Table to calculate required minimum
distributions must use a life expectancy
of 27 .4 years under the existing regula-
tions . Using the Uniform Lifetime Table
set forth in the proposed regulations, this
IRA owner would use a life expectancy of
29 .1 years to calculate required minimum
distributions . As another example, under
the existing regulations, a 75-year old sur-
viving spouse who is the employee’s sole
beneficiary and uses the Single Life Table
to compute required minimum distribu-
tions must use a life expectancy of 13 .4
years . Under the proposed regulations,
the spouse would use a life expectancy of
14 .8 years . The effect of these changes is
to reduce required minimum distributions,
which will allow participants to retain
larger amounts in their retirement plans to
account for the possibility they may live
longer .
II . Updated Life Expectancy and
Distribution Period Tables
The life expectancy and distribution
period tables in the proposed regulations
have been developed based on mortality
rates for 2021 . These mortality rates were
derived by applying mortality improve-
ment through 2021 to the mortality rates
from the experience tables used to devel-
op the 2012 Individual Annuity Mortality
tables (which are the most recent individ-
ual annuity mortality tables) .
6
The sepa-
rate mortality rates for males and females
in these experience tables, which were
based on the Payout Annuity Mortality
Experience Study (which covered the pe-
riod 2000 to 2004), have been projected
from the central year of 2002 using the
respective mortality improvement rates
from the Mortality Improvement Scale
4
Pursuant to §1.401(a)(9)-8, Q&A-2(a)(3), the rules of §1.401(a)(9)-6 also apply to an annuity contract purchased under a defined contribution plan.
5
The Annuity 2000 Basic Table was developed by projecting mortality rates from the 1983 Individual Annuity Mortality Basic Table .
6
The experience tables and the 2012 Individual Annuity Mortality tables can be found at https://www.actuary.org/sites/default/files/files/publications/Payout_Annuity_Report_09-28-11.pdf.

Bulletin No. 2019–48 1235 November 25, 2019
MP-2018 for males and females .
7
The
mortality table in the proposed regulations
was developed by blending the resulting
separate mortality rates for males and fe-
males using a fixed 50 percent male/50
percent female blend .
The Single Life Table in the proposed
regulations sets forth life expectancies for
each age, with the life expectancy for an
age calculated as the sum of the probabil-
ities of an individual at that age surviving
to each future year . The resulting life ex-
pectancy is then increased by 11/24
8
to ap-
proximate the effect of monthly payments,
and is subject to a floor of 1.0.
The Uniform Lifetime Table in the pro-
posed regulations sets forth joint and last
survivor life expectancies for each age
beginning with age 70, based on a hypo-
thetical beneficiary. Pursuant to §1.401(a)
(9)-5, Q&A-4(a), the Uniform Lifetime
Table is used for determining the distribu-
tion period for lifetime distributions to an
employee in situations in which the em-
ployee’s surviving spouse either is not the
sole designated beneficiary or is the sole
designated beneficiary but is not more
than 10 years younger than the employ-
ee . As under the existing regulations, the
joint and last survivor life expectancy of
an employee is taken from the Joint and
Last Survivor Table using a hypothetical
beneficiary who is assumed to be 10 years
younger than the employee .
The Joint and Last Survivor Table sets
forth joint and last survivor life expectan-
cies of an employee and the employee’s
beneficiary for each combination of ages
of those individuals . The joint and last sur-
vivor life expectancy for an employee and
a beneficiary at a combination of ages is
calculated as the sum of the probabilities
of the employee surviving to each future
year, plus the sum of the probabilities of
the beneficiary surviving to each future
year, minus the sum of the probabilities of
both the employee and beneficiary surviv-
ing to each future year . The resulting joint
and last survivor life expectancy is then
increased by 11/24 to approximate the ef-
fect of monthly payments, and is subject
to a floor of 1.0.
The life expectancy tables in the cur-
rent regulations are used in several exam-
ples in §1 .401(a)(9)-6, Q&A-14(f) that
illustrate the availability of the exception
described in §1 .401(a)(9)-6, Q&A-14(c)
(regarding certain increasing payments
under insurance company annuity con-
tracts) . These proposed regulations do not
include revisions to these examples to re-
flect the life expectancy tables in the pro-
posed regulations .
III . Effective/Applicability Date
The life expectancy tables and Uni-
form Lifetime Table under these proposed
regulations would apply for distribution
calendar years beginning on or after Janu-
ary 1, 2021 . Thus, for example, for an in-
dividual who attains age 70½ during 2020
(so that the minimum required distribution
for the distribution calendar year 2020 is
due April 1, 2021), the final regulations
would not apply to the minimum required
distribution for the individual’s 2020 dis-
tribution calendar year (which is due April
1, 2021), but would apply to the minimum
required distribution for the individual’s
2021 distribution calendar year (which is
due December 31, 2021) .
These proposed regulations include a
transition rule that applies if an employee
died before January 1, 2021, and, under
the rules of §1 .401(a)(9)-5, Q&A-5, the
distribution period that applies for calen-
dar years following the calendar year of
the employee’s death is equal to a single
life expectancy calculated as of the cal-
endar year of the employee’s death (or if
applicable, the year after the employee’s
death), reduced by 1 for each subsequent
year . Under this transition rule, the ini-
tial life expectancy used to determine
the distribution period is reset by using
the new Single Life Table for the age
of the relevant individual in the calen-
dar year for which life expectancy was
set under §1 .401(a)(9)-5, Q&A 5(c) . For
distribution calendar years beginning on
or after January 1, 2021, the distribution
period is determined by reducing that
initial life expectancy by 1 for each year
subsequent to the year for which it was
initially set .
This transition rule applies in three sit-
uations: (1) The employee died before the
required beginning date with a non-spou-
sal designated beneficiary (so that the ap-
plicable distribution period is determined
based on the remaining life expectancy of
the designated beneficiary for the calendar
year following the calendar year of the
employee’s death); (2) the employee died
after the required beginning date without
a designated beneficiary (so that the ap-
plicable distribution period is determined
based on the remaining life expectancy of
the employee for the year of the employ-
ee’s death); and (3) the employee, who is
younger than the designated beneficiary,
died after the required beginning date (so
that the applicable distribution period is
determined based on the remaining life
expectancy of the employee for the year
of the employee’s death) .
The proposed regulations illustrate
the application of this transition rule with
an example involving an employee who
died at age 80 in 2018 with a designated
beneficiary (who was not the employee’s
spouse) who was age 75 in the year of the
employee’s death . For 2019, the distribu-
tion period that applies for the beneficia-
ry is 12 .7 years (the period applicable for
a 76 year old under the Single Life Table
in current §1 .401(a)(9)-9), and for 2020,
it is 11 .7 years (the original distribution
period, reduced by 1 year) . For 2021, tak-
ing into account the life expectancy ta-
bles under the proposed regulations and
applying the transition rule, the appli-
cable distribution period would be 12 .0
years (the 14 .0 year life expectancy for
a 76 year old under the Single Life Table
in the proposed regulations, reduced by
2 years) .
A similar transition rule applies if an
employee’s sole beneficiary is the em-
ployee’s surviving spouse and the spouse
died before January 1, 2021 . Under the
rules of §1 .401(a)(9)-5, Q&A-5(c)(2),
the distribution period that applies for the
spouse’s beneficiary is equal to the single
life expectancy for the spouse calculat-
7
The Mortality Improvement Scale MP-2018 can be found at https://www .soa .org/experience-studies/2018/mortality-improvement-scale-mp-2018/ .
8
Assuming an equal distribution of deaths throughout the year, if a retiree is scheduled to receive monthly payments on the last day of each month then, in the year of death, on average, the
retiree would receive 11/24th of a full year’s worth of payments .

November 25, 2019 1236 Bulletin No. 2019–48
ed for the calendar year of the spouse’s
death, reduced by 1 for each subsequent
year . Under the transition rule, the initial
life expectancy used to determine the dis-
tribution period is reset by using the new
Single Life Table for the age of the spouse
in the calendar year of the spouse’s death .
For distribution calendar years beginning
on or after January 1, 2021, the distribu-
tion period is determined by reducing that
initial life expectancy by 1 for each year
subsequent to the year for which it was
initially set .
These transition rules, under which
there is a one-time reset for the relevant
life expectancy using the Single Life Ta-
ble under the proposed regulations, are
designed to recognize that the general
population has longer life expectancies
than the life expectancies set forth in the
2002 regulations . However, because the
reset life expectancy is based on the age
for which life expectancy was originally
determined (rather than the relevant indi-
vidual’s current age), it is consistent with
Congressional intent to limit recalculation
of life expectancy to the employee and the
employee’s spouse .
IV . Applicability to Revenue Ruling
2002-62
After final regulations that provide
updated life expectancy and distribution
period tables under section 401(a)(9) are
issued, if a taxpayer commenced receiv-
ing substantially equal periodic payments
before January 1, 2021, using the required
minimum distribution method described in
section 2 .01(a) of Rev . Rul . 2002-62, then
the application of the final regulations will
not be treated as a modification to a series
of substantially equal periodic payments
as described in section 72(t)(4)(A)(ii) . In
addition, if a taxpayer commences receiv-
ing substantially equal periodic payments
on or after January 1, 2021, and uses either
the fixed amortization method described
in section 2 .01(b) of Rev . Rul . 2002-62 or
the fixed annuitization method described
in section 2 .01(c) of Rev . Rul . 2002-62,
then the method should be applied by ap-
plying the corresponding life expectancy,
distribution period, and mortality tables in
the final regulations in lieu of the tables
in formerly applicable §1 .401(a)(9)-9 that
are referenced in Rev . Rul . 2002-62 .
Special Analyses
I . Regulatory Impact Analysis
Executive Orders 13771, 13563, and
12866 direct agencies to assess costs and
benefits of available regulatory alterna-
tives and, if regulation is necessary, to se-
lect regulatory approaches that maximize
net benefits, including potential economic,
environmental, public health and safety
effects, distributive impacts, and equi-
ty . Executive Order 13563 emphasizes
the importance of quantifying both costs
and benefits, reducing costs, harmonizing
rules, and promoting flexibility. The Ex-
ecutive Order 13771 designation for any
final rule resulting from the proposed reg-
ulation will be informed by comments re-
ceived . The preliminary Executive Order
13771 designation for this proposed rule
is deregulatory .
The proposed regulations have been
designated by the Office of Management
and Budget’s (OMB’s) Office of Infor-
mation and Regulatory Affairs (OIRA) as
subject to review under Executive Order
12866 pursuant to the Memorandum of
Agreement (MOA, April 11, 2018) be-
tween the Treasury Department and the
Office of Management and Budget regard-
ing review of tax regulations . OIRA has
determined that the proposed rulemaking
is significant and subject to review under
Executive Order 12866 and section 1(b)
of the Memorandum of Agreement . Ac-
cordingly, the proposed regulations have
been reviewed by OMB .
1 . Introduction and Need for Regulation
As stated earlier in the preamble to the
proposed regulations, in accordance with
Executive Order 13847, the Treasury De-
partment and the IRS have examined the
life expectancy and distribution period ta-
bles in §1 .401(a)(9)-9 and have reviewed
currently available mortality data . As a
result of this review, the Treasury Depart-
ment and the IRS determined that those
tables should be updated to reflect current
life expectancies .
The life expectancy tables and ap-
plicable distribution period tables in the
proposed regulations reflect longer life
expectancies than the tables in the exist-
ing regulations . The effect of these chang-
es is to reduce annual required minimum
distributions (RMDs) from qualified de-
fined contribution plans, IRAs, and cer-
tain other tax-favored retirement plans
(referred to as affected retirement plans) .
The purpose of such updates is to increase
the effectiveness of these tax-favored re-
tirement programs by allowing retirees
to retain more retirement savings in these
programs for their later years .
Pursuant to section 6(a)(3)(B) of Ex-
ecutive Order 12866, the following qual-
itative analysis provides further details
regarding the anticipated impacts of the
proposed regulations. After briefly de-
scribing the proposed regulations in Part
2, the baseline used for the analysis is
described in Part 3 . Part 4 describes the
entities and individuals affected by the
proposed regulations . Part 5 provides a
qualitative assessment of the potential
economic effects, including benefits and
costs, of the proposed regulations com-
pared to the baseline .
2. The Proposed Regulations
The RMD rules require an individual
to withdraw assets from an affected re-
tirement plan as generally taxable distri-
butions over the life expectancy of the
individual (or the individual and spouse) .
9

Balances remaining at the death of the
individual that are paid to a spouse as
designated beneficiary must generally be
withdrawn over the life expectancy of the
spouse .
10
The purpose of the RMD rules is
to ensure that the favorable tax treatment
afforded a qualified plan is used primarily
to provide retirement income to a partic-
ipant and designated beneficiary, while
9
This requirement to take distributions during the individual’s lifetime does not apply to a Roth IRA described in section 408A .
10
Balances payable to other designated beneficiaries must generally be withdrawn according to the beneficiary’s life expectancy (fixed as of the year of death). Different rules apply if the
individual dies prior to the required beginning date for RMDs .

Bulletin No. 2019–48 1237 November 25, 2019
mitigating the cost to the government of
deferred taxation on savings in qualified
retirement plans .
The life expectancy tables and appli-
cable distribution period tables in the pro-
posed regulations reflect longer life ex-
pectancies than the tables in the existing
regulations that are generally between one
and two years longer than under the exist-
ing regulations . This will give individuals
with affected retirement plans the option
to withdraw slightly smaller amounts
from their plans each year, giving individ-
uals and beneficiaries the option to leave
amounts in tax-favored retirement ac-
counts for a slightly longer period of time,
to account for the possibility that they may
live longer .
3. Baseline
The Treasury Department and the IRS
have assessed the benefits and costs of
these proposed regulations relative to a
no-action baseline reflecting anticipated
Federal income tax-related behavior in the
absence of these proposed regulations .
4. Affected Entities and Individuals
The proposed regulations affect indi-
viduals who withdraw exactly the RMD
amount from their affected retirement plan
but who would prefer to withdraw less in
the absence of the minimum distribution
requirements . Individuals who withdraw
more than the current RMD are not bound
by the current rules and therefore are not
expected to reduce withdrawals as a re-
sult of the proposed regulations . Using
confidential tax return data, the Treasury
Department estimates roughly 4 .6 million
individuals, or 20 .5% of all individuals
required to take RMDs from an affected
retirement plan, will make withdrawals at
the minimum required level in 2021, and
might reduce withdrawals as a result of
the rule .
In addition, Individual Retirement
Account (IRA) providers would have to
change the administration of their IRAs
to reflect the new life expectancy tables.
The Treasury Department does not have
an estimate of the number of such entities .
Additionally, employer plans that do not
require benefits to be paid out as a lump
sum would have to change the administra-
tion of their plans to reflect the new life
expectancy tables . The Treasury Depart-
ment expects that this would include most
large plans, which typically do not require
benefits to be paid out in a lump sum and
thus would be affected by the proposed
regulations . The latest available data, the
Private Pension Bulletin produced by the
Department of Labor, indicate there were
81,469 large qualified pension plans (de-
fined as plans with more than 100 partici-
pants) in 2016 .
11
5. Economic Effects
a. Labor Supply Effect
The proposed rule produces a positive
wealth effect, as lower levels of RMDs
lead to larger amounts of assets earning
tax-deferred returns . While this might
plausibly lead to a reduction in labor sup-
ply, this effect is likely to be small for the
following reasons .
First, the proposed regulations would
lead to a small decrease in the portion of
assets in affected retirement plans that
must be withdrawn as an RMD for a 70-
year old retiree . Under the current regula-
tions, if a 70-year old retiree had $250,000
in his or her affected retirement plan, the
individual is required at age 70 to with-
draw $9,124, equal to 3 .65% of plan as-
sets . Under the proposed regulations, the
individual would be required to withdraw
$8,591, equal to 3 .44% of plan assets, a
decrease of $533 or 0 .21% of plan assets .
Under the current regulations, a 90-year
old retiree with $250,000 in his or her af-
fected retirement plan would be required
at age 90 to withdraw $21,930, equal to
8 .77% of plan assets . Under the pro-
posed regulations, the individual would
be required to withdraw $20,661, equal to
8 .26% of plan assets, a decrease of $1,269
or 0 .51% of plan assets .
Second, the proposed regulations are
expected to affect the labor supply deci-
sions only of individuals who are making
withdrawals at or very close to the RMD
level . Individuals making withdrawals
from affected retirement plans exceeding
the current RMD are not bound by the cur-
rent minimum and are therefore not affect-
ed by relaxing the minimum by a small
amount . Hence, their labor supply deci-
sions are unlikely to change based on the
proposed regulations . Thus, the proposed
regulations would likely affect only a very
small portion of high income individuals
working into their late 60s and early 70s .
The small impact of the proposed reg-
ulations is illustrated by an example . As-
sume the following facts . The individual
is unmarried and has $250,000 in his or
her IRA and $0 in a taxable account . The
individual turns age 70 on January 1 and
because the individual turns 70½ in the
year must begin taking RMDs . The RMD
amount is determined as of January 1, but
is withdrawn on December 31 of the year
in question . Tax is paid immediately upon
the withdrawal of the RMD . Because the
individual who is bound by the RMD rules
has revealed a preference to continue to
save the funds rather than consume them,
the amount remaining after the tax has
been paid on the distribution is placed into
a taxable investment account on January
1 of the following year (the day after the
RMD is made) . Assets held in the IRA and
the taxable account earn a 3% rate of re-
turn once the individual turns age 70 . The
RMDs and the returns in the taxable ac-
count are taxed at a marginal rate of 22% .
Under the mortality rates in the pro-
posed regulations, an individual who is
70 is expected to live until approximately
age 90 . We examine the total assets, i .e .,
the sum of the assets in the IRA and in the
taxable account, that the taxpayer would
have at age 90 if the individual only takes
RMDs each year . Under the current regu-
lations, the individual’s total assets at age
90 would be $371,004 . Under the pro-
posed regulations, the individual’s total
assets at age 90 would be $374,461 . This
$3,457 (less than 1%) increase in total as-
sets at age 90 is unlikely to allow or incen-
tivize the individual to retire earlier than
he or she otherwise would .
The proposed regulations could in the-
ory lead to an increase in labor supply .
The argument is that because the value of
contributing to a retirement fund has in-
creased, the return to working longer has
increased . Another example illustrates
that the additional return to working is
11
https://www.dol.gov/sites/default/files/ebsa/researchers/statistics/retirement-bulletins/private-pension-plan-bulletin-historical-tables-and-graphs.pdf

November 25, 2019 1238 Bulletin No. 2019–48
small and very unlikely to induce an in-
crease in labor supply .
Assume the following facts . The in-
dividual is unmarried and is age 69 . The
individual chooses whether to work an ad-
ditional year or to retire . If the individual
works an additional year, the individual’s
income is sufficiently large so that the in-
dividual would choose to contribute the
maximum amount to an IRA ($7,000 in
2019) . If the individual retires, the indi-
vidual does not contribute to an IRA . That
is, if the individual retires at age 69, the
individual will have $250,000 of assets in
his or her IRA and $0 in a taxable account
on January 1 in the year the individual
turns age 70 . If the individual retires at
age 70, the individual will have $257,000
of assets in his or her IRA and $0 in a tax-
able account on January 1 in the year the
individual turns age 70 .
As in the previous example, the indi-
vidual has RMDs beginning at age 70 ½ .
The RMD amount is determined on Jan-
uary 1 but is withdrawn on December 31
of the year in question . Tax is paid imme-
diately upon the withdrawal of the RMD
amount . The amount remaining after the
tax has been paid on the distribution is
placed on January 1 of the following year,
i .e ., the day after the RMD was made, into
a taxable investment account . Assets held
in the IRA and the taxable account earn a
3% rate of return once the individual turns
age 70 . The RMDs and the returns in the
taxable account are taxed at a marginal tax
rate of 22% .
We again examine the total assets, i .e .,
the sum of the assets in the IRA and in the
taxable account that the individual would
have at age 90 . If the individual waits to
retire at age 70, under the current RMD
rules, the individual’s total assets at age 90
would be $10,388 more than if the taxpay-
er retired at age 69 . Under the proposed
rulemaking, if the individual waits to re-
tire at age 70, the individual’s total assets
at age 90 would be $10,485 more than if
the individual retired at age 69 .
The proposed rulemaking, therefore,
increases the difference in total assets at
age 90 by $97 . Even if the individual con-
tributed the $25,000 maximum to a 401(k)
plan – $19,000 plus $6,000 in catch-up
contributions in 2019 – the proposed
rulemaking would increase the difference
in total assets at age 90 by only $346 .
These amounts are likely much too small
to affect the individual’s decision about
whether to retire at age 69 or wait to retire
at age 70 .
Under the standard assumption that lei-
sure is a normal good, i .e ., time spent not
working increases as income and wealth
increase, the increase in potential retire-
ment income generated by the proposed
rulemaking could lead some individuals to
work less . However, given the magnitude
of the change as suggested in the preced-
ing example, this behavior is unlikely .
b. Increased Fees
Under the proposed regulations, more
assets will be left in affected retirement
plans. Using confidential tax data, the
Treasury Department estimates that in
2021, the proposed regulations would
lead to an $8 .1 billion reduction in dis-
tributions from affected retirement plans .
A joint study by Brightscope and the In-
vestment Company Institute indicates
that “all-in” fees for large plans, which
are the ones most likely not to require
distributions to be taken as a lump sum,
are typically below 1% .
12
Thus, reduced
withdrawals could lead to an increase in
fees of about $81 million earned by pro-
viders of services to affected retirement
plans in 2021 . However, in the absence of
the proposed regulations, individuals who
prefer to make smaller withdrawals would
likely transfer these funds into taxable in-
vestment accounts, which carry their own
fees . As a result, the net additional fees
earned by the investment industry as a
result of the proposed regulations are ex-
pected to be much less than $81 million .
c. Administrative Costs
Under the proposed regulations, all
IRA providers and administrators of em-
ployer-sponsored retirement plans that al-
low non-lump sum distributions will need
to update their life expectancy and distri-
bution period tables and communicate the
changes in their RMDs to their plan par-
ticipants . However, most employers use
purchased software of third-party service
providers that provide plan administrative
services for many employers . This creates
economies of scale and reduces the total
cost of the required update . The total cost
will then be spread over many employ-
ers, such that the cost to each employer
is expected to be very low . The Treasury
Department and the IRS do not have suf-
ficient data to determine the increased ad-
ministrative costs of the proposed regula-
tions for an individual IRA provider, plan
administrator who uses in-house software,
plan service provider or software devel-
oper, and invite comments on the cost
of implementing the life expectancy and
distribution period table in the proposed
regulations for these entities . The Trea-
sury Department and the IRS also invite
comments on the number of such entities
who would have to implement changes to
software in order to implement the life ex-
pectancy and distribution period table in
the proposed regulations .
II. Regulatory Flexibility Act
It is hereby certified pursuant to the
Regulatory Flexibility Act *5 U .S .C .,
chapter 6) that these proposed regulations
will not have a significant economic im-
pact on a substantial number of small en-
tities . These proposed regulations will ap-
ply to all employers that sponsor defined
contribution plans regardless of size . Al-
though data are not available to estimate
the number of small entitles affected, the
proposed rule may affect a substantial
number . As stated above, this rule updates
life expectancies that are required to be
used by statute .
Although the proposed rule may af-
fect a substantial number of small enti-
ties, the economic impact of the proposed
regulations is not likely to be significant.
Small businesses generally comply with
the minimum required distribution rules
12
See “The Brightscope/ICI Defined Contribution Plan Profile: A Close Look at 401(k) Plans” (December 2014) at https://www.ici.org/pdf/ppr_14_dcplan_profile_401k.pdf. This study
points to page 7 of “Inside the Structure of Defined Contribution/401(k) Plan Fees, 2013: A study assessing the mechanics of the ‘all-in’ fee” (August 2014) at https://www.ici.org/pdf/
rpt_14_dc_401k_fee_study.pdf, for a definition of the ‘all-in fee.’ This definition of ‘all-in fee’ “...includes all administrative or recordkeeping fees as well as investment fees (i.e., the invest-
ment option’s total expense ratio) whether they are assessed at the plan, employer or participant level. The ‘all-in’ fee excludes those recordkeeping and administrative activity fees that only
apply to particular participants who engage in the activity (e .g ., self-directed brokerage, managed accounts, loans, QDROs and distributions) .”

