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1.280F-6(f)(2)(iv) and section 6.11 in the Appendix of Rev.

101. Election to treat certain reforestation expenditures as

Proc. 2008-52.

expenses (section 194) — for an applicant’s first or second tax

year ending on or after December 31, 2005, to elect to deduct

90. Insurance companies’ incentive payments to health

reforestation expenditures with respect to any qualified timber

care providers (section 446) — for deducting provider

property paid or incurred after October 22, 2004, as provided in

incentive payments, to the method of including those payments

section 194(b). See section 8.02 in the Appendix of Rev. Proc.

in discounted unpaid losses without regard to section 404. See

2008-52.

section 14.07 in the Appendix of Rev. Proc. 2008-52.

102. Election to treat certain desulfurization costs as

91. Up-front network upgrade payments received by

expenses (section 179B) — for a small business refiner (as

utilities (section 61) — to a safe harbor method provided in

defined in section 45H(c)(1)) for its first or second tax year

Rev. Proc. 2005-35, 2005-2 C.B. 76. See section 1.01 in the

ending on or after December 31, 2005, to elect to deduct 75

Appendix of Rev. Proc. 2008-52.

percent of qualified capital costs (as defined in section

92. Allocation of environmental remediation costs to

45H(c)(2)) paid or incurred after December 31, 2002, in tax

production (section 263A) — to a method that allocates under

years ending after that date. See section 8.03 in the Appendix

section 263A environmental remediation costs to the inventory

of Rev. Proc. 2008-52.

produced during the tax year such costs are incurred. See Rev.

103. Qualifying electric transmission transactions (section

Rul. 2005-42, 2005-2 C.B. 67, and section 11.06 in the

451(i)) — for an applicant’s first or second tax year ending on or

Appendix of Rev. Proc. 2008-52.

after December 31, 2005, for qualified gain from a qualifying

93. Obsolete.

electric transmission transaction, to recognizing all or part of

94. Credit card cash advance fees (section 451) — to a

the qualified gain ratably over the 8-year period beginning with

method that treats credit card cash advance fees as creating or

the year that includes the date of the transaction, as provided in

increasing original issue discount (OID) on a pool of credit card

section 451(i). See section 15.09 in the Appendix of Rev. Proc.

loans that includes the cash advances that give rise to the fees.

2008-52.

See section 15.08 in the Appendix of Rev. Proc. 2008-52.

104. GO Zone additional first year depreciation deduction

95. Obsolete.

(section 1400N(d)) — for qualified GO Zone property placed in

96. Replacement cost method for heavy equipment

service by the taxpayer on or after August 28, 2005, during tax

dealers’ parts inventory (sections 471 and 472) — to the

year beginning in 2004 or 2005, to claiming the GO Zone

replacement cost method for heavy equipment dealers’ parts

additional first year depreciation deduction for a class of

inventory described in Rev. Proc. 2006-14, 2006-1 C.B. 350.

property for which the taxpayer did not claim the GO Zone

Complete Schedule D, Parts II and III, of Form 3115, as

additional first year depreciation deduction on the taxpayer’s

applicable. See section 21.08 in the Appendix of Rev. Proc.

2004 or 2005 federal tax return. This change in method of

2008-52.

accounting must be timely filed with the taxpayer’s federal tax

97. Depreciation of qualified revitalization building in the

return for the first tax year succeeding the 2004 or 2005 tax

expanded area of a renewal community (section 1400I) — for

year, as applicable. Complete Schedule E of Form 3115. See

a qualified revitalization building that is placed in service by the

section 6.15 in the Appendix of Rev. Proc. 2008-52.

