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U.S. IRS Issues Revenue Procedure on Method of Accounting for CFCs

12 May 2021

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Approved Changes

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United States

The U.S. IRS has announced the issuance of Revenue Procedure 2021-26 on accounting method changes for CFCs. --- Revenue Procedure 2021-26 provides guidance with respect to accounting method changes made on behalf of certain foreign corporations. The procedure accomplishes the following: expands, for a limited period, the availability of automatic consent for controlled foreign corporations ("CFCs") to change their methods of accounting for depreciation to the alternative depreciation system under section 168(g) in order to ease the burden on CFCs of conforming their income and earnings and profits computations with their qualified business asset investment computations; prescribes terms and conditions...