Bulletin No. 2019–48 1239 November 25, 2019
using either third-party administrators
or software, creating economies of scale
that mitigate the cost of updating life ex-
pectancy tables . Such software is updated
periodically irrespective of a change in
life expectancies used to determine min-
imum required distributions . The portion
of the cost of a periodic update that is
attributable to the implementation of the
life expectancy and distribution period
tables in the proposed regulations will be
spread over the client base of a service
provider that uses software developed in-
house, and over the group of purchasers
of generally-available plan administration
software . Because, in either case, the cost
of changing software to implement the
updated life expectancies is spread over
a large group of businesses that maintain
retirement plans, it is estimated that the
incremental cost for each affected small
businesses as a result of the use of updated
life expectancies is not significant.
Notwithstanding this certification,
Treasury and the IRS invite comments
about the impact that the proposed rule
would have on small entities . Pursuant to
section 7805(f) of the Code, this notice of
proposed rulemaking will be submitted
to the Chief Counsel for Advocacy of the
Small Business Administration for com-
ment on its impact on small entities .
Comments and Public Hearing
Before these proposed regulations are
adopted as final regulations, consideration
will be given to any comments that are
submitted timely to the Treasury Depart-
ment and the IRS as prescribed in this
preamble in the “ADDRESSES” section .
The Treasury Department and the IRS
request comments on all aspects of these
proposed regulations, including:
• How often the life expectancy and
distribution period tables in these reg-
ulations should be updated .
• The extent of the administrative bur-
den involved in implementing any
such updates .
• Whether guidance is needed so that a
participant whose plan administrator
or trustee fails to implement the final
regulations in a timely fashion may
take required minimum distributions
(or roll over distributions in excess of
the required minimum distribution) in
a manner that takes into account the
final regulations.
All comments will be available for
public inspection and copying at www .
regulations .gov or upon request .
A public hearing on these proposed reg-
ulations has been scheduled for January
23, 2020, beginning at 10 a .m . in the IRS
Auditorium, Internal Revenue Service,
1111 Constitution Avenue, NW, Washing-
ton, DC 20224 . Due to building security
procedures, visitors must enter at the Con-
stitution Avenue entrance . In addition, all
visitors must present photo identification
to enter the building . Because of access
restrictions, visitors will not be admitted
beyond the immediate entrance area more
than 30 minutes before the hearing starts .
For information about having your name
placed on the building access list to attend
the hearing, see the “FOR FURTHER
INFORMATION CONTACT” section
of this preamble .
The rules of 26 CFR 601 .601(a)(3) ap-
ply to the hearing . Persons who wish to
present oral comments at the hearing must
submit written or electronic comments by
January 7, 2020, and an outline of topics
to be discussed and the amount of time
to be devoted to each topic by January
7, 2020 . A period of 10 minutes will be
allotted to each person for making com-
ments . An agenda showing the scheduling
of the speakers will be prepared after the
deadline for receiving outlines has passed .
Copies of the agenda will be available free
of charge at the hearing .
Drafting Information
The principal authors of these proposed
regulations are Arslan Malik and Linda S .
F. Marshall, of the Office of the Associ-
ate Chief Counsel (Employee Benefits,
Exempt Organizations, and Employment
Taxes) . However, other personnel from
the Treasury Department and the IRS par-
ticipated in the development of the pro-
posed regulations .
* * * * *
Proposed Amendments to the
Regulations
Accordingly, 26 CFR part 1 is pro-
posed to be amended as follows:
PART 1 – INCOME TAX
Paragraph 1 . The authority citation for
part 1 continues to read in part as follows:
Authority: 26 U .S .C . 7805 * * *
§ 1.401(a)(9)-5 [Amended]
Par . 2 . Section 1 .401(a)(9)-5 is amend-
ed by:
1 . Removing the language “A-1 of §
1 .401(a)(9)-9” wherever it appears
and adding “§1 .401(a)(9)-9(b)” in its
place .
2 . Removing the language “A-2 of §
1 .401(a)(9)-9” wherever it appears
and adding “§1 .401(a)(9)-9(c)” in its
place .
3 . Removing the language “A-3 of §
1 .401(a)(9)-9” wherever it appears
and adding “§1 .401(a)(9)-9(d)” in its
place .
§ 1.401(a)(9)-6 [Amended]
Par . 3 . Section 1 .401(a)(9)-6 is amend-
ed by:
1 . Removing the language “A-1 of §
1 .401(a)(9)-9” wherever it appears
and adding “§1 .401(a)(9)-9(b)” in its
place .
2 . Removing the language “A-2 of §
1 .401(a)(9)-9” wherever it appears
and adding “§1 .401(a)(9)-9(d)” in its
place .
3 . Removing the language “A-3 of §
1 .401(a)(9)-9” wherever it appears
and adding “§1 .401(a)(9)-9(e)” in its
place .
§ 1.401(a)(9)-8 [Amended]
Par . 4 . Section 1 .401(a)(9)-8 is amend-
ed by removing the language “A-2 of
§1 .401(a)(9)-9” wherever it appears and
adding “§1 .401(a)(9)-9(d)” in its place .
Par . 5 . Section 1 .401(a)(9)-9 is amend-
ed to read as follows:
Section 1.401(a)(9)-9 Life Expectancy
and Distribution Period Tables .
(a) In general. This section specifies the
life expectancy and applicable distribution
period tables that apply for purposes of de-
termining required minimum distributions
under section 401(a)(9) . Paragraphs (b),
(c), and (d) of this section set forth these
tables . Paragraph (e) of this section pro-
vides the mortality rates that are used to

November 25, 2019 1240 Bulletin No. 2019–48
develop these tables . Paragraph (f) of this
section provides applicability date rules .
(b) Single Life Table . The following ta-
ble, referred to as the Single Life Table,
sets forth the life expectancy of an indi-
vidual at each age .
Table 1 to Paragraph (b)
AgeLife expectancy
084 .5
183 .7
282 .7
381 .7
480 .8
579 .8
678 .8
777 .8
876 .8
975 .8
1074 .8
1173 .8
1272 .8
1371 .9
1470 .9
1569 .9
1668 .9
1767 .9
1866 .9
1966 .0
2065 .0
2164 .0
2263 .0
2362 .0
2461 .1
2560 .1
2659 .1
2758 .2
2857 .2
2956 .2
3055 .3
3154 .3
3253 .4
3352 .4
3451 .4
3550 .5
3649 .5
3748 .6
3847 .6
AgeLife expectancy
3946 .6
4045 .7
4144 .7
4243 .8
4342 .8
4441 .8
4540 .9
4639 .9
4739 .0
4838 .0
4937 .1
5036 .1
5135 .2
5234 .3
5333 .3
5432 .4
5531 .5
5630 .6
5729 .7
5828 .8
5927 .9
6027 .1
6126 .2
6225 .3
6324 .5
6423 .6
6522 .8
6622 .0
6721 .2
6820 .4
6919 .5
7018 .7
7117 .9
7217 .1
7316 .3
7415 .6
7514 .8
7614 .0
7713 .3
7812 .6
791
1 .9
AgeLife expectancy
8011 .2
8110 .5
829 .9
839 .2
848 .6
858 .1
867 .5
877 .0
886 .6
896 .1
905 .7
915 .3
924 .9
934 .6
944 .2
953 .9
963 .7
973 .4
983 .2
993 .0
1002 .8
1012 .6
1022 .5
1032 .3
1042 .2
1052 .1
1062 .1
1072 .1
1082 .0
1092 .0
1102 .0
1112 .0
1122 .0
1131 .9
1141 .9
1151 .8
1161 .8
1171 .6
1181 .4
1191 .1
120 +1 .0

Bulletin No. 2019–48 1241 November 25, 2019
(c) Uniform Lifetime Table . The fol-
tions to an employee in situations in which spouse is the sole designated beneficiary
lowing table, referred to as the Uniform
the employee’s surviving spouse is not the but is not more than 10 years younger than
Lifetime Table, sets forth the distribution
sole designated beneficiary. This table the employee .
period that applies for lifetime distribu-
is also used if the employee’s surviving
Table 2 to Paragraph (c)
Age of employee
Distribution
period
7029
.1
7128 .2
7227 .3
7326 .4
7425 .5
7524 .6
7623 .7
7722 .8
7821 .9
7921 .0
8020 .2
8119 .3
8218 .4
8317 .6
8416 .8
8516 .0
Age of employee
Distribution
period
8615 .2
8714 .4
8813 .6
8912 .9
9012 .1
9111 .4
9210 .8
9310 .1
949 .5
958 .9
968 .3
977 .8
987 .3
996 .8
1006 .4
1015 .9
1025 .6
1035 .2
Age of employee
Distribution
period
1044 .9
1054 .6
1064 .3
1074 .1
1083 .9
1093 .7
1103 .5
1113 .4
1123 .2
1133 .1
1143 .0
1152 .9
1162 .8
1172 .7
1182 .5
1192 .3
120 +2 .0
(d) Joint and Last Survivor Table
. The
and Last Survivor Table, is used for de-termining the joint and last survivor life
following table, referred to as the Joint
expectancy of two individuals .
Table 3 to Paragraph (d)
Ages012345678
091 .891 .490 .990 .590 .189 .789 .389 .088 .7
191 .490 .990 .489 .989 .589 .188 .788 .388 .0
290 .990 .489 .989 .488 .988 .588 .187 .787 .3
390 .589 .989 .488 .988 .487 .987 .587 .186 .7
490 .189 .588 .988 .487 .987 .486 .986 .586 .1
589 .789 .188 .587 .987 .486 .986 .485 .985 .5
689 .388 .788 .187 .586 .986 .485 .985 .484 .9
789 .088 .387 .787 .186 .585 .985 .484 .984 .4
888 .788 .087 .386 .786 .185 .584 .984 .483 .9
988 .487 .787 .086 .385 .785 .184 .583 .983 .4
1088 .187 .486 .786 .085 .384 .784 .183 .582 .9
1187 .987 .186 .485 .785 .084 .483 .783 .182 .5
1287 .686 .986 .1
85 .484 .784 .083 .482 .782 .1
1387 .486 .785 .985 .184 .483 .783 .082 .481 .7

November 25, 2019 1242 Bulletin No. 2019–48
Ages012345678
14
87 .286 .485 .784 .984 .283 .482 .782 .081 .4
1587 .086 .285 .584 .783 .983 .282 .481 .781 .0
1686 .986 .185 .384 .583 .782 .982 .281 .480 .7
1786 .785 .985 .184 .383 .582 .781 .981 .280 .4
1886 .685 .784 .984 .183 .382 .581 .780 .980 .2
1986 .485 .684 .783 .983 .182 .381 .580 .779 .9
2086 .385 .584 .683 .882 .982 .181 .380 .579 .7
2186 .285 .384 .583 .682 .881 .981 .180 .379 .5
2286 .185 .284 .383 .582 .681 .880 .980 .179 .3
2386 .085 .184 .283 .482 .581 .680 .879 .979 .1
2485 .985 .084 .183 .282 .481 .580 .679 .878 .9
2585 .884 .984 .083 .182 .281 .480 .579 .678 .8
2685 .784 .883 .983 .082 .181 .280 .479 .578 .6
2785 .684 .883 .982 .982 .081 .180 .379 .478 .5
2885 .684 .783 .882 .982 .081 .080 .179 .378 .4
2985 .584 .683 .782 .881 .981 .080 .179 .278 .3
3085 .484 .683 .682 .781 .880 .980 .079 .178 .2
3185 .484 .583 .682 .681 .780 .879 .979 .078 .1
3285 .384 .483 .582 .681 .680 .779 .878 .978 .0
3385 .384 .483 .582 .581 .680 .779 .778 .877 .9
3485 .284 .383 .482 .581 .580 .679 .778 .777 .8
3585 .284 .383 .482 .481 .580 .579 .678 .777 .7
3685 .284 .383 .382 .481 .480 .579 .578 .677 .7
3785 .184 .283 .382 .381 .480 .479 .578 .577 .6
3885 .184 .283 .282 .381 .380 .479 .478 .577 .6
3985 .184 .283 .282 .381 .380 .379 .478 .477 .5
4085 .084 .183 .282 .281 .380 .379 .378 .477 .4
4185 .084 .183 .182 .281 .280 .379 .378 .477 .4
4285 .084 .183 .182 .281 .280 .279 .378 .377 .4
4384 .984 .083 .182 .181 .280 .279 .278 .377 .3
4484 .984 .083 .182 .181 .180 .279 .278 .277 .3
4584 .984 .083 .082 .181 .180 .179 .278 .277 .3
4684 .984 .083 .082 .181 .180 .179 .278 .277 .2
4784 .984 .083 .082 .081 .180 .179 .178 .277 .2
4884 .883 .983 .082 .081 .080 .179 .178 .177 .2
4984 .883 .983 .082 .081 .080 .179 .178 .177 .1
5084 .883 .982 .982 .081 .080 .079 .178 .177 .1
5184 .883 .982 .982 .081 .080 .079 .078 .177 .1
5284 .883 .982 .981 .981 .080 .079 .078 .077 .1
5384 .883 .982 .981 .981 .080 .079 .078 .077 .1
5484 .783 .982 .981 .980 .980 .079 .078 .077 .0
5584 .783 .882 .981 .980 .979 .979 .078 .077 .0
5684 .783 .882 .981 .980 .979 .979 .078 .077 .0
5784 .783 .882 .981 .980 .979 .978 .978 .077 .0

Bulletin No. 2019–48 1243 November 25, 2019
Ages012345678
5884 .783 .882 .881 .980 .979 .978 .978 .077 .0
5984 .783 .882 .881 .980 .979 .978 .977 .977 .0
6084 .783 .882 .881 .880 .979 .978 .977 .976 .9
6184 .783 .882 .881 .880 .979 .978 .977 .976 .9
6284 .783 .882 .881 .880 .979 .978 .977 .976 .9
6384 .683 .882 .881 .880 .879 .978 .977 .976 .9
6484 .683 .882 .881 .880 .879 .978 .977 .976 .9
6584 .683 .882 .881 .880 .879 .878 .977 .976 .9
6684 .683 .782 .881 .880 .879 .878 .977 .976 .9
6784 .683 .782 .881 .880 .879 .878 .877 .976 .9
6884 .683 .782 .881 .880 .879 .878 .877 .976 .9
6984 .683 .782 .881 .880 .879 .878 .877 .976 .9
7084 .683 .782 .881 .880 .879 .878 .877 .876 .9
7184 .683 .782 .881 .880 .879 .878 .877 .876 .9
7284 .683 .782 .881 .880 .879 .878 .877 .876 .9
7384 .683 .782 .781 .880 .879 .878 .877 .876 .8
7484 .683 .782 .781 .880 .879 .878 .877 .876 .8
7584 .683 .782 .781 .880 .879 .878 .877 .876 .8
7684 .683 .782 .781 .880 .879 .878 .877 .876 .8
7784 .683 .782 .781 .880 .879 .878 .877 .876 .8
7884 .683 .782 .781 .880 .879 .878 .877 .876 .8
7984 .683 .782 .781 .880 .879 .878 .877 .876 .8
8084 .683 .782 .781 .880 .879 .878 .877 .876 .8
8184 .683 .782 .781 .880 .879 .878 .877 .876 .8
8284 .683 .782 .781 .780 .879 .878 .877 .876 .8
8384 .683 .782 .781 .780 .879 .878 .877 .876 .8
8484 .683 .782 .781 .780 .879 .878 .877 .876 .8
8584 .683 .782 .781 .780 .879 .878 .877 .876 .8
8684 .583 .782 .781 .780 .879 .878 .877 .876 .8
8784 .583 .782 .781 .780 .879 .878 .877 .876 .8
8884 .583 .782 .781 .780 .879 .878 .877 .876 .8
8984 .583 .782 .781 .780 .879 .878 .877 .876 .8
9084 .583 .782 .781 .780 .879 .878 .877 .876 .8
9184 .583 .782 .781 .780 .879 .878 .877 .876 .8
9284 .583 .782 .781 .780 .879 .878 .877 .876 .8
9384 .583 .782 .781 .780 .879 .878 .877 .876 .8
9484 .583 .782 .781 .780 .879 .878 .877 .876 .8
9584 .583 .782 .781 .780 .879 .878 .877 .876 .8
9684 .583 .782 .781 .780 .879 .878 .877 .876 .8
9784 .583 .782 .781 .780 .879 .878 .877 .876 .8
9884 .583 .782 .781 .780 .879 .878 .877 .876 .8
9984 .583 .782 .781 .780 .879 .878 .877 .876 .8
10084 .583 .782 .781 .780 .879 .878 .877 .876 .8
10184 .583 .782 .781 .780 .879 .878 .877 .876 .8

November 25, 2019 1244 Bulletin No. 2019–48
Ages012345678
10284 .583 .782 .781 .780 .879 .878 .877 .876 .8
10384 .583 .782 .781 .780 .879 .878 .877 .876 .8
10484 .583 .782 .781 .780 .879 .878 .877 .876 .8
10584 .583 .782 .781 .780 .879 .878 .877 .876 .8
10684 .583 .782 .781 .780 .879 .878 .877 .876 .8
10784 .583 .782 .781 .780 .879 .878 .877 .876 .8
10884 .583 .782 .781 .780 .879 .878 .877 .876 .8
10984 .583 .782 .781 .780 .879 .878 .877 .876 .8
11084 .583 .782 .781 .780 .879 .878 .877 .876 .8
11184 .583 .782 .781 .780 .879 .878 .877 .876 .8
11284 .583 .782 .781 .780 .879 .878 .877 .876 .8
11384 .583 .782 .781 .780 .879 .878 .877 .876 .8
11484 .583 .782 .781 .780 .879 .878 .877 .876 .8
11584 .583 .782 .781 .780 .879 .878 .877 .876 .8
11684 .583 .782 .781 .780 .879 .878 .877 .876 .8
11784 .583 .782 .781 .780 .879 .878 .877 .876 .8
11884 .583 .782 .781 .780 .879 .878 .877 .876 .8
11984 .583 .782 .781 .780 .879 .878 .877 .876 .8
120+84 .583 .782 .781 .780 .879 .878 .877 .876 .8