applicant after December 31, 2001, in the area of a renewal

105. Additional first year depreciation deduction (sections

community that was expanded by the U.S. Department of

168 and 1400L) — for a change for depreciation under section

Housing and Urban Development and for which the applicant

168(k) or 1400L(b) to comply with Regulation section

receives a retroactive commercial revitalization expenditure

1.168(k)-1 or 1.1400L(b)-1 because of revisions made to

allocation. This change applies only if the applicant filed the

Regulation section 1.168(k)-1T or 1.1400L(b)-1T by the final

federal tax return for the placed-in-service year of that building

regulations. This change in method of accounting must be

on or before the date the applicant received the retroactive

made for either (i) the applicant’s last tax year ending before

commercial revitalization expenditure allocation. Complete

October 1, 2006, if the applicant’s federal income tax return is

Schedule E of Form 3115. See section 6.12 in the Appendix of

timely filed (including an extension) after October 18, 2006, for

Rev. Proc. 2008-52.

that last tax year; or (ii) the applicant’s first tax year ending on

98. Insurance contracts acquired in an assumption

or after October 18, 2006. Complete Schedule E of Form 3115.

reinsurance transaction (section 197) — for an applicant’s

See section 6.16 in the Appendix of Rev. Proc. 2008-52.

first tax year ending after April 10, 2006, for certain insurance

106. Timing of incurring certain liabilities for services or

contracts acquired in an assumption reinsurance transaction, to

insurance (section 461) — for an applicant that is currently

comply with Regulations section 1.197-2(g)(5). See Regulations

treating the mere execution of a contract for services or

section 1.197-2(g)(5) and section 6.13 in the Appendix or Rev.

insurance as establishing the fact of the liability under section

Proc. 2008-52.

461 and wants to change from that method for liabilities for

99. Elections to treat participations and residuals under

services or insurance to comply with Rev. Rul. 2007-3, 2007-4

the income forecast method (section 167(g)) — for certain

I.R.B. 350. See section 19.06 in the Appendix of Rev. Proc.

property subject to the income forecast method under section

2008-52.

167(g) to elect either to include in the adjusted basis of the

107. Impermissible to permissible method of accounting

property, participations and residuals expected to be paid

for depreciation or amortization for disposed depreciable

before the end of the tenth tax year following the tax year in

or amortizable property (sections 167, 168, 197, 1400I,

which the property is placed in service, or to exclude

1400L(b), 1400L(c), or 1400N(d) or former 168) — for an item

participations and residuals from the adjusted basis of the

of certain depreciable or amortizable property that has been

property and deduct the participations and residuals in the tax

disposed of by the applicant and for which the applicant did not

year that the participations and residuals are paid. This change

take into account any depreciation allowance or did take into

must be filed with the applicant’s federal tax return for the first

account some depreciation but less than the depreciation

or second tax year ending on or after December 31, 2005.

allowable, from using an impermissible method of accounting

Complete Schedule E of Form 3115. See section 6.14 in the

for depreciation to using a permissible method of accounting for

Appendix of Rev. Proc. 2008-52.

depreciation. Complete Schedule E of Form 3115. See section

100. Election to treat the cost of any qualified film or

6.17 in the Appendix of Rev. Proc. 2008-52.

television production as an expense (section 181) — for any

108. Change by bank for uncollected interest (section

qualified film or television production subject to section 181 for

446) — for a bank (as defined in Regulation section

which the applicant begins principal photography after October

1.166-2(d)(4)(i)) that uses an accrual method of accounting; is

22, 2004, and before January 1, 2009, to elect to treat the costs

subject to supervision by Federal authorities, or by state

of the production as an expense, as provided for in section 181.

authorities maintaining substantially equivalent standards; and

This change must be filed with the applicant’s federal tax return

has six or more years of collection experience to change to the

for the first or second tax year ending on or after December 31,

safe harbor method of accounting for uncollected interest (other

2005. See section 8.01 in the Appendix of Rev. Proc. 2008-52.

than interest described in Regulation section 1.446 – 2(a)(2)) set

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Instructions For Form 3115 - Application For Change In Accounting Method - Internal Revenue Service - 2009 Page 14

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