Intangibles capitalization.

• Author: Laffie, Leslie S.
• Position: From the IRS

Rev. Proc. 2004-23 sets forth exclusive administrative procedures for taxpayers to obtain automatic consent to change to an accounting method under recently issued final regulations (TD 9107) on capitalizing costs incurred in acquiring or creating intangibles.

The procedures generally are consistent with the existing procedures for automatic accounting-method changes; however, following the issuance of an advance notice of proposed rulemaking on capitalizing costs incurred as to intangible assets (NPRM REG-125638-01, 1/24/02), some taxpayers changed to accounting methods provided in the final regulations without IRS consent...