Bulletin No. 2019–48 1245 November 25, 2019
Ages91011121314151617
088 .488 .187 .987 .687 .487 .287 .086 .986 .7
187 .787 .487 .186 .986 .786 .486 .286 .185 .9
287 .086 .786 .486 .185 .985 .785 .585 .385 .1
386 .386 .085 .785 .485 .184 .984 .784 .584 .3
485 .785 .385 .084 .784 .484 .283 .983 .783 .5
585 .184 .784 .484 .083 .783 .483 .282 .982 .7
684 .584 .183 .783 .483 .082 .782 .482 .281 .9
783 .983 .583 .182 .782 .482 .081 .781 .481 .2
883 .482 .982 .582 .181 .781 .481 .080 .780 .4
982 .982 .481 .981 .581 .180 .780 .480 .079 .7
1082 .481 .981 .480 .980 .580 .179 .779 .479 .0
1181 .981 .480 .980 .479 .979 .579 .178 .778 .4
1281 .580 .980 .479 .979 .478 .978 .578 .177 .7
1381 .180 .579 .979 .478 .978 .477 .977 .577 .1
1480 .780 .179 .578 .978 .477 .977 .476 .976 .5
1580 .479 .779 .178 .577 .977 .476 .976 .475 .9
1680 .079 .478 .778 .177 .576 .976 .475 .975 .4
1779 .779 .078 .477 .777 .176 .575 .975 .474 .9
1879 .478 .778 .077 .476 .776 .175 .575 .074 .4
1979 .278 .477 .777 .076 .475 .775 .174 .574 .0
2078 .978 .277 .476 .776 .075 .474 .774 .173 .5
2178 .777 .977 .276 .475 .775 .074 .473 .773 .1
2278 .577 .776 .976 .275 .474 .774 .073 .472 .7
2378 .377 .576 .775 .975 .274 .473 .773 .172 .4
2478 .177 .376 .575 .774 .974 .273 .572 .772 .1
2577 .977 .176 .375 .574 .773 .973 .272 .571 .7
2677 .876 .976 .175 .374 .573 .772 .972 .271 .5
2777 .676 .875 .975 .174 .373 .572 .771 .971 .2
2877 .576 .675 .874 .974 .173 .372 .571 .771 .0
2977 .476 .575 .674 .873 .973 .172 .371 .570 .7
3077 .376 .475 .574 .673 .873 .072 .171 .370 .5
3177 .276 .375 .474 .573 .772 .872 .071 .170 .3
3277 .176 .275 .374 .473 .572 .771 .871 .070 .1
3377 .076 .175 .274 .373 .472 .571 .770 .870 .0
3476 .976 .075 .174 .273 .372 .471 .570 .769 .8
3576 .875 .975 .074 .173 .272 .371 .470 .569 .7
3676 .775 .874 .974 .073 .172 .271 .370 .469 .5
3776 .775 .774 .873 .973 .072 .171 .270 .369 .4
3876 .675 .774 .773 .872 .972 .071 .170 .269 .3
3976 .675 .674 .773 .872 .871 .971 .070 .169 .2
4076 .575 .674 .673 .772 .871 .870 .970 .069 .1
4176 .575 .574 .673 .672 .771 .870 .869 .969 .0
4276 .475 .574 .573 .672 .671 .770 .869 .868 .9
4376 .475 .474 .573 .572 .671 .670 .769 .868 .9

November 25, 2019 1246 Bulletin No. 2019–48
Ages91011121314151617
4476 .375 .474 .473 .572 .571 .670 .669 .768 .8
4576 .375 .374 .473 .472 .571 .570 .669 .668 .7
4676 .375 .374 .373 .472 .471 .570 .569 .668 .7
4776 .275 .374 .373 .372 .471 .470 .569 .568 .6
4876 .275 .274 .373 .372 .371 .470 .469 .568 .5
4976 .275 .274 .273 .372 .371 .470 .469 .468 .5
5076 .175 .274 .273 .272 .371 .370 .469 .468 .5
5176 .175 .274 .273 .272 .271 .370 .369 .468 .4
5276 .175 .174 .273 .272 .271 .370 .369 .368 .4
5376 .175 .174 .173 .272 .271 .270 .369 .368 .3
5476 .175 .174 .173 .172 .271 .270 .269 .368 .3
5576 .075 .174 .173 .172 .171 .270 .269 .268 .3
5676 .075 .074 .173 .172 .171 .270 .269 .268 .3
5776 .075 .074 .173 .172 .171 .170 .269 .268 .2
5876 .075 .074 .073 .172 .171 .170 .169 .268 .2
5976 .075 .074 .073 .072 .171 .170 .169 .268 .2
6076 .075 .074 .073 .072 .171 .170 .169 .168 .2
6176 .075 .074 .073 .072 .071 .170 .169 .168 .1
6275 .975 .074 .073 .072 .071 .070 .169 .168 .1
6375 .975 .074 .073 .072 .071 .070 .169 .168 .1
6475 .974 .974 .073 .072 .071 .070 .069 .168 .1
6575 .974 .973 .973 .072 .071 .070 .069 .168 .1
6675 .974 .973 .973 .072 .071 .070 .069 .068 .1
6775 .974 .973 .972 .972 .071 .070 .069 .068 .1
6875 .974 .973 .972 .972 .071 .070 .069 .068 .0
6975 .974 .973 .972 .971 .971 .070 .069 .068 .0
7075 .974 .973 .972 .971 .971 .070 .069 .068 .0
7175 .974 .973 .972 .971 .970 .970 .069 .068 .0
7275 .974 .973 .972 .971 .970 .970 .069 .068 .0
7375 .974 .973 .972 .971 .970 .970 .069 .068 .0
7475 .974 .973 .972 .971 .970 .969 .969 .068 .0
7575 .974 .973 .972 .971 .970 .969 .969 .068 .0
7675 .874 .973 .972 .971 .970 .969 .968 .968 .0
7775 .874 .973 .972 .971 .970 .969 .968 .968 .0
7875 .874 .973 .972 .971 .970 .969 .968 .968 .0
7975 .874 .873 .972 .971 .970 .969 .968 .968 .0
8075 .874 .873 .972 .971 .970 .969 .968 .967 .9
8175 .874 .873 .972 .971 .970 .969 .968 .967 .9
8275 .874 .873 .972 .971 .970 .969 .968 .967 .9
8375 .874 .873 .972 .971 .970 .969 .968 .967 .9
8475 .874 .873 .872 .971 .970 .969 .968 .967 .9
8575 .874 .873 .872 .971 .970 .969 .968 .967 .9
8675 .874 .873 .872 .971 .970 .969 .968 .967 .9
8775 .874 .873 .872 .971 .970 .969 .968 .967 .9

Bulletin No. 2019–48 1247 November 25, 2019
Ages91011121314151617
8875 .874 .873 .872 .971 .970 .969 .968 .967 .9
8975 .874 .873 .872 .971 .970 .969 .968 .967 .9
9075 .874 .873 .872 .971 .970 .969 .968 .967 .9
9175 .874 .873 .872 .971 .970 .969 .968 .967 .9
9275 .874 .873 .872 .971 .970 .969 .968 .967 .9
9375 .874 .873 .872 .871 .970 .969 .968 .967 .9
9475 .874 .873 .872 .871 .970 .969 .968 .967 .9
9575 .874 .873 .872 .871 .970 .969 .968 .967 .9
9675 .874 .873 .872 .871 .970 .969 .968 .967 .9
9775 .874 .873 .872 .871 .970 .969 .968 .967 .9
9875 .874 .873 .872 .871 .970 .969 .968 .967 .9
9975 .874 .873 .872 .871 .970 .969 .968 .967 .9
10075 .874 .873 .872 .871 .970 .969 .968 .967 .9
10175 .874 .873 .872 .871 .970 .969 .968 .967 .9
10275 .874 .873 .872 .871 .970 .969 .968 .967 .9
10375 .874 .873 .872 .871 .970 .969 .968 .967 .9
10475 .874 .873 .872 .871 .970 .969 .968 .967 .9
10575 .874 .873 .872 .871 .970 .969 .968 .967 .9
10675 .874 .873 .872 .871 .970 .969 .968 .967 .9
10775 .874 .873 .872 .871 .970 .969 .968 .967 .9
10875 .874 .873 .872 .871 .970 .969 .968 .967 .9
10975 .874 .873 .872 .871 .970 .969 .968 .967 .9
11075 .874 .873 .872 .871 .970 .969 .968 .967 .9
11175 .874 .873 .872 .871 .970 .969 .968 .967 .9
11275 .874 .873 .872 .871 .970 .969 .968 .967 .9
11375 .874 .873 .872 .871 .970 .969 .968 .967 .9
11475 .874 .873 .872 .871 .970 .969 .968 .967 .9
11575 .874 .873 .872 .871 .970 .969 .968 .967 .9
11675 .874 .873 .872 .871 .970 .969 .968 .967 .9
11775 .874 .873 .872 .871 .970 .969 .968 .967 .9
11875 .874 .873 .872 .871 .970 .969 .968 .967 .9
11975 .874 .873 .872 .871 .970 .969 .968 .967 .9
120+75 .874 .873 .872 .871 .970 .969 .968 .967 .9

November 25, 2019 1248 Bulletin No. 2019–48
Ages181920212223242526
086 .686 .486 .386 .286 .186 .085 .985 .885 .7
185 .785 .685 .585 .385 .285 .185 .084 .984 .8
284 .984 .784 .684 .584 .384 .284 .184 .083 .9
384 .183 .983 .883 .683 .583 .483 .283 .183 .0
483 .383 .182 .982 .882 .682 .582 .482 .282 .1
582 .582 .382 .181 .981 .881 .681 .581 .481 .2
681 .781 .581 .381 .180 .980 .880 .680 .580 .4
780 .980 .780 .580 .380 .179 .979 .879 .679 .5
880 .279 .979 .779 .579 .379 .178 .978 .878 .6
979 .479 .278 .978 .778 .578 .378 .177 .977 .8
1078 .778 .478 .277 .977 .777 .577 .377 .176 .9
1178 .077 .777 .477 .276 .976 .776 .576 .376 .1
1277 .477 .076 .776 .476 .275 .975 .775 .575 .3
1376 .776 .476 .075 .775 .475 .274 .974 .774 .5
1476 .175 .775 .475 .074 .774 .474 .273 .973 .7
1575 .575 .174 .774 .474 .073 .773 .573 .272 .9
1675 .074 .574 .173 .773 .473 .172 .772 .572 .2
1774 .474 .073 .573 .172 .772 .472 .171 .771 .5
1873 .973 .473 .072 .572 .171 .771 .471 .170 .8
1973 .472 .972 .472 .071 .571 .170 .870 .470 .1
2073 .072 .471 .971 .471 .070 .570 .169 .869 .4
2172 .572 .071 .470 .970 .470 .069 .569 .168 .8
2272 .171 .571 .070 .469 .969 .469 .068 .568 .1
2371 .771 .170 .570 .069 .468 .968 .468 .067 .6
2471 .470 .870 .169 .569 .068 .467 .967 .467 .0
2571 .170 .469 .869 .168 .568 .067 .466 .966 .5
2670 .870 .169 .468 .868 .167 .667 .066 .565 .9
2770 .569 .869 .168 .467 .867 .266 .666 .065 .5
2870 .269 .568 .868 .167 .466 .866 .265 .665 .0
2970 .069 .268 .567 .867 .166 .465 .865 .264 .6
3069 .769 .068 .267 .566 .866 .165 .464 .864 .2
3169 .568 .768 .067 .266 .565 .865 .164 .463 .8
3269 .368 .567 .767 .066 .265 .564 .864 .163 .4
3369 .168 .367 .566 .766 .065 .264 .563 .863 .1
3469 .068 .167 .366 .565 .865 .064 .263 .562 .8
3568 .868 .067 .266 .365 .564 .864 .063 .362 .5
3668 .767 .867 .066 .265 .464 .663 .863 .062 .3
3768 .567 .766 .866 .065 .264 .463 .662 .862 .0
3868 .467 .666 .765 .865 .064 .263 .462 .661 .8
3968 .367 .466 .665 .764 .964 .063 .262 .461 .6
4068 .267 .366 .465 .664 .763 .963 .062 .261 .4
4168 .167 .266 .365 .464 .663 .762 .962 .061 .2
4268 .067 .166 .265 .364 .563 .662 .761 .961 .0
4367 .967 .066 .165 .264 .363 .562 .661 .760 .9

Bulletin No. 2019–48 1249 November 25, 2019
Ages181920212223242526
4467 .966 .966 .065 .164 .263 .462 .561 .660 .7
4567 .866 .966 .065 .064 .163 .362 .461 .560 .6
4667 .766 .865 .965 .064 .163 .262 .361 .460 .5
4767 .766 .765 .864 .964 .063 .162 .261 .360 .4
4867 .666 .765 .764 .863 .963 .062 .161 .260 .3
4967 .666 .665 .764 .863 .862 .962 .061 .160 .2
5067 .566 .665 .664 .763 .862 .861 .961 .060 .1
5167 .566 .565 .664 .663 .762 .861 .960 .960 .0
5267 .466 .565 .564 .663 .762 .761 .860 .960 .0
5367 .466 .465 .564 .563 .662 .761 .760 .859 .9
5467 .466 .465 .464 .563 .662 .661 .760 .759 .8
5567 .366 .465 .464 .563 .562 .661 .660 .759 .8
5667 .366 .365 .464 .463 .562 .561 .660 .659 .7
5767 .366 .365 .364 .463 .462 .561 .560 .659 .7
5867 .266 .365 .364 .463 .462 .561 .560 .659 .6
5967 .266 .365 .364 .363 .462 .461 .560 .559 .6
6067 .266 .265 .364 .363 .362 .461 .460 .559 .5
6167 .266 .265 .264 .363 .362 .461 .460 .559 .5
6267 .266 .265 .264 .363 .362 .361 .460 .459 .5
6367 .166 .265 .264 .263 .362 .361 .460 .459 .4
6467 .166 .265 .264 .263 .362 .361 .360 .459 .4
6567 .166 .165 .264 .263 .262 .361 .360 .359 .4
6667 .166 .165 .264 .263 .262 .261 .360 .359 .4
6767 .166 .165 .164 .263 .262 .261 .360 .359 .3
6867 .166 .165 .164 .263 .262 .261 .360 .359 .3
6967 .166 .165 .164 .163 .262 .261 .260 .359 .3
7067 .066 .165 .164 .163 .262 .261 .260 .359 .3
7167 .066 .165 .164 .163 .162 .261 .260 .259 .3
7267 .066 .165 .164 .163 .162 .261 .260 .259 .3
7367 .066 .065 .164 .163 .162 .161 .260 .259 .3
7467 .066 .065 .164 .163 .162 .161 .260 .259 .2
7567 .066 .065 .064 .163 .162 .161 .260 .259 .2
7667 .066 .065 .064 .163 .162 .161 .260 .259 .2
7767 .066 .065 .064 .163 .162 .161 .160 .259 .2
7867 .066 .065 .064 .163 .162 .161 .160 .259 .2
7967 .066 .065 .064 .063 .162 .161 .160 .259 .2
8067 .066 .065 .064 .063 .162 .161 .160 .259 .2
8167 .066 .065 .064 .063 .162 .161 .160 .159 .2
8267 .066 .065 .064 .063 .162 .161 .160 .159 .2
8367 .066 .065 .064 .063 .062 .161 .160 .159 .2
8467 .066 .065 .064 .063 .062 .161 .160 .159 .2
8567 .066 .065 .064 .063 .062 .161 .160 .159 .2
8667 .066 .065 .064 .063 .062 .161 .160 .159 .2
8766 .966 .065 .064 .063 .062 .161 .160 .159 .1

November 25, 2019 1250 Bulletin No. 2019–48
Ages181920212223242526
8866 .966 .065 .064 .063 .062 .161 .160 .159 .1
8966 .966 .065 .064 .063 .062 .161 .160 .159 .1
9066 .966 .065 .064 .063 .062 .161 .160 .159 .1
9166 .966 .065 .064 .063 .062 .161 .160 .159 .1
9266 .966 .065 .064 .063 .062 .061 .160 .159 .1
9366 .966 .065 .064 .063 .062 .061 .160 .159 .1
9466 .966 .065 .064 .063 .062 .061 .160 .159 .1
9566 .966 .065 .064 .063 .062 .061 .160 .159 .1
9666 .966 .065 .064 .063 .062 .061 .160 .159 .1
9766 .966 .065 .064 .063 .062 .061 .160 .159 .1
9866 .966 .065 .064 .063 .062 .061 .160 .159 .1
9966 .966 .065 .064 .063 .062 .061 .160 .159 .1
10066 .966 .065 .064 .063 .062 .061 .160 .159 .1
10166 .966 .065 .064 .063 .062 .061 .160 .159 .1
10266 .966 .065 .064 .063 .062 .061 .160 .159 .1
10366 .966 .065 .064 .063 .062 .061 .160 .159 .1
10466 .966 .065 .064 .063 .062 .061 .160 .159 .1
10566 .966 .065 .064 .063 .062 .061 .160 .159 .1
10666 .966 .065 .064 .063 .062 .061 .160 .159 .1
10766 .966 .065 .064 .063 .062 .061 .160 .159 .1
10866 .966 .065 .064 .063 .062 .061 .160 .159 .1
10966 .966 .065 .064 .063 .062 .061 .160 .159 .1
11066 .966 .065 .064 .063 .062 .061 .160 .159 .1
11166 .966 .065 .064 .063 .062 .061 .160 .159 .1
11266 .966 .065 .064 .063 .062 .061 .160 .159 .1
11366 .966 .065 .064 .063 .062 .061 .160 .159 .1
11466 .966 .065 .064 .063 .062 .061 .160 .159 .1
11566 .966 .065 .064 .063 .062 .061 .160 .159 .1
11666 .966 .065 .064 .063 .062 .061 .160 .159 .1
11766 .966 .065 .064 .063 .062 .061 .160 .159 .1
11866 .966 .065 .064 .063 .062 .061 .160 .159 .1
11966 .966 .065 .064 .063 .062 .061 .160 .159 .1
120+66 .966 .065 .064 .063 .062 .061 .160 .159 .1

Bulletin No. 2019–48 1251 November 25, 2019
Ages272829303132333435
085 .685 .685 .585 .485 .485 .385 .385 .285 .2
184 .884 .784 .684 .684 .584 .484 .484 .384 .3
283 .983 .883 .783 .683 .683 .583 .583 .483 .4
382 .982 .982 .882 .782 .682 .682 .582 .582 .4
482 .082 .081 .981 .881 .781 .681 .681 .581 .5
581 .181 .081 .080 .980 .880 .780 .780 .680 .5
680 .380 .180 .180 .079 .979 .879 .779 .779 .6
779 .479 .379 .279 .179 .078 .978 .878 .778 .7
878 .578 .478 .378 .278 .178 .077 .977 .877 .7
977 .677 .577 .477 .377 .277 .177 .076 .976 .8
1076 .876 .676 .576 .476 .376 .276 .176 .075 .9
1175 .975 .875 .675 .575 .475 .375 .275 .175 .0
1275 .174 .974 .874 .674 .574 .474 .374 .274 .1
1374 .374 .173 .973 .873 .773 .573 .473 .373 .2
1473 .573 .373 .173 .072 .872 .772 .572 .472 .3
1572 .772 .572 .372 .172 .071 .871 .771 .571 .4
1671 .971 .771 .571 .371 .171 .070 .870 .770 .5
1771 .271 .070 .770 .570 .370 .170 .069 .869 .7
1870 .570 .270 .069 .769 .569 .369 .169 .068 .8
1969 .869 .569 .269 .068 .768 .568 .368 .168 .0
2069 .168 .868 .568 .268 .067 .767 .567 .367 .2
2168 .468 .167 .867 .567 .267 .066 .766 .566 .3
2267 .867 .467 .166 .866 .566 .266 .065 .865 .5
2367 .266 .866 .466 .165 .865 .565 .265 .064 .8
2466 .666 .265 .865 .465 .164 .864 .564 .264 .0
2566 .065 .665 .264 .864 .464 .163 .863 .563 .3
2665 .565 .064 .664 .263 .863 .463 .162 .862 .5
2765 .064 .564 .063 .663 .262 .862 .562 .161 .8
2864 .564 .063 .563 .062 .662 .261 .861 .561 .1
2964 .063 .563 .062 .562 .061 .661 .260 .860 .5
3063 .663 .062 .562 .061 .561 .060 .660 .259 .8
3163 .262 .662 .061 .561 .060 .560 .159 .659 .2
3262 .862 .261 .661 .060 .560 .059 .559 .158 .6
3362 .561 .861 .260 .660 .159 .559 .058 .558 .1
3462 .161 .560 .860 .259 .659 .158 .558 .057 .5
3561 .861 .160 .559 .859 .258 .658 .157 .557 .0
3661 .560 .860 .159 .558 .858 .257 .657 .156 .6
3761 .360 .559 .859 .258 .557 .957 .256 .756 .1
3861 .060 .359 .658 .958 .257 .556 .956 .355 .7
3960 .860 .059 .358 .657 .957 .256 .555 .955 .3
4060 .659 .859 .058 .357 .656 .956 .255 .554 .9
4160 .459 .658 .858 .157 .356 .655 .955 .254 .5
4260 .259 .458 .657 .857 .156 .355 .654 .954 .2
4360 .159 .258 .457 .656 .856 .155 .354 .653 .9

