Revenue rulings represent the conclusions of the Service on the application of the law to the pivotal facts stated in the revenue ruling. Procedures relating solely to matters of internal management are not published however, statements of internal practices and procedures that affect the rights and duties of taxpayers are published. All published rulings apply retroactively unless otherwise indicated. It is the policy of the Service to publish in the Bulletin all substantive 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. The Internal Revenue Bulletin is the authoritative instrument of the Commissioner of Internal Revenue for announcing official 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. 2019-43, which provides the list of automatic changes in methods of accounting, to expand the applicability of automatic changes for a change in use of certain depreciable property. Finally, this revenue procedure modifies Rev. 2019-08, which provides guidance under § 168(g) related to certain property held by an electing real property trade or business. This revenue procedure also modifies Rev. This revenue procedure explains how a taxpayer changes its method of computing depreciation under § 168(g) for such property to comply with TCDTRA.
The Taxpayer Certainty and Disaster Tax Relief Act of 2020 (TCDTRA), enacted in December 2020, retroactively provides a recovery period of 30 years under the alternative depreciation system in § 168(g) (ADS) for certain residential rental property, as defined in § 168(e)(2)(A) of the Code, placed in service before January 1, 2018, held by an electing real property trade or business as defined in § 163(j)(7)(B), and not previously subject to the ADS.
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