November 25, 2019 1252 Bulletin No. 2019–48
Ages272829303132333435
4459 .959 .158 .257 .456 .655 .955 .154 .453 .6
4559 .858 .958 .157 .356 .455 .754 .954 .153 .4
4659 .658 .857 .957 .156 .355 .554 .753 .953 .1
4759 .558 .657 .856 .956 .155 .354 .553 .752 .9
4859 .458 .557 .756 .856 .055 .154 .353 .552 .7
4959 .358 .457 .556 .755 .855 .054 .153 .352 .5
5059 .258 .357 .456 .655 .754 .854 .053 .252 .3
5159 .158 .257 .356 .555 .654 .753 .953 .052 .2
5259 .058 .157 .256 .455 .554 .653 .752 .952 .0
5359 .058 .157 .256 .355 .454 .553 .652 .751 .9
5458 .958 .057 .156 .255 .354 .453 .552 .651 .8
5558 .857 .957 .056 .155 .254 .353 .452 .551 .7
5658 .857 .956 .956 .055 .154 .253 .352 .451 .6
5758 .757 .856 .956 .055 .054 .153 .252 .351 .5
5858 .757 .756 .855 .955 .054 .153 .252 .351 .4
5958 .657 .756 .855 .854 .954 .053 .152 .251 .3
6058 .657 .756 .755 .854 .953 .953 .052 .151 .2
6158 .657 .656 .755 .754 .853 .953 .052 .151 .1
6258 .557 .656 .655 .754 .853 .852 .952 .051 .1
6358 .557 .556 .655 .754 .753 .852 .951 .951 .0
6458 .557 .556 .655 .654 .753 .852 .851 .951 .0
6558 .457 .556 .555 .654 .753 .752 .851 .950 .9
6658 .457 .556 .555 .654 .653 .752 .751 .850 .9
6758 .457 .456 .555 .554 .653 .752 .751 .850 .8
6858 .457 .456 .555 .554 .653 .652 .751 .750 .8
6958 .457 .456 .455 .554 .553 .652 .751 .750 .8
7058 .357 .456 .455 .554 .553 .652 .651 .750 .7
7158 .357 .456 .455 .554 .553 .652 .651 .750 .7
7258 .357 .356 .455 .454 .553 .552 .651 .650 .7
7358 .357 .356 .455 .454 .553 .552 .651 .650 .7
7458 .357 .356 .455 .454 .553 .552 .551 .650 .6
7558 .357 .356 .355 .454 .453 .552 .551 .650 .6
7658 .357 .356 .355 .454 .453 .552 .551 .650 .6
7758 .257 .356 .355 .454 .453 .552 .551 .650 .6
7858 .257 .356 .355 .454 .453 .452 .551 .550 .6
7958 .257 .356 .355 .454 .453 .452 .551 .550 .6
8058 .257 .356 .355 .354 .453 .452 .551 .550 .6
8158 .257 .356 .355 .354 .453 .452 .551 .550 .6
8258 .257 .256 .355 .354 .453 .452 .551 .550 .5
8358 .257 .256 .355 .354 .453 .452 .551 .550 .5
8458 .257 .256 .355 .354 .453 .452 .451 .550 .5
8558 .257 .256 .355 .354 .453 .452 .451 .550 .5
8658 .257 .256 .355 .354 .353 .452 .451 .550 .5
8758 .257 .256 .355 .354 .353 .452 .451 .550 .5

Bulletin No. 2019–48 1253 November 25, 2019
Ages272829303132333435
8858 .257 .256 .355 .354 .353 .452 .451 .550 .5
8958 .257 .256 .355 .354 .353 .452 .451 .550 .5
9058 .257 .256 .355 .354 .353 .452 .451 .550 .5
9158 .257 .256 .355 .354 .353 .452 .451 .550 .5
9258 .257 .256 .255 .354 .353 .452 .451 .550 .5
9358 .257 .256 .255 .354 .353 .452 .451 .550 .5
9458 .257 .256 .255 .354 .353 .452 .451 .550 .5
9558 .257 .256 .255 .354 .353 .452 .451 .550 .5
9658 .257 .256 .255 .354 .353 .452 .451 .550 .5
9758 .257 .256 .255 .354 .353 .452 .451 .550 .5
9858 .257 .256 .255 .354 .353 .452 .451 .550 .5
9958 .257 .256 .255 .354 .353 .452 .451 .550 .5
10058 .257 .256 .255 .354 .353 .452 .451 .550 .5
10158 .257 .256 .255 .354 .353 .452 .451 .450 .5
10258 .257 .256 .255 .354 .353 .452 .451 .450 .5
10358 .257 .256 .255 .354 .353 .452 .451 .450 .5
10458 .257 .256 .255 .354 .353 .452 .451 .450 .5
10558 .257 .256 .255 .354 .353 .452 .451 .450 .5
10658 .257 .256 .255 .354 .353 .452 .451 .450 .5
10758 .257 .256 .255 .354 .353 .452 .451 .450 .5
10858 .257 .256 .255 .354 .353 .452 .451 .450 .5
10958 .257 .256 .255 .354 .353 .452 .451 .450 .5
11058 .257 .256 .255 .354 .353 .452 .451 .450 .5
11158 .257 .256 .255 .354 .353 .452 .451 .450 .5
11258 .257 .256 .255 .354 .353 .452 .451 .450 .5
11358 .257 .256 .255 .354 .353 .452 .451 .450 .5
11458 .257 .256 .255 .354 .353 .452 .451 .450 .5
11558 .257 .256 .255 .354 .353 .452 .451 .450 .5
11658 .257 .256 .255 .354 .353 .452 .451 .450 .5
11758 .257 .256 .255 .354 .353 .452 .451 .450 .5
11858 .257 .256 .255 .354 .353 .452 .451 .450 .5
11958 .257 .256 .255 .354 .353 .452 .451 .450 .5
120+58 .257 .256 .255 .354 .353 .452 .451 .450 .5

November 25, 2019 1254 Bulletin No. 2019–48
Ages363738394041424344
085 .285 .185 .185 .185 .085 .085 .084 .984 .9
184 .384 .284 .284 .284 .184 .184 .184 .084 .0
283 .383 .383 .283 .283 .283 .183 .183 .183 .1
382 .482 .382 .382 .382 .282 .282 .282 .182 .1
481 .481 .481 .381 .381 .381 .281 .281 .281 .1
580 .580 .480 .480 .380 .380 .380 .280 .280 .2
679 .579 .579 .479 .479 .379 .379 .379 .279 .2
778 .678 .578 .578 .478 .478 .478 .378 .378 .2
877 .777 .677 .677 .577 .477 .477 .477 .377 .3
976 .776 .776 .676 .676 .576 .576 .476 .476 .3
1075 .875 .775 .775 .675 .675 .575 .575 .475 .4
1174 .974 .874 .774 .774 .674 .674 .574 .574 .4
1274 .073 .973 .873 .873 .773 .673 .673 .573 .5
1373 .173 .072 .972 .872 .872 .772 .672 .672 .5
1472 .272 .172 .071 .971 .871 .871 .771 .671 .6
1571 .371 .271 .171 .070 .970 .870 .870 .770 .6
1670 .470 .370 .270 .170 .069 .969 .869 .869 .7
1769 .569 .469 .369 .269 .169 .068 .968 .968 .8
1868 .768 .568 .468 .368 .268 .168 .067 .967 .9
1967 .867 .767 .667 .467 .367 .267 .167 .066 .9
2067 .066 .866 .766 .666 .466 .366 .266 .166 .0
2166 .266 .065 .865 .765 .665 .465 .365 .265 .1
2265 .465 .265 .064 .964 .764 .664 .564 .364 .2
2364 .664 .464 .264 .063 .963 .763 .663 .563 .4
2463 .863 .663 .463 .263 .062 .962 .762 .662 .5
2563 .062 .862 .662 .462 .262 .061 .961 .761 .6
2662 .362 .061 .861 .661 .461 .261 .060 .960 .7
2761 .561 .361 .060 .860 .660 .460 .260 .159 .9
2860 .860 .560 .360 .059 .859 .659 .459 .259 .1
2960 .159 .859 .659 .359 .058 .858 .658 .458 .2
3059 .559 .258 .958 .658 .358 .157 .857 .657 .4
3158 .858 .558 .257 .957 .657 .357 .156 .856 .6
3258 .257 .957 .557 .256 .956 .656 .356 .155 .9
3357 .657 .256 .956 .556 .255 .955 .655 .355 .1
3457 .156 .756 .355 .955 .555 .254 .954 .654 .4
3556 .656 .155 .755 .354 .954 .554 .253 .953 .6
3656 .055 .655 .154 .754 .353 .953 .653 .252 .9
3755 .655 .154 .654 .153 .753 .352 .952 .652 .2
3855 .154 .654 .153 .653 .152 .752 .351 .951 .6
3954 .754 .153 .653 .152 .652 .151 .751 .350 .9
4054 .353 .753 .152 .652 .151 .651 .250 .750 .3
4153 .953 .352 .752 .151 .651 .150 .650 .249 .7
4253 .652 .952 .351 .751 .250 .650 .149 .649 .2
4353 .252 .651 .951 .350 .750 .249 .649 .148 .6

Bulletin No. 2019–48 1255 November 25, 2019
Ages363738394041424344
4452 .952 .251 .650 .950 .349 .749 .248 .648 .1
4552 .651 .951 .350 .650 .049 .348 .748 .247 .7
4652 .451 .750 .950 .349 .649 .048 .347 .847 .2
4752 .151 .450 .750 .049 .348 .648 .047 .446 .8
4851 .951 .250 .449 .749 .048 .347 .647 .046 .4
4951 .750 .950 .249 .448 .748 .047 .346 .646 .0
5051 .550 .749 .949 .248 .447 .747 .046 .345 .7
5151 .450 .549 .749 .048 .247 .546 .746 .045 .3
5251 .250 .449 .648 .848 .047 .246 .545 .745 .0
5351 .050 .249 .448 .647 .847 .046 .245 .544 .8
5450 .950 .149 .248 .447 .646 .846 .045 .344 .5
5550 .849 .949 .148 .247 .446 .645 .845 .044 .3
5650 .749 .848 .948 .147 .346 .445 .644 .844 .1
5750 .649 .748 .848 .047 .146 .345 .544 .743 .9
5850 .549 .648 .747 .847 .046 .145 .344 .543 .7
5950 .449 .548 .647 .746 .946 .045 .244 .343 .5
6050 .349 .448 .547 .646 .845 .945 .044 .243 .4
6150 .249 .348 .447 .546 .745 .844 .944 .143 .2
6250 .249 .348 .447 .546 .645 .744 .843 .943 .1
6350 .149 .248 .347 .446 .545 .644 .743 .843 .0
6450 .049 .148 .247 .346 .445 .544 .643 .742 .9
6550 .049 .148 .247 .246 .345 .444 .543 .642 .8
6650 .049 .048 .147 .246 .345 .444 .543 .642 .7
6749 .949 .048 .047 .146 .245 .344 .443 .542 .6
6849 .948 .948 .047 .146 .245 .244 .343 .442 .5
6949 .848 .948 .047 .046 .145 .244 .343 .342 .4
7049 .848 .947 .947 .046 .145 .144 .243 .342 .4
7149 .848 .847 .947 .046 .045 .144 .243 .242 .3
7249 .748 .847 .946 .946 .045 .044 .143 .242 .3
7349 .748 .847 .846 .945 .945 .044 .143 .142 .2
7449 .748 .847 .846 .945 .945 .044 .043 .142 .2
7549 .748 .747 .846 .845 .944 .944 .043 .142 .1
7649 .748 .747 .846 .845 .944 .944 .043 .042 .1
7749 .648 .747 .746 .845 .844 .943 .943 .042 .1
7849 .648 .747 .746 .845 .844 .943 .943 .042 .0
7949 .648 .747 .746 .845 .844 .943 .943 .042 .0
8049 .648 .747 .746 .745 .844 .843 .942 .942 .0
8149 .648 .647 .746 .745 .844 .843 .942 .942 .0
8249 .648 .647 .746 .745 .844 .843 .942 .942 .0
8349 .648 .647 .746 .745 .844 .843 .842 .941 .9
8449 .648 .647 .746 .745 .744 .843 .842 .941 .9
8549 .648 .647 .746 .745 .744 .843 .842 .941 .9
8649 .648 .647 .646 .745 .744 .843 .842 .941 .9
8749 .648 .647 .646 .745 .744 .843 .842 .941 .9

November 25, 2019 1256 Bulletin No. 2019–48
Ages363738394041424344
8849 .648 .647 .646 .745 .744 .843 .842 .841 .9
8949 .648 .647 .646 .745 .744 .843 .842 .841 .9
9049 .548 .647 .646 .745 .744 .843 .842 .841 .9
9149 .548 .647 .646 .745 .744 .743 .842 .841 .9
9249 .548 .647 .646 .745 .744 .743 .842 .841 .9
9349 .548 .647 .646 .745 .744 .743 .842 .841 .9
9449 .548 .647 .646 .745 .744 .743 .842 .841 .9
9549 .548 .647 .646 .745 .744 .743 .842 .841 .9
9649 .548 .647 .646 .745 .744 .743 .842 .841 .9
9749 .548 .647 .646 .745 .744 .743 .842 .841 .9
9849 .548 .647 .646 .745 .744 .743 .842 .841 .9
9949 .548 .647 .646 .745 .744 .743 .842 .841 .9
10049 .548 .647 .646 .745 .744 .743 .842 .841 .9
10149 .548 .647 .646 .745 .744 .743 .842 .841 .9
10249 .548 .647 .646 .745 .744 .743 .842 .841 .9
10349 .548 .647 .646 .745 .744 .743 .842 .841 .9
10449 .548 .647 .646 .745 .744 .743 .842 .841 .9
10549 .548 .647 .646 .745 .744 .743 .842 .841 .9
10649 .548 .647 .646 .745 .744 .743 .842 .841 .9
10749 .548 .647 .646 .745 .744 .743 .842 .841 .9
10849 .548 .647 .646 .745 .744 .743 .842 .841 .9
10949 .548 .647 .646 .645 .744 .743 .842 .841 .9
11049 .548 .647 .646 .645 .744 .743 .842 .841 .9
11149 .548 .647 .646 .645 .744 .743 .842 .841 .9
11249 .548 .647 .646 .645 .744 .743 .842 .841 .9
11349 .548 .647 .646 .645 .744 .743 .842 .841 .9
11449 .548 .647 .646 .645 .744 .743 .842 .841 .9
11549 .548 .647 .646 .645 .744 .743 .842 .841 .9
11649 .548 .647 .646 .645 .744 .743 .842 .841 .8
11749 .548 .647 .646 .645 .744 .743 .842 .841 .8
11849 .548 .647 .646 .645 .744 .743 .842 .841 .8
11949 .548 .647 .646 .645 .744 .743 .842 .841 .8
120+49 .548 .647 .646 .645 .744 .743 .842 .841 .8

Bulletin No. 2019–48 1257 November 25, 2019
Ages454647484950515253
084 .984 .984 .984 .884 .884 .884 .884 .884 .8
184 .084 .084 .083 .983 .983 .983 .983 .983 .9
283 .083 .083 .083 .083 .082 .982 .982 .982 .9
382 .182 .182 .082 .082 .082 .082 .081 .981 .9
481 .181 .181 .181 .081 .081 .081 .081 .081 .0
580 .180 .180 .180 .180 .180 .080 .080 .080 .0
679 .279 .279 .179 .179 .179 .179 .079 .079 .0
778 .278 .278 .278 .178 .178 .178 .178 .078 .0
877 .377 .277 .277 .277 .177 .177 .177 .177 .1
976 .376 .376 .276 .276 .276 .176 .176 .176 .1
1075 .375 .375 .375 .275 .275 .275 .275 .175 .1
1174 .474 .374 .374 .374 .274 .274 .274 .274 .1
1273 .473 .473 .373 .373 .373 .273 .273 .273 .2
1372 .572 .472 .472 .372 .372 .372 .272 .272 .2
1471 .571 .571 .471 .471 .471 .371 .371 .371 .2
1570 .670 .570 .570 .470 .470 .470 .370 .370 .3
1669 .669 .669 .569 .569 .469 .469 .469 .369 .3
1768 .768 .768 .668 .568 .568 .568 .468 .468 .3
1867 .867 .767 .767 .667 .667 .567 .567 .467 .4
1966 .966 .866 .766 .766 .666 .666 .566 .566 .4
2066 .065 .965 .865 .765 .765 .665 .665 .565 .5
2165 .065 .064 .964 .864 .864 .764 .664 .664 .5
2264 .164 .164 .063 .963 .863 .863 .763 .763 .6
2363 .363 .263 .163 .062 .962 .862 .862 .762 .7
2462 .462 .362 .262 .162 .061 .961 .961 .861 .7
2561 .561 .461 .361 .261 .161 .060 .960 .960 .8
2660 .660 .560 .460 .360 .260 .160 .060 .059 .9
2759 .859 .659 .559 .459 .359 .259 .159 .059 .0
2858 .958 .858 .658 .558 .458 .358 .258 .158 .1
2958 .157 .957 .857 .757 .557 .457 .357 .257 .2
3057 .357 .156 .956 .856 .756 .656 .556 .456 .3
3156 .456 .356 .156 .055 .855 .755 .655 .555 .4
3255 .755 .555 .355 .155 .054 .854 .754 .654 .5
3354 .954 .754 .554 .354 .154 .053 .953 .753 .6
3454 .153 .953 .753 .553 .353 .253 .052 .952 .7
3553 .453 .152 .952 .752 .552 .352 .252 .051 .9
3652 .652 .452 .151 .951 .751 .551 .451 .251 .0
3751 .951 .751 .451 .250 .950 .750 .550 .450 .2
3851 .350 .950 .750 .450 .249 .949 .749 .649 .4
3950 .650 .350 .049 .749 .449 .249 .048 .848 .6
4050 .049 .649 .349 .048 .748 .448 .248 .047 .8
4149 .349 .048 .648 .348 .047 .747 .547 .247 .0
4248 .748 .348 .047 .647 .347 .046 .746 .546 .2
4348 .247 .847 .447 .046 .646 .346 .045 .745 .5

November 25, 2019 1258 Bulletin No. 2019–48
Ages454647484950515253
4447 .747 .246 .846 .446 .045 .745 .345 .044 .8
4547 .146 .746 .245 .845 .445 .044 .744 .444 .1
4646 .746 .245 .745 .244 .844 .444 .043 .743 .4
4746 .245 .745 .244 .744 .243 .843 .443 .142 .7
4845 .845 .244 .744 .243 .743 .342 .842 .442 .1
4945 .444 .844 .243 .743 .242 .742 .341 .941 .5
5045 .044 .443 .843 .342 .742 .241 .741 .340 .9
5144 .744 .043 .442 .842 .341 .741 .240 .840 .3
5244 .443 .743 .142 .441 .941 .340 .840 .339 .8
5344 .143 .442 .742 .141 .540 .940 .339 .839 .3
5443 .843 .142 .441 .741 .140 .539 .939 .338 .8
5543 .542 .842 .141 .440 .840 .139 .538 .938 .4
5643 .342 .541 .841 .140 .439 .839 .138 .538 .0
5743 .142 .341 .640 .840 .139 .538 .838 .237 .6
5842 .942 .141 .340 .639 .939 .238 .537 .837 .2
5942 .741 .941 .140 .439 .638 .938 .237 .536 .9
6042 .541 .740 .940 .139 .438 .637 .937 .236 .6
6142 .441 .640 .740 .039 .238 .437 .737 .036 .3
6242 .241 .440 .639 .839 .038 .237 .536 .736 .0
6342 .141 .340 .439 .638 .838 .037 .236 .535 .8
6442 .041 .140 .339 .538 .637 .837 .036 .335 .5
6541 .941 .040 .239 .338 .537 .736 .936 .135 .3
6641 .840 .940 .039 .238 .437 .536 .735 .935 .1
6741 .740 .839 .939 .138 .237 .436 .635 .735 .0
6841 .640 .739 .839 .038 .137 .336 .435 .634 .8
6941 .540 .639 .838 .938 .037 .136 .335 .534 .6
7041 .540 .639 .738 .837 .937 .036 .235 .334 .5
7141 .440 .539 .638 .737 .836 .936 .135 .234 .4
7241 .340 .439 .538 .637 .736 .936 .035 .134 .3
7341 .340 .439 .538 .637 .736 .835 .935 .034 .2
7441 .240 .339 .438 .537 .636 .735 .834 .934 .1
7541 .240 .339 .438 .437 .536 .635 .734 .934 .0
7641 .240 .239 .338 .437 .536 .635 .734 .833 .9
7741 .140 .239 .338 .437 .436 .535 .634 .733 .9
7841 .140 .239 .238 .337 .436 .535 .634 .733 .8
7941 .140 .139 .238 .337 .436 .435 .534 .633 .7
8041 .140 .139 .238 .237 .336 .435 .534 .633 .7
8141 .040 .139 .138 .237 .336 .435 .434 .533 .6
8241 .040 .139 .138 .237 .336 .335 .434 .533 .6
8341 .040 .039 .138 .237 .236 .335 .434 .533 .6
8441 .040 .039 .138 .137 .236 .335 .434 .433 .5
8541 .040 .039 .138 .137 .236 .335 .334 .433 .5
8641 .040 .039 .138 .137 .236 .235 .334 .433 .5
8740 .940 .039 .038 .137 .236 .235 .334 .433 .5

Bulletin No. 2019–48 1259 November 25, 2019
Ages454647484950515253
8840 .940 .039 .038 .137 .136 .235 .334 .433 .4
8940 .940 .039 .038 .137 .136 .235 .334 .333 .4
9040 .940 .039 .038 .137 .136 .235 .334 .333 .4
9140 .940 .039 .038 .137 .136 .235 .234 .333 .4
9240 .940 .039 .038 .137 .136 .235 .234 .333 .4
9340 .940 .039 .038 .137 .136 .235 .234 .333 .4
9440 .940 .039 .038 .137 .136 .235 .234 .333 .4
9540 .940 .039 .038 .037 .136 .235 .234 .333 .4
9640 .939 .939 .038 .037 .136 .235 .234 .333 .4
9740 .939 .939 .038 .037 .136 .235 .234 .333 .4
9840 .939 .939 .038 .037 .136 .135 .234 .333 .4
9940 .939 .939 .038 .037 .136 .135 .234 .333 .3
10040 .939 .939 .038 .037 .136 .135 .234 .333 .3
10140 .939 .939 .038 .037 .136 .135 .234 .333 .3
10240 .939 .939 .038 .037 .136 .135 .234 .333 .3
10340 .939 .939 .038 .037 .136 .135 .234 .333 .3
10440 .939 .939 .038 .037 .136 .135 .234 .333 .3
10540 .939 .939 .038 .037 .136 .135 .234 .333 .3
10640 .939 .939 .038 .037 .136 .135 .234 .333 .3
10740 .939 .939 .038 .037 .136 .135 .234 .333 .3
10840 .939 .939 .038 .037 .136 .135 .234 .333 .3
10940 .939 .939 .038 .037 .136 .135 .234 .333 .3
11040 .939 .939 .038 .037 .136 .135 .234 .333 .3
11140 .939 .939 .038 .037 .136 .135 .234 .333 .3
11240 .939 .939 .038 .037 .136 .135 .234 .333 .3
11340 .939 .939 .038 .037 .136 .135 .234 .333 .3
11440 .939 .939 .038 .037 .136 .135 .234 .333 .3
11540 .939 .939 .038 .037 .136 .135 .234 .333 .3
11640 .939 .939 .038 .037 .136 .135 .234 .333 .3
11740 .939 .939 .038 .037 .136 .135 .234 .333 .3
11840 .939 .939 .038 .037 .136 .135 .234 .333 .3
11940 .939 .939 .038 .037 .136 .135 .234 .333 .3
120+40 .939 .939 .038 .037 .136 .135 .234 .333 .3

November 25, 2019 1260 Bulletin No. 2019–48
Ages545556575859606162
084 .784 .784 .784 .784 .784 .784 .784 .784 .7
183 .983 .883 .883 .883 .883 .883 .883 .883 .8
282 .982 .982 .982 .982 .882 .882 .882 .882 .8
381 .981 .981 .981 .981 .981 .981 .881 .881 .8
480 .980 .980 .980 .980 .980 .980 .980 .980 .9
580 .079 .979 .979 .979 .979 .979 .979 .979 .9
679 .079 .079 .078 .978 .978 .978 .978 .978 .9
778 .078 .078 .078 .078 .077 .977 .977 .977 .9
877 .077 .077 .077 .077 .077 .076 .976 .976 .9
976 .176 .076 .076 .076 .076 .076 .076 .075 .9
1075 .175 .175 .075 .075 .075 .075 .075 .075 .0
1174 .174 .174 .174 .174 .074 .074 .074 .074 .0
1273 .173 .173 .173 .173 .173 .073 .073 .073 .0
1372 .272 .172 .172 .172 .172 .172 .172 .072 .0
1471 .271 .271 .271 .171 .171 .171 .171 .171 .0
1570 .270 .270 .270 .270 .170 .170 .170 .170 .1
1669 .369 .269 .269 .269 .269 .269 .169 .169 .1
1768 .368 .368 .368 .268 .268 .268 .268 .168 .1
1867 .467 .367 .367 .367 .267 .267 .267 .267 .2
1966 .466 .466 .366 .366 .366 .366 .266 .266 .2
2065 .465 .465 .465 .365 .365 .365 .365 .265 .2
2164 .564 .564 .464 .464 .464 .364 .364 .364 .3
2263 .663 .563 .563 .463 .463 .463 .363 .363 .3
2362 .662 .662 .562 .562 .562 .462 .462 .462 .3
2461 .761 .661 .661 .561 .561 .561 .461 .461 .4
2560 .760 .760 .660 .660 .660 .560 .560 .560 .4
2659 .859 .859 .759 .759 .659 .659 .559 .559 .5
2758 .958 .858 .858 .758 .758 .658 .658 .658 .5
2858 .057 .957 .957 .857 .757 .757 .757 .657 .6
2957 .157 .056 .956 .956 .856 .856 .756 .756 .6
3056 .256 .156 .056 .055 .955 .855 .855 .755 .7
3155 .355 .255 .155 .055 .054 .954 .954 .854 .8
3254 .454 .354 .254 .154 .154 .053 .953 .953 .8
3353 .553 .453 .353 .253 .253 .153 .053 .052 .9
3452 .652 .552 .452 .352 .352 .252 .152 .152 .0
3551 .851 .751 .651 .551 .451 .351 .251 .151 .1
3650 .950 .850 .750 .650 .550 .450 .350 .250 .2
3750 .149 .949 .849 .749 .649 .549 .449 .349 .3
3849 .249 .148 .948 .848 .748 .648 .548 .448 .4
3948 .448 .248 .148 .047 .847 .747 .647 .547 .5
4047 .647 .447 .347 .147 .046 .946 .846 .746 .6
4146 .846 .646 .446 .346 .146 .045 .945 .845 .7
4246 .045 .845 .645 .545 .345 .245 .044 .944 .8
4345 .345 .044 .844 .744 .544 .344 .244 .143 .9

Bulletin No. 2019–48 1261 November 25, 2019
Ages545556575859606162
4444 .544 .344 .143 .943 .743 .543 .443 .243 .1
4543 .843 .543 .343 .142 .942 .742 .542 .442 .2
4643 .142 .842 .542 .342 .141 .941 .741 .641 .4
4742 .442 .141 .841 .641 .341 .140 .940 .740 .6
4841 .741 .441 .140 .840 .640 .440 .140 .039 .8
4941 .140 .840 .440 .139 .939 .639 .439 .239 .0
5040 .540 .139 .839 .539 .238 .938 .638 .438 .2
5139 .939 .539 .138 .838 .538 .237 .937 .737 .5
5239 .338 .938 .538 .237 .837 .537 .237 .036 .7
5338 .838 .438 .037 .637 .236 .936 .636 .336 .0
5438 .337 .937 .437 .036 .636 .235 .935 .635 .3
5537 .937 .436 .936 .436 .035 .635 .334 .934 .6
5637 .436 .936 .435 .935 .535 .134 .734 .334 .0
5737 .036 .435 .935 .435 .034 .534 .133 .733 .4
5836 .636 .035 .535 .034 .534 .033 .633 .232 .8
5936 .235 .635 .134 .534 .033 .533 .132 .632 .2
6035 .935 .334 .734 .133 .633 .132 .632 .131 .7
6135 .634 .934 .333 .733 .232 .632 .131 .631 .2
6235 .334 .634 .033 .432 .832 .231 .731 .230 .7
6335 .034 .433 .733 .032 .431 .831 .330 .730 .2
6434 .834 .133 .432 .732 .131 .530 .930 .329 .8
6534 .633 .833 .132 .531 .831 .230 .530 .029 .4
6634 .433 .632 .932 .231 .530 .930 .229 .629 .0
6734 .233 .432 .732 .031 .330 .629 .929 .328 .7
6834 .033 .232 .531 .731 .030 .329 .629 .028 .4
6933 .833 .132 .331 .530 .830 .129 .428 .728 .1
7033 .732 .932 .131 .330 .629 .929 .128 .527 .8
7133 .632 .732 .031 .230 .429 .728 .928 .227 .5
7233 .432 .631 .831 .030 .229 .528 .728 .027 .3
7333 .332 .531 .730 .930 .129 .328 .627 .827 .1
7433 .232 .431 .630 .729 .929 .228 .427 .626 .9
7533 .132 .331 .530 .629 .829 .028 .227 .526 .7
7633 .132 .231 .430 .529 .728 .928 .127 .326 .6
7733 .032 .131 .330 .429 .628 .828 .027 .226 .4
7832 .932 .031 .230 .329 .528 .727 .927 .126 .3
7932 .932 .031 .130 .329 .428 .627 .827 .026 .2
8032 .831 .931 .130 .229 .328 .527 .726 .926 .1
8132 .731 .931 .030 .129 .328 .427 .626 .826 .0
8232 .731 .830 .930 .129 .228 .427 .526 .725 .9
8332 .731 .830 .930 .029 .228 .327 .526 .725 .8
8432 .631 .730 .930 .029 .128 .327 .426 .625 .8
8532 .631 .730 .829 .929 .128 .227 .426 .525 .7
8632 .631 .730 .829 .929 .028 .227 .326 .525 .7
8732 .631 .730 .829 .929 .028 .227 .326 .525 .6

November 25, 2019 1262 Bulletin No. 2019–48
Ages545556575859606162
8832 .531 .630 .729 .929 .028 .127 .326 .425 .6
8932 .531 .630 .729 .829 .028 .127 .226 .425 .5
9032 .531 .630 .729 .828 .928 .127 .226 .425 .5
9132 .531 .630 .729 .828 .928 .127 .226 .325 .5
9232 .531 .630 .729 .828 .928 .027 .226 .325 .5
9332 .531 .630 .729 .828 .928 .027 .226 .325 .5
9432 .531 .630 .729 .828 .928 .027 .126 .325 .4
9532 .531 .530 .629 .828 .928 .027 .126 .325 .4
9632 .431 .530 .629 .728 .928 .027 .126 .325 .4
9732 .431 .530 .629 .728 .928 .027 .126 .325 .4
9832 .431 .530 .629 .728 .828 .027 .126 .225 .4
9932 .431 .530 .629 .728 .828 .027 .126 .225 .4
10032 .431 .530 .629 .728 .828 .027 .126 .225 .4
10132 .431 .530 .629 .728 .828 .027 .126 .225 .4
10232 .431 .530 .629 .728 .828 .027 .126 .225 .4
10332 .431 .530 .629 .728 .827 .927 .126 .225 .4
10432 .431 .530 .629 .728 .827 .927 .126 .225 .4
10532 .431 .530 .629 .728 .827 .927 .126 .225 .4
10632 .431 .530 .629 .728 .827 .927 .126 .225 .4
10732 .431 .530 .629 .728 .827 .927 .126 .225 .4
10832 .431 .530 .629 .728 .827 .927 .126 .225 .4
10932 .431 .530 .629 .728 .827 .927 .126 .225 .4
11032 .431 .530 .629 .728 .827 .927 .126 .225 .4
11132 .431 .530 .629 .728 .827 .927 .126 .225 .4
11232 .431 .530 .629 .728 .827 .927 .126 .225 .4
11332 .431 .530 .629 .728 .827 .927 .126 .225 .4
11432 .431 .530 .629 .728 .827 .927 .126 .225 .4
11532 .431 .530 .629 .728 .827 .927 .126 .225 .4
11632 .431 .530 .629 .728 .827 .927 .126 .225 .3
11732 .431 .530 .629 .728 .827 .927 .126 .225 .3
11832 .431 .530 .629 .728 .827 .927 .126 .225 .3
11932 .431 .530 .629 .728 .827 .927 .126 .225 .3
120+32 .431 .530 .629 .728 .827 .927 .126 .225 .3

Bulletin No. 2019–48 1263 November 25, 2019
Ages636465666768697071
084 .684 .684 .684 .684 .684 .684 .684 .684 .6
183 .883 .883 .883 .783 .783 .783 .783 .783 .7
282 .882 .882 .882 .882 .882 .882 .882 .882 .8
381 .881 .881 .881 .881 .881 .881 .881 .881 .8
480 .880 .880 .880 .880 .880 .880 .880 .880 .8
579 .979 .979 .879 .879 .879 .879 .879 .879 .8
678 .978 .978 .978 .978 .878 .878 .878 .878 .8
777 .977 .977 .977 .977 .977 .977 .977 .877 .8
876 .976 .976 .976 .976 .976 .976 .976 .976 .9
975 .975 .975 .975 .975 .975 .975 .975 .975 .9
1075 .074 .974 .974 .974 .974 .974 .974 .974 .9
1174 .074 .073 .973 .973 .973 .973 .973 .973 .9
1273 .073 .073 .073 .072 .972 .972 .972 .972 .9
1372 .072 .072 .072 .072 .072 .071 .971 .971 .9
1471 .071 .071 .071 .071 .071 .071 .071 .070 .9
1570 .170 .070 .070 .070 .070 .070 .070 .070 .0
1669 .169 .169 .169 .069 .069 .069 .069 .069 .0
1768 .168 .168 .168 .168 .168 .068 .068 .068 .0
1867 .167 .167 .167 .167 .167 .167 .167 .067 .0
1966 .266 .266 .166 .166 .166 .166 .166 .166 .1
2065 .265 .265 .265 .265 .165 .165 .165 .165 .1
2164 .264 .264 .264 .264 .264 .264 .164 .164 .1
2263 .363 .363 .263 .263 .263 .263 .263 .263 .1
2362 .362 .362 .362 .262 .262 .262 .262 .262 .2
2461 .461 .361 .361 .361 .361 .361 .261 .261 .2
2560 .460 .460 .360 .360 .360 .360 .360 .360 .2
2659 .459 .459 .459 .459 .359 .359 .359 .359 .3
2758 .558 .558 .458 .458 .458 .458 .458 .358 .3
2857 .557 .557 .557 .557 .457 .457 .457 .457 .4
2956 .656 .656 .556 .556 .556 .556 .456 .456 .4
3055 .755 .655 .655 .655 .555 .555 .555 .555 .5
3154 .754 .754 .754 .654 .654 .654 .554 .554 .5
3253 .853 .853 .753 .753 .753 .653 .653 .653 .6
3352 .952 .852 .852 .752 .752 .752 .752 .652 .6
3451 .951 .951 .951 .851 .851 .751 .751 .751 .7
3551 .051 .050 .950 .950 .850 .850 .850 .750 .7
3650 .150 .050 .050 .049 .949 .949 .849 .849 .8
3749 .249 .149 .149 .049 .048 .948 .948 .948 .8
3848 .348 .248 .248 .148 .048 .048 .047 .947 .9
3947 .447 .347 .247 .247 .147 .147 .047 .047 .0
4046 .546 .446 .346 .346 .246 .246 .146 .146 .0
4145 .645 .545 .445 .445 .345 .245 .245 .145 .1
4244 .744 .644 .544 .544 .444 .344 .344 .244 .2
4343 .843 .743 .643 .643 .543 .443 .343 .343 .2

November 25, 2019 1264 Bulletin No. 2019–48
Ages636465666768697071
4443 .042 .942 .842 .742 .642 .542 .442 .442 .3
4542 .142 .041 .941 .841 .741 .641 .541 .541 .4
4641 .341 .141 .040 .940 .840 .740 .640 .640 .5
4740 .440 .340 .240 .039 .939 .839 .839 .739 .6
4839 .639 .539 .339 .239 .139 .038 .938 .838 .7
4938 .838 .638 .538 .438 .238 .138 .037 .937 .8
5038 .037 .837 .737 .537 .437 .337 .137 .036 .9
5137 .237 .036 .936 .736 .636 .436 .336 .236 .1
5236 .536 .336 .135 .935 .735 .635 .535 .335 .2
5335 .835 .535 .335 .135 .034 .834 .634 .534 .4
5435 .034 .834 .634 .434 .234 .033 .833 .733 .6
5534 .434 .133 .833 .633 .433 .233 .132 .932 .7
5633 .733 .433 .132 .932 .732 .532 .332 .132 .0
5733 .032 .732 .532 .232 .031 .731 .531 .331 .2
5832 .432 .131 .831 .531 .331 .030 .830 .630 .4
5931 .831 .531 .230 .930 .630 .330 .129 .929 .7
6031 .330 .930 .530 .229 .929 .629 .429 .128 .9
6130 .730 .330 .029 .629 .329 .028 .728 .528 .2
6230 .229 .829 .429 .028 .728 .428 .127 .827 .5
6329 .829 .328 .928 .528 .127 .827 .427 .126 .9
6429 .328 .828 .428 .027 .627 .226 .826 .526 .2
6528 .928 .427 .927 .427 .026 .626 .325 .925 .6
6628 .528 .027 .427 .026 .526 .125 .725 .425 .0
6728 .127 .627 .026 .526 .125 .625 .224 .824 .4
6827 .827 .226 .626 .125 .625 .124 .724 .323 .9
6927 .426 .826 .325 .725 .224 .724 .223 .823 .4
7027 .126 .525 .925 .424 .824 .323 .823 .322 .9
7126 .926 .225 .625 .024 .423 .923 .422 .922 .4
7226 .626 .025 .324 .724 .123 .523 .022 .522 .0
7326 .425 .725 .024 .423 .823 .222 .622 .121 .6
7426 .225 .524 .824 .123 .522 .922 .321 .721 .2
7526 .025 .324 .623 .923 .222 .622 .021 .420 .8
7625 .825 .124 .423 .723 .022 .421 .721 .120 .5
7725 .724 .924 .223 .522 .822 .121 .520 .820 .2
7825 .524 .824 .023 .322 .621 .921 .220 .620 .0
7925 .424 .623 .923 .222 .421 .721 .020 .419 .7
8025 .324 .523 .823 .022 .321 .620 .920 .219 .5
8125 .224 .423 .622 .922 .121 .420 .720 .019 .3
8225 .124 .323 .522 .822 .021 .320 .519 .819 .1
8325 .024 .223 .422 .721 .921 .220 .419 .719 .0
8425 .024 .223 .422 .621 .821 .020 .319 .618 .8
8524 .924 .123 .322 .521 .721 .020 .219 .418 .7
8624 .824 .023 .222 .421 .720 .920 .119 .318 .6
8724 .824 .023 .222 .421 .620 .820 .019 .318 .5

Bulletin No. 2019–48 1265 November 25, 2019
Ages636465666768697071
8824 .823 .923 .122 .321 .520 .720 .019 .218 .4
8924 .723 .923 .122 .321 .520 .719 .919 .118 .4
9024 .723 .923 .022 .221 .420 .619 .919 .118 .3
9124 .723 .823 .022 .221 .420 .619 .819 .018 .3
9224 .623 .823 .022 .221 .420 .619 .819 .018 .2
9324 .623 .823 .022 .221 .320 .519 .718 .918 .2
9424 .623 .822 .922 .121 .320 .519 .718 .918 .1
9524 .623 .822 .922 .121 .320 .519 .718 .918 .1
9624 .623 .722 .922 .121 .320 .519 .718 .918 .1
9724 .623 .722 .922 .121 .320 .519 .718 .918 .1
9824 .623 .722 .922 .121 .320 .419 .618 .818 .0
9924 .523 .722 .922 .121 .220 .419 .618 .818 .0
10024 .523 .722 .922 .121 .220 .419 .618 .818 .0
10124 .523 .722 .922 .021 .220 .419 .618 .818 .0
10224 .523 .722 .922 .021 .220 .419 .618 .818 .0
10324 .523 .722 .922 .021 .220 .419 .618 .818 .0
10424 .523 .722 .922 .021 .220 .419 .618 .818 .0
10524 .523 .722 .922 .021 .220 .419 .618 .818 .0
10624 .523 .722 .922 .021 .220 .419 .618 .818 .0
10724 .523 .722 .822 .021 .220 .419 .618 .818 .0
10824 .523 .722 .822 .021 .220 .419 .618 .818 .0
10924 .523 .722 .822 .021 .220 .419 .618 .818 .0
11024 .523 .722 .822 .021 .220 .419 .618 .818 .0
11124 .523 .722 .822 .021 .220 .419 .618 .818 .0
11224 .523 .722 .822 .021 .220 .419 .618 .818 .0
11324 .523 .722 .822 .021 .220 .419 .618 .818 .0
11424 .523 .722 .822 .021 .220 .419 .618 .818 .0
11524 .523 .722 .822 .021 .220 .419 .618 .818 .0
11624 .523 .722 .822 .021 .220 .419 .618 .818 .0
11724 .523 .722 .822 .021 .220 .419 .618 .717 .9
11824 .523 .722 .822 .021 .220 .419 .618 .717 .9
11924 .523 .622 .822 .021 .220 .419 .518 .717 .9
120+24 .523 .622 .822 .021 .220 .419 .518 .717 .9

November 25, 2019 1266 Bulletin No. 2019–48
Ages727374757677787980
084 .684 .684 .684 .684 .684 .684 .684 .684 .6
183 .783 .783 .783 .783 .783 .783 .783 .783 .7
282 .882 .782 .782 .782 .782 .782 .782 .782 .7
381 .881 .881 .881 .881 .881 .881 .881 .881 .8
480 .880 .880 .880 .880 .880 .880 .880 .880 .8
579 .879 .879 .879 .879 .879 .879 .879 .879 .8
678 .878 .878 .878 .878 .878 .878 .878 .878 .8
777 .877 .877 .877 .877 .877 .877 .877 .877 .8
876 .976 .876 .876 .876 .876 .876 .876 .876 .8
975 .975 .975 .975 .975 .875 .875 .875 .875 .8
1074 .974 .974 .974 .974 .974 .974 .974 .874 .8
1173 .973 .973 .973 .973 .973 .973 .973 .973 .9
1272 .972 .972 .972 .972 .972 .972 .972 .972 .9
1371 .971 .971 .971 .971 .971 .971 .971 .971 .9
1470 .970 .970 .970 .970 .970 .970 .970 .970 .9
1570 .070 .069 .969 .969 .969 .969 .969 .969 .9
1669 .069 .069 .069 .068 .968 .968 .968 .968 .9
1768 .068 .068 .068 .068 .068 .068 .068 .067 .9
1867 .067 .067 .067 .067 .067 .067 .067 .067 .0
1966 .166 .066 .066 .066 .066 .066 .066 .066 .0
2065 .165 .165 .165 .065 .065 .065 .065 .065 .0
2164 .164 .164 .164 .164 .164 .164 .164 .064 .0
2263 .163 .163 .163 .163 .163 .163 .163 .163 .1
2362 .262 .162 .162 .162 .162 .162 .162 .162 .1
2461 .261 .261 .261 .261 .261 .161 .161 .161 .1
2560 .260 .260 .260 .260 .260 .260 .260 .260 .2
2659 .359 .359 .259 .259 .259 .259 .259 .259 .2
2758 .358 .358 .358 .358 .358 .258 .258 .258 .2
2857 .357 .357 .357 .357 .357 .357 .357 .357 .3
2956 .456 .456 .456 .356 .356 .356 .356 .356 .3
3055 .455 .455 .455 .455 .455 .455 .455 .455 .3
3154 .554 .554 .554 .454 .454 .454 .454 .454 .4
3253 .553 .553 .553 .553 .553 .553 .453 .453 .4
3352 .652 .652 .552 .552 .552 .552 .552 .552 .5
3451 .651 .651 .651 .651 .651 .651 .551 .551 .5
3550 .750 .750 .650 .650 .650 .650 .650 .650 .6
3649 .749 .749 .749 .749 .749 .649 .649 .649 .6
3748 .848 .848 .848 .748 .748 .748 .748 .748 .7
3847 .947 .847 .847 .847 .847 .747 .747 .747 .7
3946 .946 .946 .946 .846 .846 .846 .846 .846 .7
4046 .045 .945 .945 .945 .945 .845 .845 .845 .8
4145 .045 .045 .044 .944 .944 .944 .944 .944 .8
4244 .144 .144 .044 .044 .043 .943 .943 .943 .9
4343 .243 .143 .143 .143 .043 .043 .043 .042 .9

Bulletin No. 2019–48 1267 November 25, 2019
Ages727374757677787980
4442 .342 .242 .242 .142 .142 .142 .042 .042 .0
4541 .341 .341 .241 .241 .241 .141 .141 .141 .1
4640 .440 .440 .340 .340 .240 .240 .240 .140 .1
4739 .539 .539 .439 .439 .339 .339 .239 .239 .2
4838 .638 .638 .538 .438 .438 .438 .338 .338 .2
4937 .737 .737 .637 .537 .537 .437 .437 .437 .3
5036 .936 .836 .736 .636 .636 .536 .536 .436 .4
5136 .035 .935 .835 .735 .735 .635 .635 .535 .5
5235 .135 .034 .934 .934 .834 .734 .734 .634 .6
5334 .334 .234 .134 .033 .933 .933 .833 .733 .7
5433 .433 .333 .233 .133 .133 .032 .932 .932 .8
5532 .632 .532 .432 .332 .232 .132 .032 .031 .9
5631 .831 .731 .631 .531 .431 .331 .231 .131 .1
5731 .030 .930 .730 .630 .530 .430 .330 .330 .2
5830 .230 .129 .929 .829 .729 .629 .529 .429 .3
5929 .529 .329 .229 .028 .928 .828 .728 .628 .5
6028 .728 .628 .428 .228 .128 .027 .927 .827 .7
6128 .027 .827 .627 .527 .327 .227 .127 .026 .9
6227 .327 .126 .926 .726 .626 .426 .326 .226 .1
6326 .626 .426 .226 .025 .825 .725 .525 .425 .3
6426 .025 .725 .525 .325 .124 .924 .824 .624 .5
6525 .325 .024 .824 .624 .424 .224 .023 .923 .8
6624 .724 .424 .123 .923 .723 .523 .323 .223 .0
6724 .123 .823 .523 .223 .022 .822 .622 .422 .3
6823 .523 .222 .922 .622 .422 .121 .921 .721 .6
6923 .022 .622 .322 .021 .721 .521 .221 .020 .9
7022 .522 .121 .721 .421 .120 .820 .620 .420 .2
7122 .021 .621 .220 .820 .520 .220 .019 .719 .5
7221 .521 .120 .720 .320 .019 .619 .419 .118 .9
7321 .120 .620 .219 .819 .419 .118 .818 .518 .2
7420 .720 .219 .719 .318 .918 .618 .217 .917 .6
7520 .319 .819 .318 .918 .518 .117 .717 .417 .1
7620 .019 .418 .918 .518 .017 .617 .216 .916 .5
7719 .619 .118 .618 .117 .617 .216 .816 .416 .0
7819 .418 .818 .217 .717 .216 .816 .315 .915 .6
7919 .118 .517 .917 .416 .916 .415 .915 .515 .1
8018 .918 .217 .617 .116 .516 .015 .615 .114 .7
8118 .618 .017 .416 .816 .215 .715 .214 .714 .3
8218 .417 .817 .216 .616 .015 .414 .914 .414 .0
8318 .317 .617 .016 .315 .715 .214 .614 .113 .6
8418 .117 .416 .816 .115 .514 .914 .413 .813 .3
8518 .017 .316 .616 .015 .314 .714 .113 .613 .1
8617 .917 .216 .515 .815 .214 .513 .913 .412 .8
8717 .817 .116 .415 .715 .014 .413 .813 .212 .6

November 25, 2019 1268 Bulletin No. 2019–48
Ages727374757677787980
8817 .717 .016 .215 .614 .914 .213 .613 .012 .4
8917 .616 .916 .215 .414 .814 .113 .512 .912 .3
9017 .516 .816 .115 .414 .714 .013 .412 .712 .1
9117 .516 .716 .015 .314 .613 .913 .212 .612 .0
9217 .416 .715 .915 .214 .513 .813 .212 .511 .9
9317 .416 .615 .915 .214 .413 .713 .112 .411 .8
9417 .416 .615 .815 .114 .413 .713 .012 .411 .7
9517 .316 .615 .815 .114 .313 .612 .912 .311 .6
9617 .316 .515 .815 .014 .313 .612 .912 .211 .6
9717 .316 .515 .715 .014 .313 .512 .912 .211 .5
9817 .316 .515 .715 .014 .213 .512 .812 .111 .5
9917 .216 .515 .714 .914 .213 .512 .812 .111 .4
10017 .216 .415 .714 .914 .213 .512 .812 .111 .4
10117 .216 .415 .714 .914 .213 .412 .712 .011 .4
10217 .216 .415 .714 .914 .213 .412 .712 .011 .4
10317 .216 .415 .614 .914 .113 .412 .712 .011 .3
10417 .216 .415 .614 .914 .113 .412 .712 .011 .3
10517 .216 .415 .614 .914 .113 .412 .712 .011 .3
10617 .216 .415 .614 .914 .113 .412 .712 .011 .3
10717 .216 .415 .614 .914 .113 .412 .712 .011 .3
10817 .216 .415 .614 .914 .113 .412 .712 .011 .3
10917 .216 .415 .614 .914 .113 .412 .712 .011 .3
11017 .216 .415 .614 .914 .113 .412 .712 .011 .3
11117 .216 .415 .614 .914 .113 .412 .712 .011 .3
11217 .216 .415 .614 .914 .113 .412 .712 .011 .3
11317 .216 .415 .614 .914 .113 .412 .712 .011 .3
11417 .216 .415 .614 .814 .113 .412 .612 .011 .3
11517 .216 .415 .614 .814 .113 .412 .611 .911 .3
11617 .216 .415 .614 .814 .113 .312 .611 .911 .3
11717 .116 .415 .614 .814 .113 .312 .611 .911 .2
11817 .116 .415 .614 .814 .113 .312 .611 .911 .2
11917 .116 .315 .614 .814 .013 .312 .611 .911 .2
120+17 .116 .315 .614 .814 .013 .312 .611 .911 .2

Bulletin No. 2019–48 1269 November 25, 2019
Ages818283848586878889
084 .684 .684 .684 .684 .684 .584 .584 .584 .5
183 .783 .783 .783 .783 .783 .783 .783 .783 .7
282 .782 .782 .782 .782 .782 .782 .782 .782 .7
381 .881 .781 .781 .781 .781 .781 .781 .781 .7
480 .880 .880 .880 .880 .880 .880 .880 .880 .8
579 .879 .879 .879 .879 .879 .879 .879 .879 .8
678 .878 .878 .878 .878 .878 .878 .878 .878 .8
777 .877 .877 .877 .877 .877 .877 .877 .877 .8
876 .876 .876 .876 .876 .876 .876 .876 .876 .8
975 .875 .875 .875 .875 .875 .875 .875 .875 .8
1074 .874 .874 .874 .874 .874 .874 .874 .874 .8
1173 .973 .973 .973 .873 .873 .873 .873 .873 .8
1272 .972 .972 .972 .972 .972 .972 .972 .972 .9
1371 .971 .971 .971 .971 .971 .971 .971 .971 .9
1470 .970 .970 .970 .970 .970 .970 .970 .970 .9
1569 .969 .969 .969 .969 .969 .969 .969 .969 .9
1668 .968 .968 .968 .968 .968 .968 .968 .968 .9
1767 .967 .967 .967 .967 .967 .967 .967 .967 .9
1867 .067 .067 .067 .067 .067 .066 .966 .966 .9
1966 .066 .066 .066 .066 .066 .066 .066 .066 .0
2065 .065 .065 .065 .065 .065 .065 .065 .065 .0
2164 .064 .064 .064 .064 .064 .064 .064 .064 .0
2263 .163 .163 .063 .063 .063 .063 .063 .063 .0
2362 .162 .162 .162 .162 .162 .162 .162 .162 .1
2461 .161 .161 .161 .161 .161 .161 .161 .161 .1
2560 .160 .160 .160 .160 .160 .160 .160 .160 .1
2659 .259 .259 .259 .259 .259 .259 .159 .159 .1
2758 .258 .258 .258 .258 .258 .258 .258 .258 .2
2857 .357 .257 .257 .257 .257 .257 .257 .257 .2
2956 .356 .356 .356 .356 .356 .356 .356 .356 .3
3055 .355 .355 .355 .355 .355 .355 .355 .355 .3
3154 .454 .454 .454 .454 .454 .354 .354 .354 .3
3253 .453 .453 .453 .453 .453 .453 .453 .453 .4
3352 .552 .552 .552 .452 .452 .452 .452 .452 .4
3451 .551 .551 .551 .551 .551 .551 .551 .551 .5
3550 .650 .550 .550 .550 .550 .550 .550 .550 .5
3649 .649 .649 .649 .649 .649 .649 .649 .649 .6
3748 .648 .648 .648 .648 .648 .648 .648 .648 .6
3847 .747 .747 .747 .747 .747 .647 .647 .647 .6
3946 .746 .746 .746 .746 .746 .746 .746 .746 .7
4045 .845 .845 .845 .745 .745 .745 .745 .745 .7
4144 .844 .844 .844 .844 .844 .844 .844 .844 .8
4243 .943 .943 .843 .843 .843 .843 .843 .843 .8
4342 .942 .942 .942 .942 .942 .942 .942 .842 .8

November 25, 2019 1270 Bulletin No. 2019–48
Ages818283848586878889
4442 .042 .041 .941 .941 .941 .941 .941 .941 .9
4541 .041 .041 .041 .041 .041 .040 .940 .940 .9
4640 .140 .140 .040 .040 .040 .040 .040 .040 .0
4739 .139 .139 .139 .139 .139 .139 .039 .039 .0
4838 .238 .238 .238 .138 .138 .138 .138 .138 .1
4937 .337 .337 .237 .237 .237 .237 .237 .137 .1
5036 .436 .336 .336 .336 .336 .236 .236 .236 .2
5135 .435 .435 .435 .435 .335 .335 .335 .335 .3
5234 .534 .534 .534 .434 .434 .434 .434 .434 .3
5333 .633 .633 .633 .533 .533 .533 .533 .433 .4
5432 .732 .732 .732 .632 .632 .632 .632 .532 .5
5531 .931 .831 .831 .731 .731 .731 .731 .631 .6
5631 .030 .930 .930 .930 .830 .830 .830 .730 .7
5730 .130 .130 .030 .029 .929 .929 .929 .929 .8
5829 .329 .229 .229 .129 .129 .029 .029 .029 .0
5928 .428 .428 .328 .328 .228 .228 .228 .128 .1
6027 .627 .527 .527 .427 .427 .327 .327 .327 .2
6126 .826 .726 .726 .626 .526 .526 .526 .426 .4
6226 .025 .925 .825 .825 .725 .725 .625 .625 .5
6325 .225 .125 .025 .024 .924 .824 .824 .824 .7
6424 .424 .324 .224 .224 .124 .024 .023 .923 .9
6523 .623 .523 .423 .423 .323 .223 .223 .123 .1
6622 .922 .822 .722 .622 .522 .422 .422 .322 .3
6722 .122 .021 .921 .821 .721 .721 .621 .521 .5
6821 .421 .321 .221 .021 .020 .920 .820 .720 .7
6920 .720 .520 .420 .320 .220 .120 .020 .019 .9
7020 .019 .819 .719 .619 .419 .319 .319 .219 .1
7119 .319 .119 .018 .818 .718 .618 .518 .418 .4
7218 .618 .418 .318 .118 .017 .917 .817 .717 .6
7318 .017 .817 .617 .417 .317 .217 .117 .016 .9
7417 .417 .217 .016 .816 .616 .516 .416 .216 .2
7516 .816 .616 .316 .116 .015 .815 .715 .615 .4
7616 .216 .015 .715 .515 .315 .215 .014 .914 .8
7715 .715 .415 .214 .914 .714 .514 .414 .214 .1
7815 .214 .914 .614 .414 .113 .913 .813 .613 .5
7914 .714 .414 .113 .813 .613 .413 .213 .012 .9
8014 .314 .013 .613 .313 .112 .812 .612 .412 .3
8113 .913 .513 .212 .912 .612 .312 .111 .911 .7
8213 .513 .112 .812 .412 .111 .911 .611 .411 .2
8313 .212 .812 .412 .011 .711 .411 .210 .910 .7
8412 .912 .412 .011 .711 .311 .010 .710 .510 .3
8512 .612 .111 .711 .311 .010 .710 .410 .19 .9
8612 .311 .911 .411 .010 .710 .310 .09 .79 .5
8712 .111 .611 .210 .710 .410 .09 .79 .49 .1

Bulletin No. 2019–48 1271 November 25, 2019
Ages818283848586878889
8811 .911 .410 .910 .510 .19 .79 .49 .18 .8
8911 .711 .210 .710 .39 .99 .59 .18 .88 .5
9011 .611 .010 .510 .19 .69 .28 .98 .58 .2
9111 .410 .910 .49 .99 .59 .08 .78 .38 .0
9211 .310 .810 .29 .79 .38 .98 .58 .17 .8
9311 .210 .610 .19 .69 .18 .78 .37 .97 .6
9411 .110 .510 .09 .59 .08 .68 .17 .77 .4
9511 .010 .59 .99 .48 .98 .48 .07 .67 .2
9611 .010 .49 .89 .38 .88 .37 .97 .57 .1
9710 .910 .39 .79 .28 .78 .27 .87 .47 .0
9810 .910 .39 .79 .18 .68 .17 .77 .36 .9
9910 .810 .29 .69 .18 .68 .17 .67 .26 .8
10010 .810 .29 .69 .08 .58 .07 .67 .16 .7
10110 .710 .19 .59 .08 .58 .07 .57 .16 .7
10210 .710 .19 .58 .98 .47 .97 .47 .06 .6
10310 .710 .19 .58 .98 .47 .97 .47 .06 .6
10410 .710 .19 .58 .98 .47 .97 .46 .96 .5
10510 .710 .09 .58 .98 .37 .87 .46 .96 .5
10610 .710 .09 .48 .98 .37 .87 .46 .96 .5
10710 .710 .09 .48 .98 .37 .87 .36 .96 .5
10810 .710 .09 .48 .98 .37 .87 .36 .96 .5
10910 .710 .09 .48 .98 .37 .87 .36 .96 .5
11010 .710 .09 .48 .98 .37 .87 .36 .96 .5
11110 .610 .09 .48 .88 .37 .87 .36 .96 .4
11210 .610 .09 .48 .88 .37 .87 .36 .96 .4
11310 .610 .09 .48 .88 .37 .87 .36 .86 .4
11410 .610 .09 .48 .88 .37 .87 .36 .86 .4
11510 .610 .09 .48 .88 .37 .77 .36 .86 .4
11610 .610 .09 .48 .88 .27 .77 .26 .86 .3
11710 .69 .99 .38 .78 .27 .77 .26 .76 .3
11810 .59 .99 .38 .78 .27 .67 .16 .76 .2
11910 .59 .99 .38 .78 .17 .67 .16 .66 .2
120+10 .59 .99 .28 .68 .17 .57 .06 .66 .1

November 25, 2019 1272 Bulletin No. 2019–48
Ages909192939495969798
084 .584 .584 .584 .584 .584 .584 .584 .584 .5
183 .783 .783 .783 .783 .783 .783 .783 .783 .7
282 .782 .782 .782 .782 .782 .782 .782 .782 .7
381 .781 .781 .781 .781 .781 .781 .781 .781 .7
480 .880 .880 .880 .880 .880 .880 .880 .880 .8
579 .879 .879 .879 .879 .879 .879 .879 .879 .8
678 .878 .878 .878 .878 .878 .878 .878 .878 .8
777 .877 .877 .877 .877 .877 .877 .877 .877 .8
876 .876 .876 .876 .876 .876 .876 .876 .876 .8
975 .875 .875 .875 .875 .875 .875 .875 .875 .8
1074 .874 .874 .874 .874 .874 .874 .874 .874 .8
1173 .873 .873 .873 .873 .873 .873 .873 .873 .8
1272 .972 .972 .972 .872 .872 .872 .872 .872 .8
1371 .971 .971 .971 .971 .971 .971 .971 .971 .9
1470 .970 .970 .970 .970 .970 .970 .970 .970 .9
1569 .969 .969 .969 .969 .969 .969 .969 .969 .9
1668 .968 .968 .968 .968 .968 .968 .968 .968 .9
1767 .967 .967 .967 .967 .967 .967 .967 .967 .9
1866 .966 .966 .966 .966 .966 .966 .966 .966 .9
1966 .066 .066 .066 .066 .066 .066 .066 .066 .0
2065 .065 .065 .065 .065 .065 .065 .065 .065 .0
2164 .064 .064 .064 .064 .064 .064 .064 .064 .0
2263 .063 .063 .063 .063 .063 .063 .063 .063 .0
2362 .162 .162 .062 .062 .062 .062 .062 .062 .0
2461 .161 .161 .161 .161 .161 .161 .161 .161 .1
2560 .160 .160 .160 .160 .160 .160 .160 .160 .1
2659 .159 .159 .159 .159 .159 .159 .159 .159 .1
2758 .258 .258 .258 .258 .258 .258 .258 .258 .2
2857 .257 .257 .257 .257 .257 .257 .257 .257 .2
2956 .356 .356 .256 .256 .256 .256 .256 .256 .2
3055 .355 .355 .355 .355 .355 .355 .355 .355 .3
3154 .354 .354 .354 .354 .354 .354 .354 .354 .3
3253 .453 .453 .453 .453 .453 .453 .453 .453 .4
3352 .452 .452 .452 .452 .452 .452 .452 .452 .4
3451 .551 .551 .551 .551 .551 .551 .551 .551 .5
3550 .550 .550 .550 .550 .550 .550 .550 .550 .5
3649 .549 .549 .549 .549 .549 .549 .549 .549 .5
3748 .648 .648 .648 .648 .648 .648 .648 .648 .6
3847 .647 .647 .647 .647 .647 .647 .647 .647 .6
3946 .746 .746 .746 .746 .746 .746 .746 .746 .7
4045 .745 .745 .745 .745 .745 .745 .745 .745 .7
4144 .844 .744 .744 .744 .744 .744 .744 .744 .7
4243 .843 .843 .843 .843 .843 .843 .843 .843 .8
4342 .842 .842 .842 .842 .842 .842 .842 .842 .8

Bulletin No. 2019–48 1273 November 25, 2019
Ages909192939495969798
4441 .941 .941 .941 .941 .941 .941 .941 .941 .9
4540 .940 .940 .940 .940 .940 .940 .940 .940 .9
4640 .040 .040 .040 .040 .040 .039 .939 .939 .9
4739 .039 .039 .039 .039 .039 .039 .039 .039 .0
4838 .138 .138 .138 .138 .138 .038 .038 .038 .0
4937 .137 .137 .137 .137 .137 .137 .137 .137 .1
5036 .236 .236 .236 .236 .236 .236 .236 .236 .1
5135 .335 .235 .235 .235 .235 .235 .235 .235 .2
5234 .334 .334 .334 .334 .334 .334 .334 .334 .3
5333 .433 .433 .433 .433 .433 .433 .433 .433 .4
5432 .532 .532 .532 .532 .532 .532 .432 .432 .4
5531 .631 .631 .631 .631 .631 .531 .531 .531 .5
5630 .730 .730 .730 .730 .730 .630 .630 .630 .6
5729 .829 .829 .829 .829 .829 .829 .729 .729 .7
5828 .928 .928 .928 .928 .928 .928 .928 .928 .8
5928 .128 .128 .028 .028 .028 .028 .028 .028 .0
6027 .227 .227 .227 .227 .127 .127 .127 .127 .1
6126 .426 .326 .326 .326 .326 .326 .326 .326 .2
6225 .525 .525 .525 .525 .425 .425 .425 .425 .4
6324 .724 .724 .624 .624 .624 .624 .624 .624 .6
6423 .923 .823 .823 .823 .823 .823 .723 .723 .7
6523 .023 .023 .023 .022 .922 .922 .922 .922 .9
6622 .222 .222 .222 .222 .122 .122 .122 .122 .1
6721 .421 .421 .421 .321 .321 .321 .321 .321 .3
6820 .620 .620 .620 .520 .520 .520 .520 .520 .4
6919 .919 .819 .819 .719 .719 .719 .719 .719 .6
7019 .119 .019 .018 .918 .918 .918 .918 .918 .8
7118 .318 .318 .218 .218 .118 .118 .118 .118 .0
7217 .517 .517 .417 .417 .417 .317 .317 .317 .3
7316 .816 .716 .716 .616 .616 .616 .516 .516 .5
7416 .116 .015 .915 .915 .815 .815 .815 .715 .7
7515 .415 .315 .215 .215 .115 .115 .015 .015 .0
7614 .714 .614 .514 .414 .414 .314 .314 .314 .2
7714 .013 .913 .813 .713 .713 .613 .613 .513 .5
7813 .413 .213 .213 .113 .012 .912 .912 .912 .8
7912 .712 .612 .512 .412 .412 .312 .212 .212 .1
8012 .112 .011 .911 .811 .711 .611 .611 .511 .5
8111 .611 .411 .311 .211 .111 .011 .010 .910 .9
8211 .010 .910 .810 .610 .510 .510 .410 .310 .3
8310 .510 .410 .210 .110 .09 .99 .89 .79 .7
8410 .19 .99 .79 .69 .59 .49 .39 .29 .1
859 .69 .59 .39 .19 .08 .98 .88 .78 .6
869 .29 .08 .98 .78 .68 .48 .38 .28 .1
878 .98 .78 .58 .38 .18 .07 .97 .87 .7

November 25, 2019 1274 Bulletin No. 2019–48
Ages909192939495969798
888 .58 .38 .17 .97 .77 .67 .57 .47 .3
898 .28 .07 .87 .67 .47 .27 .17 .06 .9
907 .97 .77 .57 .37 .16 .96 .86 .66 .5
917 .77 .47 .27 .06 .86 .66 .56 .36 .2
927 .57 .26 .96 .76 .56 .36 .26 .05 .9
937 .37 .06 .76 .56 .36 .15 .95 .85 .6
947 .16 .86 .56 .36 .05 .85 .75 .55 .4
956 .96 .66 .36 .15 .85 .65 .55 .35 .1
966 .86 .56 .25 .95 .75 .55 .35 .14 .9
976 .66 .36 .05 .85 .55 .35 .14 .94 .8
986 .56 .25 .95 .65 .45 .14 .94 .84 .6
996 .46 .15 .85 .55 .35 .04 .84 .64 .5
1006 .46 .05 .75 .45 .14 .94 .74 .54 .3
1016 .35 .95 .65 .35 .14 .84 .64 .44 .2
1026 .25 .95 .65 .35 .04 .74 .54 .34 .1
1036 .25 .85 .55 .24 .94 .74 .44 .24 .0
1046 .15 .85 .55 .14 .94 .64 .44 .24 .0
1056 .15 .85 .45 .14 .84 .64 .34 .13 .9
1066 .15 .75 .45 .14 .84 .64 .34 .13 .9
1076 .15 .75 .45 .14 .84 .54 .34 .13 .9
1086 .15 .75 .45 .14 .84 .54 .34 .13 .9
1096 .15 .75 .45 .14 .84 .54 .34 .13 .9
1106 .15 .75 .45 .14 .84 .54 .34 .13 .9
1116 .15 .75 .45 .04 .84 .54 .34 .03 .9
1126 .05 .75 .35 .04 .74 .54 .24 .03 .8
1136 .05 .75 .35 .04 .74 .54 .24 .03 .8
1146 .05 .65 .35 .04 .74 .44 .24 .03 .8
1156 .05 .65 .35 .04 .74 .44 .23 .93 .7
1165 .95 .65 .24 .94 .64 .34 .13 .93 .7
1175 .95 .55 .24 .84 .54 .34 .03 .83 .6
1185 .85 .45 .14 .84 .44 .23 .93 .73 .5
1195 .75 .45 .04 .74 .34 .03 .83 .53 .3
120+5 .75 .34 .94 .64 .23 .93 .73 .43 .2

Bulletin No. 2019–48 1275 November 25, 2019
Ages99100101102103104105106107
084 .584 .584 .584 .584 .584 .584 .584 .584 .5
183 .783 .783 .783 .783 .783 .783 .783 .783 .7
282 .782 .782 .782 .782 .782 .782 .782 .782 .7
381 .781 .781 .781 .781 .781 .781 .781 .781 .7
480 .880 .880 .880 .880 .880 .880 .880 .880 .8
579 .879 .879 .879 .879 .879 .879 .879 .879 .8
678 .878 .878 .878 .878 .878 .878 .878 .878 .8
777 .877 .877 .877 .877 .877 .877 .877 .877 .8
876 .876 .876 .876 .876 .876 .876 .876 .876 .8
975 .875 .875 .875 .875 .875 .875 .875 .875 .8
1074 .874 .874 .874 .874 .874 .874 .874 .874 .8
1173 .873 .873 .873 .873 .873 .873 .873 .873 .8
1272 .872 .872 .872 .872 .872 .872 .872 .872 .8
1371 .971 .971 .971 .971 .971 .971 .971 .971 .9
1470 .970 .970 .970 .970 .970 .970 .970 .970 .9
1569 .969 .969 .969 .969 .969 .969 .969 .969 .9
1668 .968 .968 .968 .968 .968 .968 .968 .968 .9
1767 .967 .967 .967 .967 .967 .967 .967 .967 .9
1866 .966 .966 .966 .966 .966 .966 .966 .966 .9
1966 .066 .066 .066 .066 .066 .066 .066 .066 .0
2065 .065 .065 .065 .065 .065 .065 .065 .065 .0
2164 .064 .064 .064 .064 .064 .064 .064 .064 .0
2263 .063 .063 .063 .063 .063 .063 .063 .063 .0
2362 .062 .062 .062 .062 .062 .062 .062 .062 .0
2461 .161 .161 .161 .161 .161 .161 .161 .161 .1
2560 .160 .160 .160 .160 .160 .160 .160 .160 .1
2659 .159 .159 .159 .159 .159 .159 .159 .159 .1
2758 .258 .258 .258 .258 .258 .258 .258 .258 .2
2857 .257 .257 .257 .257 .257 .257 .257 .257 .2
2956 .256 .256 .256 .256 .256 .256 .256 .256 .2
3055 .355 .355 .355 .355 .355 .355 .355 .355 .3
3154 .354 .354 .354 .354 .354 .354 .354 .354 .3
3253 .453 .453 .453 .453 .453 .453 .453 .453 .4
3352 .452 .452 .452 .452 .452 .452 .452 .452 .4
3451 .551 .551 .451 .451 .451 .451 .451 .451 .4
3550 .550 .550 .550 .550 .550 .550 .550 .550 .5
3649 .549 .549 .549 .549 .549 .549 .549 .549 .5
3748 .648 .648 .648 .648 .648 .648 .648 .648 .6
3847 .647 .647 .647 .647 .647 .647 .647 .647 .6
3946 .746 .746 .746 .746 .746 .746 .746 .746 .7
4045 .745 .745 .745 .745 .745 .745 .745 .745 .7
4144 .744 .744 .744 .744 .744 .744 .744 .744 .7
4243 .843 .843 .843 .843 .843 .843 .843 .843 .8
4342 .842 .842 .842 .842 .842 .842 .842 .842 .8

November 25, 2019 1276 Bulletin No. 2019–48
Ages99100101102103104105106107
4441 .941 .941 .941 .941 .941 .941 .941 .941 .9
4540 .940 .940 .940 .940 .940 .940 .940 .940 .9
4639 .939 .939 .939 .939 .939 .939 .939 .939 .9
4739 .039 .039 .039 .039 .039 .039 .039 .039 .0
4838 .038 .038 .038 .038 .038 .038 .038 .038 .0
4937 .137 .137 .137 .137 .137 .137 .137 .137 .1
5036 .136 .136 .136 .136 .136 .136 .136 .136 .1
5135 .235 .235 .235 .235 .235 .235 .235 .235 .2
5234 .334 .334 .334 .334 .334 .334 .334 .334 .3
5333 .333 .333 .333 .333 .333 .333 .333 .333 .3
5432 .432 .432 .432 .432 .432 .432 .432 .432 .4
5531 .531 .531 .531 .531 .531 .531 .531 .531 .5
5630 .630 .630 .630 .630 .630 .630 .630 .630 .6
5729 .729 .729 .729 .729 .729 .729 .729 .729 .7
5828 .828 .828 .828 .828 .828 .828 .828 .828 .8
5928 .028 .028 .028 .027 .927 .927 .927 .927 .9
6027 .127 .127 .127 .127 .127 .127 .127 .127 .1
6126 .226 .226 .226 .226 .226 .226 .226 .226 .2
6225 .425 .425 .425 .425 .425 .425 .425 .425 .4
6324 .524 .524 .524 .524 .524 .524 .524 .524 .5
6423 .723 .723 .723 .723 .723 .723 .723 .723 .7
6522 .922 .922 .922 .922 .922 .922 .922 .922 .8
6622 .122 .122 .022 .022 .022 .022 .022 .022 .0
6721 .221 .221 .221 .221 .221 .221 .221 .221 .2
6820 .420 .420 .420 .420 .420 .420 .420 .420 .4
6919 .619 .619 .619 .619 .619 .619 .619 .619 .6
7018 .818 .818 .818 .818 .818 .818 .818 .818 .8
7118 .018 .018 .018 .018 .018 .018 .018 .018 .0
7217 .217 .217 .217 .217 .217 .217 .217 .217 .2
7316 .516 .416 .416 .416 .416 .416 .416 .416 .4
7415 .715 .715 .715 .715 .615 .615 .615 .615 .6
7514 .914 .914 .914 .914 .914 .914 .914 .914 .9
7614 .214 .214 .214 .214 .114 .114 .114 .114 .1
7713 .513 .513 .413 .413 .413 .413 .413 .413 .4
7812 .812 .812 .712 .712 .712 .712 .712 .712 .7
7912 .112 .112 .012 .012 .012 .012 .012 .012 .0
8011 .411 .411 .411 .411 .311 .311 .311 .311 .3
8110 .810 .810 .710 .710 .710 .710 .710 .710 .7
8210 .210 .210 .110 .110 .110 .110 .010 .010 .0
839 .69 .69 .59 .59 .59 .59 .59 .49 .4
849 .19 .09 .08 .98 .98 .98 .98 .98 .9
858 .68 .58 .58 .48 .48 .48 .38 .38 .3
868 .18 .08 .07 .97 .97 .97 .87 .87 .8
877 .67 .67 .57 .47 .47 .47 .47 .47 .3

Bulletin No. 2019–48 1277 November 25, 2019
Ages99100101102103104105106107
887 .27 .17 .17 .07 .06 .96 .96 .96 .9
896 .86 .76 .76 .66 .66 .56 .56 .56 .5
906 .46 .46 .36 .26 .26 .16 .16 .16 .1
916 .16 .05 .95 .95 .85 .85 .85 .75 .7
925 .85 .75 .65 .65 .55 .55 .45 .45 .4
935 .55 .45 .35 .35 .25 .15 .15 .15 .1
945 .35 .15 .15 .04 .94 .94 .84 .84 .8
955 .04 .94 .84 .74 .74 .64 .64 .64 .5
964 .84 .74 .64 .54 .44 .44 .34 .34 .3
974 .64 .54 .44 .34 .24 .24 .14 .14 .1
984 .54 .34 .24 .14 .04 .03 .93 .93 .9
994 .34 .24 .14 .03 .93 .83 .83 .73 .7
1004 .24 .03 .93 .83 .73 .73 .63 .63 .6
1014 .13 .93 .83 .73 .63 .53 .53 .53 .4
1024 .03 .83 .73 .63 .53 .43 .43 .33 .3
1033 .93 .73 .63 .53 .43 .33 .33 .23 .2
1043 .83 .73 .53 .43 .33 .23 .23 .23 .1
1053 .83 .63 .53 .43 .33 .23 .13 .13 .1
1063 .73 .63 .53 .33 .23 .23 .13 .13 .1
1073 .73 .63 .43 .33 .23 .13 .13 .13 .0
1083 .73 .63 .43 .33 .23 .13 .13 .03 .0
1093 .73 .53 .43 .33 .23 .13 .13 .03 .0
1103 .73 .53 .43 .33 .23 .13 .03 .03 .0
1113 .73 .53 .43 .33 .23 .13 .03 .03 .0
1123 .73 .53 .43 .23 .13 .13 .03 .03 .0
1133 .63 .53 .33 .23 .13 .03 .03 .02 .9
1143 .63 .43 .33 .23 .13 .03 .02 .92 .9
1153 .63 .43 .33 .13 .03 .02 .92 .92 .9
1163 .53 .33 .23 .13 .02 .92 .82 .82 .8
1173 .43 .23 .13 .02 .92 .82 .72 .72 .7
1183 .33 .13 .02 .82 .72 .62 .62 .52 .5
1193 .12 .92 .82 .62 .52 .42 .32 .32 .3
120+3 .02 .82 .62 .52 .32 .22 .12 .12 .1

November 25, 2019 1278 Bulletin No. 2019–48
Ages108109110111112113114115116
084 .584 .584 .584 .584 .584 .584 .584 .584 .5
183 .783 .783 .783 .783 .783 .783 .783 .783 .7
282 .782 .782 .782 .782 .782 .782 .782 .782 .7
381 .781 .781 .781 .781 .781 .781 .781 .781 .7
480 .880 .880 .880 .880 .880 .880 .880 .880 .8
579 .879 .879 .879 .879 .879 .879 .879 .879 .8
678 .878 .878 .878 .878 .878 .878 .878 .878 .8
777 .877 .877 .877 .877 .877 .877 .877 .877 .8
876 .876 .876 .876 .876 .876 .876 .876 .876 .8
975 .875 .875 .875 .875 .875 .875 .875 .875 .8
1074 .874 .874 .874 .874 .874 .874 .874 .874 .8
1173 .873 .873 .873 .873 .873 .873 .873 .873 .8
1272 .872 .872 .872 .872 .872 .872 .872 .872 .8
1371 .971 .971 .971 .971 .971 .971 .971 .971 .9
1470 .970 .970 .970 .970 .970 .970 .970 .970 .9
1569 .969 .969 .969 .969 .969 .969 .969 .969 .9
1668 .968 .968 .968 .968 .968 .968 .968 .968 .9
1767 .967 .967 .967 .967 .967 .967 .967 .967 .9
1866 .966 .966 .966 .966 .966 .966 .966 .966 .9
1966 .066 .066 .066 .066 .066 .066 .066 .066 .0
2065 .065 .065 .065 .065 .065 .065 .065 .065 .0
2164 .064 .064 .064 .064 .064 .064 .064 .064 .0
2263 .063 .063 .063 .063 .063 .063 .063 .063 .0
2362 .062 .062 .062 .062 .062 .062 .062 .062 .0
2461 .161 .161 .161 .161 .161 .161 .161 .161 .1
2560 .160 .160 .160 .160 .160 .160 .160 .160 .1
2659 .159 .159 .159 .159 .159 .159 .159 .159 .1
2758 .258 .258 .258 .258 .258 .258 .258 .258 .2
2857 .257 .257 .257 .257 .257 .257 .257 .257 .2
2956 .256 .256 .256 .256 .256 .256 .256 .256 .2
3055 .355 .355 .355 .355 .355 .355 .355 .355 .3
3154 .354 .354 .354 .354 .354 .354 .354 .354 .3
3253 .453 .453 .453 .453 .453 .453 .453 .453 .4
3352 .452 .452 .452 .452 .452 .452 .452 .452 .4
3451 .451 .451 .451 .451 .451 .451 .451 .451 .4
3550 .550 .550 .550 .550 .550 .550 .550 .550 .5
3649 .549 .549 .549 .549 .549 .549 .549 .549 .5
3748 .648 .648 .648 .648 .648 .648 .648 .648 .6
3847 .647 .647 .647 .647 .647 .647 .647 .647 .6
3946 .746 .646 .646 .646 .646 .646 .646 .646 .6
4045 .745 .745 .745 .745 .745 .745 .745 .745 .7
4144 .744 .744 .744 .744 .744 .744 .744 .744 .7
4243 .843 .843 .843 .843 .843 .843 .843 .843 .8
4342 .842 .842 .842 .842 .842 .842 .842 .842 .8

Bulletin No. 2019–48 1279 November 25, 2019
Ages108109110111112113114115116
4441 .941 .941 .941 .941 .941 .941 .941 .941 .8
4540 .940 .940 .940 .940 .940 .940 .940 .940 .9
4639 .939 .939 .939 .939 .939 .939 .939 .939 .9
4739 .039 .039 .039 .039 .039 .039 .039 .039 .0
4838 .038 .038 .038 .038 .038 .038 .038 .038 .0
4937 .137 .137 .137 .137 .137 .137 .137 .137 .1
5036 .136 .136 .136 .136 .136 .136 .136 .136 .1
5135 .235 .235 .235 .235 .235 .235 .235 .235 .2
5234 .334 .334 .334 .334 .334 .334 .334 .334 .3
5333 .333 .333 .333 .333 .333 .333 .333 .333 .3
5432 .432 .432 .432 .432 .432 .432 .432 .432 .4
5531 .531 .531 .531 .531 .531 .531 .531 .531 .5
5630 .630 .630 .630 .630 .630 .630 .630 .630 .6
5729 .729 .729 .729 .729 .729 .729 .729 .729 .7
5828 .828 .828 .828 .828 .828 .828 .828 .828 .8
5927 .927 .927 .927 .927 .927 .927 .927 .927 .9
6027 .127 .127 .127 .127 .127 .127 .127 .127 .1
6126 .226 .226 .226 .226 .226 .226 .226 .226 .2
6225 .425 .425 .425 .425 .425 .425 .425 .425 .3
6324 .524 .524 .524 .524 .524 .524 .524 .524 .5
6423 .723 .723 .723 .723 .723 .723 .723 .723 .7
6522 .822 .822 .822 .822 .822 .822 .822 .822 .8
6622 .022 .022 .022 .022 .022 .022 .022 .022 .0
6721 .221 .221 .221 .221 .221 .221 .221 .221 .2
6820 .420 .420 .420 .420 .420 .420 .420 .420 .4
6919 .619 .619 .619 .619 .619 .619 .619 .619 .6
7018 .818 .818 .818 .818 .818 .818 .818 .818 .8
7118 .018 .018 .018 .018 .018 .018 .018 .018 .0
7217 .217 .217 .217 .217 .217 .217 .217 .217 .2
7316 .416 .416 .416 .416 .416 .416 .416 .416 .4
7415 .615 .615 .615 .615 .615 .615 .615 .615 .6
7514 .914 .914 .914 .914 .914 .914 .814 .814 .8
7614 .114 .114 .114 .114 .114 .114 .114 .114 .1
7713 .413 .413 .413 .413 .413 .413 .413 .413 .3
7812 .712 .712 .712 .712 .712 .712 .612 .612 .6
7912 .012 .012 .012 .012 .012 .012 .011 .911 .9
8011 .311 .311 .311 .311 .311 .311 .311 .311 .3
8110 .710 .710 .710 .610 .610 .610 .610 .610 .6
8210 .010 .010 .010 .010 .010 .010 .010 .010 .0
839 .49 .49 .49 .49 .49 .49 .49 .49 .4
848 .98 .98 .98 .88 .88 .88 .88 .88 .8
858 .38 .38 .38 .38 .38 .38 .38 .38 .2
867 .87 .87 .87 .87 .87 .87 .87 .77 .7
877 .37 .37 .37 .37 .37 .37 .37 .37 .2

November 25, 2019 1280 Bulletin No. 2019–48
Ages108109110111112113114115116
886 .96 .96 .96 .96 .96 .86 .86 .86 .8
896 .56 .56 .56 .46 .46 .46 .46 .46 .3
906 .16 .16 .16 .16 .06 .06 .06 .05 .9
915 .75 .75 .75 .75 .75 .75 .65 .65 .6
925 .45 .45 .45 .45 .35 .35 .35 .35 .2
935 .15 .15 .15 .05 .05 .05 .05 .04 .9
944 .84 .84 .84 .84 .74 .74 .74 .74 .6
954 .54 .54 .54 .54 .54 .54 .44 .44 .3
964 .34 .34 .34 .34 .24 .24 .24 .24 .1
974 .14 .14 .14 .04 .04 .04 .03 .93 .9
983 .93 .93 .93 .93 .83 .83 .83 .73 .7
993 .73 .73 .73 .73 .73 .63 .63 .63 .5
1003 .63 .53 .53 .53 .53 .53 .43 .43 .3
1013 .43 .43 .43 .43 .43 .33 .33 .33 .2
1023 .33 .33 .33 .33 .23 .23 .23 .13 .1
1033 .23 .23 .23 .23 .13 .13 .13 .03 .0
1043 .13 .13 .13 .13 .13 .03 .03 .02 .9
1053 .13 .13 .03 .03 .03 .03 .02 .92 .8
1063 .03 .03 .03 .03 .03 .02 .92 .92 .8
1073 .03 .03 .03 .03 .02 .92 .92 .92 .8
1083 .03 .03 .03 .02 .92 .92 .92 .82 .8
1093 .03 .03 .02 .92 .92 .92 .92 .82 .8
1103 .03 .03 .02 .92 .92 .92 .92 .82 .7
1113 .02 .92 .92 .92 .92 .92 .82 .82 .7
1122 .92 .92 .92 .92 .92 .92 .82 .82 .7
1132 .92 .92 .92 .92 .92 .82 .82 .72 .7
1142 .92 .92 .92 .82 .82 .82 .82 .72 .6
1152 .82 .82 .82 .82 .82 .72 .72 .72 .6
1162 .82 .82 .72 .72 .72 .72 .62 .62 .5
1172 .72 .62 .62 .62 .62 .62 .52 .52 .4
1182 .52 .52 .52 .42 .42 .42 .42 .32 .2
1192 .32 .32 .22 .22 .22 .22 .12 .12 .0
120+2 .02 .02 .02 .02 .01 .91 .91 .81 .8

Bulletin No. 2019–48 1281 November 25, 2019
Ages117118119120+
084 .584 .584 .584 .5
183 .783 .783 .783 .7
282 .782 .782 .782 .7
381 .781 .781 .781 .7
480 .880 .880 .880 .8
579 .879 .879 .879 .8
678 .878 .878 .878 .8
777 .877 .877 .877 .8
876 .876 .876 .876 .8
975 .875 .875 .875 .8
1074 .874 .874 .874 .8
1173 .873 .873 .873 .8
1272 .872 .872 .872 .8
1371 .971 .971 .971 .9
1470 .970 .970 .970 .9
1569 .969 .969 .969 .9
1668 .968 .968 .968 .9
1767 .967 .967 .967 .9
1866 .966 .966 .966 .9
1966 .066 .066 .066 .0
2065 .065 .065 .065 .0
2164 .064 .064 .064 .0
2263 .063 .063 .063 .0
2362 .062 .062 .062 .0
2461 .161 .161 .161 .1
2560 .160 .160 .160 .1
2659 .159 .159 .159 .1
2758 .258 .258 .258 .2
2857 .257 .257 .257 .2
2956 .256 .256 .256 .2
3055 .355 .355 .355 .3
3154 .354 .354 .354 .3
3253 .453 .453 .453 .4
3352 .452 .452 .452 .4
3451 .451 .451 .451 .4
3550 .550 .550 .550 .5
3649 .549 .549 .549 .5
3748 .648 .648 .648 .6
3847 .647 .647 .647 .6
3946 .646 .646 .646 .6
4045 .745 .745 .745 .7
4144 .744 .744 .744 .7
4243 .843 .843 .843 .8
4342 .842 .842 .842 .8

November 25, 2019 1282 Bulletin No. 2019–48
Ages117118119120+
4441 .841 .841 .841 .8
4540 .940 .940 .940 .9
4639 .939 .939 .939 .9
4739 .039 .039 .039 .0
4838 .038 .038 .038 .0
4937 .137 .137 .137 .1
5036 .136 .136 .136 .1
5135 .235 .235 .235 .2
5234 .334 .334 .334 .3
5333 .333 .333 .333 .3
5432 .432 .432 .432 .4
5531 .531 .531 .531 .5
5630 .630 .630 .630 .6
5729 .729 .729 .729 .7
5828 .828 .828 .828 .8
5927 .927 .927 .927 .9
6027 .127 .127 .127 .1
6126 .226 .226 .226 .2
6225 .325 .325 .325 .3
6324 .524 .524 .524 .5
6423 .723 .723 .623 .6
6522 .822 .822 .822 .8
6622 .022 .022 .022 .0
6721 .221 .221 .221 .2
6820 .420 .420 .420 .4
6919 .619 .619 .519 .5
7018 .718 .718 .718 .7
7117 .917 .917 .917 .9
7217 .117 .117 .117 .1
7316 .416 .416 .316 .3
7415 .615 .615 .615 .6
7514 .814 .814 .814 .8
7614 .114 .114 .014 .0
7713 .313 .313 .313 .3
7812 .612 .612 .612 .6
7911 .911 .911 .911 .9
8011 .211 .211 .211 .2
8110 .610 .510 .510 .5
829 .99 .99 .99 .9
839 .39 .39 .39 .2
848 .78 .78 .78 .6
858 .28 .28 .18 .1
867 .77 .67 .67 .5
877 .27 .17 .17 .0

Bulletin No. 2019–48 1283 November 25, 2019
Ages117118119120+
886 .76 .76 .66 .6
896 .36 .26 .26 .1
905 .95 .85 .75 .7
915 .55 .45 .45 .3
925 .25 .15 .04 .9
934 .84 .84 .74 .6
944 .54 .44 .34 .2
954 .34 .24 .03 .9
964 .03 .93 .83 .7
973 .83 .73 .53 .4
983 .63 .53 .33 .2
993 .43 .33 .13 .0
1003 .23 .12 .92 .8
1013 .13 .02 .82 .6
1023 .02 .82 .62 .5
1032 .92 .72 .52 .3
1042 .82 .62 .42 .2
1052 .72 .62 .32 .1
1062 .72 .52 .32 .1
1072 .72 .52 .32 .1
1082 .72 .52 .32 .0
1092 .62 .52 .32 .0
1102 .62 .52 .22 .0
1112 .62 .42 .22 .0
1122 .62 .42 .22 .0
1132 .62 .42 .2
1 .9
1142 .52 .42 .11 .9
1152 .52 .32 .11 .8
1162 .42 .22 .01 .8
1172 .32 .11 .91 .6
1182 .11 .91 .71 .4
1191 .91 .71 .31 .1
120+1 .61 .41 .11 .0
(e) Mortality rates . The following are
bles set forth in paragraphs (b), (c) and (d)
the mortality rates used to calculate the ta-
of this section .
Table 4 to Paragraph (e)
AgeProbability of Death
00 .001765
10 .000442
20 .000293
30 .000232
40 .000177
50 .000162
AgeProbability of Death
60 .000153
70 .000145
80 .000132
90 .000127
100 .000128
110 .000135
120 .000146
AgeProbability of Death
130 .000165
140 .000192
150 .000224
160 .000253
170 .000277
180 .000293
190 .000305

November 25, 2019 1284 Bulletin No. 2019–48
AgeProbability of Death
200 .000314
210 .000344
220 .000378
230 .000421
240 .000467
250 .000520
260 .000581
270 .000630
280 .000677
290 .000720
300 .000762
310 .000797
320 .000822
330 .000830
340 .000826
350 .000818
360 .000813
370 .000818
380 .000830
390 .000847
400 .000872
410 .000902
420 .000938
430 .000974
440 .001012
450 .001061
460 .001128
470 .001223
480 .001345
490 .001488
500 .001661
510 .001883
520 .002134
530 .002413
AgeProbability of Death
540 .002722
550 .003057
560 .003418
570 .003805
580 .004213
590 .004646
600 .005104
610 .005587
620 .006102
630 .006655
640 .007255
650 .007913
660 .008265
670 .008687
680 .009194
690 .009804
700 .010535
710 .011413
720 .012454
730 .013684
740 .015121
750 .016798
760 .018740
770 .020993
780 .023598
790 .026624
800 .030122
810 .034190
820 .038892
830 .044271
840 .050391
850 .057285
860 .064967
870 .073466
AgeProbability of Death
880 .082774
890 .092864
900 .103667
910 .115152
920 .127474
930 .140876
940 .155859
950 .173011
960 .188348
970 .205840
980 .224127
990 .243120
1000 .262731
1010 .282787
1020 .303096
1030 .323605
1040 .344149
1050 .362406
1060 .373952
1070 .382053
1080 .384203
1090 .386443
1100 .388694
1110 .390860
1120 .393195
1130 .395445
1140 .397687
1150 .400000
1160 .400000
1170 .400000
1180 .400000
1190 .400000
1201 .000000
(f) Applicability dates—(1) In General . (2) Application to life expectancies that
each subsequent year, then that life expec-
The life expectancy tables and Uniform may not be recalculated—(i) Applicability
tancy is reset as provided in paragraph (f)
Lifetime Table set forth in this section ap-of current tables . If an employee died be-
(2)(ii) of this section . Similarly, if an em-
ply for distribution calendar years begin-fore January 1, 2021, and, under the rules
ployee’s sole beneficiary is the employ-
ning on or after January 1, 2021 . For life of §1 .401(a)(9)-5, the distribution period
ee’s surviving spouse, and the spouse dies
expectancy tables and the Uniform Life-that applies for a calendar year follow-
before January 1, 2021, then the spouse’s
time Table applicable for earlier distribu-ing the calendar year of the employee’s
life expectancy for the calendar year of the
tion calendar years, see §1 .401(a)(9)-9, as death is equal to a single life expectancy
spouse’s death (which is used to determine
set forth in 26 CFR Part 1 revised April calculated as of the calendar year of the
the applicable distribution period for later
1, 2019 (formerly applicable §1 .401(a)employee’s death (or, if applicable, the
years) is reset as provided in paragraph (f)
(9)-9) .following calendar year), reduced by 1 for
(2)(ii) of this section .

Bulletin No. 2019–48 1285 November 25, 2019
(ii) Determination of applicable dis-
tribution period . With respect to a life
expectancy described in paragraph (f)
(2)(i) of this section, the distribution
period that applies for a distribution
calendar year beginning on or after Jan-
uary 1, 2021, is determined by using
the Single Life Table in paragraph (b)
of this section to determine initial life
expectancy for the age of the relevant
individual in the relevant calendar year
and then reducing the resulting distri-
bution period by 1 for each subsequent
year . For example, assume that an em-
ployee died at age 80 in 2018 and the
employee’s designated beneficiary (who
was not the employee’s spouse) was age
75 in the year of the employee’s death .
For 2019, the distribution period that
would have applied for the beneficiary
was 12 .7 years (the period applicable for
a 76 year old under the Single Life Table
in formerly applicable §1 .401(a)(9)-9),
and for 2020, it would have been 11 .7
years (the original distribution period,
reduced by 1 year) . For 2021, the appli-
cable distribution period would be 12 .0
years (the 14 .0 year life expectancy for
a 76 year old under the Single Life Table
in paragraph (b) of this section, reduced
by 2 years) .
Sunita Lough,
Deputy Commissioner for Services
and Enforcement.
(Filed by the Office of the Federal Register on No-
vember 7, 2019, 8:45 a .m ., and published in the issue
of the Federal Register for November 8, 2019, 84
F .R . 60812)

Bulletin No. 2019–48 i November 25, 2019
Definition of Terms
Revenue rulings and revenue procedures
(hereinafter referred to as “rulings”) that
have an effect on previous rulings use the
following defined terms to describe the
effect:
Amplified describes a situation where
no change is being made in a prior pub-
lished position, but the prior position is
being extended to apply to a variation of
the fact situation set forth therein . Thus, if
an earlier ruling held that a principle ap-
plied to A, and the new ruling holds that
the same principle also applies to B, the
earlier ruling is amplified. (Compare with
modified, below) .
Clarified is used in those instances
where the language in a prior ruling is be-
ing made clear because the language has
caused, or may cause, some confusion . It
is not used where a position in a prior rul-
ing is being changed .
Distinguished describes a situation
where a ruling mentions a previously pub-
lished ruling and points out an essential
difference between them .
Modified is used where the substance
of a previously published position is being
changed . Thus, if a prior ruling held that a
principle applied to A but not to B, and the
new ruling holds that it applies to both A
and B, the prior ruling is modified because
it corrects a published position . (Compare
with amplified and clarified, above) .
Obsoleted describes a previously pub-
lished ruling that is not considered deter-
minative with respect to future transactions .
This term is most commonly used in a ruling
that lists previously published rulings that
are obsoleted because of changes in laws or
regulations . A ruling may also be obsoleted
because the substance has been included in
regulations subsequently adopted .
Revoked describes situations where the
position in the previously published ruling
is not correct and the correct position is
being stated in a new ruling .
Superseded describes a situation where
the new ruling does nothing more than
restate the substance and situation of a
previously published ruling (or rulings) .
Thus, the term is used to republish under
the 1986 Code and regulations the same
position published under the 1939 Code
and regulations . The term is also used
when it is desired to republish in a single
ruling a series of situations, names, etc .,
that were previously published over a
period of time in separate rulings . If the
new ruling does more than restate the sub-
stance of a prior ruling, a combination of
terms is used . For example, modified and
superseded describes a situation where the
substance of a previously published ruling
is being changed in part and is continued
without change in part and it is desired to
restate the valid portion of the previous-
ly published ruling in a new ruling that is
self contained . In this case, the previously
published ruling is first modified and then,
as modified, is superseded.
Supplemented is used in situations in
which a list, such as a list of the names of
countries, is published in a ruling and that
list is expanded by adding further names
in subsequent rulings . After the original
ruling has been supplemented several
times, a new ruling may be published that
includes the list in the original ruling and
the additions, and supersedes all prior rul-
ings in the series .
Suspended is used in rare situations to
show that the previous published rulings
will not be applied pending some future
action such as the issuance of new or
amended regulations, the outcome of cas-
es in litigation, or the outcome of a Ser-
vice study .
Abbreviations
The following abbreviations in current use
and formerly used will appear in material
published in the Bulletin.
A—Individual .
Acq.—Acquiescence .
B—Individual .
BE—Beneficiary.
BK—Bank .
B.T.A.—Board of Tax Appeals .
C—Individual .
C.B.—Cumulative Bulletin .
CFR—Code of Federal Regulations .
CI—City .
COOP—Cooperative .
Ct.D.—Court Decision .
CY—County .
D—Decedent .
DC—Dummy Corporation .
DE—Donee .
Del. Order—Delegation Order .
DISC—Domestic International Sales Corporation .
DR—Donor .
E—Estate .
EE—Employee .
E.O.—Executive Order .
ER—Employer .
ERISA—Employee Retirement Income Security Act .
EX—Executor .
F—Fiduciary .
FC—Foreign Country .
FICA—Federal Insurance Contributions Act .
FISC—Foreign International Sales Company .
FPH—Foreign Personal Holding Company .
F.R.—Federal Register .
FUTA—Federal Unemployment Tax Act .
FX—Foreign corporation .
G.C.M.—Chief Counsel’s Memorandum .
GE—Grantee .
GP—General Partner .
GR—Grantor .
IC—Insurance Company .
I.R.B.—Internal Revenue Bulletin .
LE—Lessee .
LP—Limited Partner .
LR—Lessor .
M—Minor .
Nonacq.—Nonacquiescence .
O—Organization .
P—Parent Corporation .
PHC—Personal Holding Company .
PO—Possession of the U .S .
PR—Partner .
PRS—Partnership .
PTE—Prohibited Transaction Exemption .
Pub. L.—Public Law .
REIT—Real Estate Investment Trust .
Rev. Proc.—Revenue Procedure .
Rev. Rul.—Revenue Ruling .
S—Subsidiary .
S.P.R.—Statement of Procedural Rules .
Stat.—Statutes at Large .
T—Target Corporation .
T.C.—Tax Court .
T.D.—Treasury Decision .
TFE—Transferee .
TFR—Transferor .
T.I.R.—Technical Information Release .
TP—Taxpayer .
TR—Trust .
TT—Trustee .
U.S.C.—United States Code .
X—Corporation .
Y—Corporation .
Z—Corporation .

November 25, 2019 ii Bulletin No. 2019–48
Numerical Finding List
1
Bulletin 2019–48
AOD:
2019-02, 2019-41 I .R .B . 806
2019-03, 2019-42 I .R .B . 934
Announcements:
2019-07, 2019-27 I .R .B . 62
2019-08, 2019-32 I .R .B . 621
2019-10, 2019-46 I .R .B . 1049
Notices:
2019-12, 2019-27 I .R .B . 57
2019-40, 2019-27 I .R .B . 59
2019-41, 2019-28 I .R .B . 256
2019-42, 2019-29 I .R .B . 352
2019-27, 2019-31 I .R .B . 484
2019-43, 2019-31 I .R .B . 487
2019-24, 2019-31 I .R .B . 489
2019-45, 2019-32 I .R .B . 593
2019-48, 2019-36 I .R .B . 678
2019-46, 2019-37 I .R .B . 695
2019-49, 2019-37 I .R .B . 699
2019-50, 2019-37 I .R .B . 700
2019-47, 2019-39 I .R .B . 731
2019-51, 2019-41 I .R .B . 866
2019-52, 2019-41 I .R .B . 869
2019-54, 2019-42 I .R .B . 935
2019-55, 2019-42 I .R .B . 937
2019-58, 2019-44 I .R .B . 1022
2019-56, 2019-45 I .R .B . 1046
2019-59, 2019-47 I .R .B . 1091
Proposed Regulations:
REG-105476-18, 2019-27 I .R .B . 63
REG-106282-18, 2019-28 I .R .B . 259
REG-101828-19, 2019-29 I .R .B . 412
REG-106877-18, 2019-30 I .R .B . 441
REG-121508-18, 2019-30 I .R .B . 456
REG-105474-18, 2019-31 I .R .B . 493
REG-118425-18, 2019-31 I .R .B . 539
REG-130700-14, 2019-36 I .R .B . 681
REG-101378-19, 2019-37 I .R .B . 702
REG-104554-18, 2019-39 I .R .B . 737
REG-104870-18, 2019-39 I .R .B . 754
REG-102508-16, 2019-40 I .R .B . 777
REG-125710-18, 2019-40 I .R .B . 785
REG-106808-19, 2019-41 I .R .B . 912
REG-136401-18, 2019-42 I .R .B . 960
REG-104223-18, 2019-43 I .R .B . 989
REG-118784-18, 2019-44 I .R .B . 1024
REG-128246-18, 2019-44 I .R .B . 1037
REG-123112-19, 2019-47 I .R .B . 1104
REG-131071-18, 2019-48 I .R .B . 1217
REG-132210-18, 2019-48 I .R .B . 1232
Revenue Rulings:
2019-16, 2019-28 I .R .B . 96
2019-17, 2019-32 I .R .B . 583
2019-18, 2019-35 I .R .B . 668
2019-19, 2019-36 I .R .B . 674
2019-20, 2019-36 I .R .B . 675
2019-21, 2019-38 I .R .B . 708
2019-22, 2019-40 I .R .B . 776
2019-23, 2019-41 I .R .B . 807
2019-24, 2019-44 I .R .B . 1004
2019-25, 2019-45 I .R .B . 1042
Revenue Procedures:
2019-24, 2019-29 I .R .B . 353
2019-28, 2019-32 I .R .B . 596
2019-29, 2019-32 I .R .B . 620
2019-30, 2019-33 I .R .B . 638
2019-31, 2019-33 I .R .B . 643
2019-32, 2019-33 I .R .B . 659
2019-33, 2019-34 I .R .B . 662
2019-34, 2019-35 I .R .B . 669
2019-23, 2019-38 I .R .B . 725
2019-36, 2019-38 I .R .B . 729
2019-37, 2019-39 I .R .B . 731
2019-35, 2019-41 I .R .B . 870
2019-38, 2019-42 I .R .B . 942
2019-39, 2019-42 I .R .B . 945
2019-40, 2019-43 I .R .B . 982
2019-41, 2019-44 I .R .B . 1022
2019-44, 2019-47 I .R .B . 1093
2019-43, 2019-48 I .R .B . 1107
2019-45, 2019-48 I .R .B . 1215
Treasury Decisions:
9863, 2019-27 I .R .B . 1
9864, 2019-27 I .R .B . 6
9865, 2019-27 I .R .B . 27
9867, 2019-28 I .R .B . 98
9868, 2019-28 I .R .B . 252
9866, 2019-29 I .R .B . 261
9861, 2019-30 I .R .B . 433
9869, 2019-30 I .R .B . 438
9862, 2019-31 I .R .B . 477
9872, 2019-32 I .R .B . 585
9871, 2019-33 I .R .B . 624
9873, 2019-33 I .R .B . 630
9874, 2019-41 I .R .B . 809
9875, 2019-41 I .R .B . 856
9876, 2019-44 I .R .B . 1005
9877, 2019-44 I .R .B . 1007
9878, 2019-45 I .R .B . 1044
9879, 2019-47 I .R .B . 1052
9880, 2019-47 I .R .B . 1085
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc ., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin
2018–52, dated December 27, 2018 .

Bulletin No. 2019–48 iii November 25, 2019
Finding List of Current Actions on
Previously Published Items
1
Bulletin 2019–48
1
A cumulative list of all revenue rulings, revenue procedures, Treasury decisions, etc ., published in Internal Revenue Bulletins 2018–27 through 2018–52 is in Internal Revenue Bulletin
2018–52, dated December 27, 2018 .

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