Tangible Property (Repair Regs)


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Tangible Property Regulations - Repair Regs Guidance and Resources 

News Alert! 
IRS raises tangible property expensing threshold to $2,500; simplifies filing and recordkeeping for small businesses. Read more.


Pile of wrenches,nuts and bolts


All taxpayers with depreciable assets or who buy, sell, improve, or dispose of assets must comply with the tangible property regulations for tax years beginning on or after Jan. 1, 2014. Certain businesses may need to file Form 3115, Application for Change in Accounting Method, to request a change in accounting method, as well as potentially make new annual elections.

The AICPA offers the below resources and information to help members understand and comply with these new rules.


AICPA Tangible Property Resources

Below are resources developed for AICPA members to aid in the understanding and implementation of Rev. Proc. 2015-20; Tangible Property Regulations:




Practice Aids
Informed Client Consent Letter: Sample letter to assist in communicating the implications of the Tangible Property Regulations to clients who qualify as small business taxpayers under Rev. Proc. 2015-20.
Repair Regs Flowchart: Resource to help you determine when to capitalize or expense a purchase/item (developed by Squire)
Repair Regs. Client Communication Letter: Sample template letter intended to provide high-level guidance on the new repair regs. and encourage the client to consult their CPA to discuss the implications (developed by Squire)
Overview of Tangible Property Regulations: One-page, high-level overview of the new repair regulations, including the recent small business relief with Rev. Proc. 2015-20 written to practitioners; can be used as a companion to the quick summary chart below (developed by Squire)
Quick Summary Chart of the Final Tangible Property Regulations: High-level overview, including definitions, guidance, dispositions, and more
Sample Written Book Capitalization Policy: De minimis safe harbor template for use in establishing a capitalization policy
 Repair Regs.: Frequently Asked Questions (FAQs)
Small Business and the New Sec. 263 Repair Regulations
 Form 3115 Booklet and Excel Spreadsheet (certain resources are free; purchase booklet for $20)

Practice Aids from Eric P. Wallace, CPA

Eric Wallace is a Director at Boyer & Ritter, CPAs and Consultants. He is well known for his expertise in tangible property regulations (section 263(a)); change in accounting methods; NOLs; and Change in Accounting Methods (IRS Form 3115). Eric and the Firm have been the experts on the TPR issues (sections 162, 167, 168, 263(a) and 1016) since their issuance in late 2011.

Below are resources developed for AICPA members, featured articles, and information regarding the TPR Toolkit:

Quick Reference Guide: Tangible Property Regulations: What to File, Where, and When
Examples of the Required and Non-Required Filings of the Tangible Property Regulations
Unit Property Considerations for Landlord Tenant Improvement
Consequences of Not Filing the Required Tangible Property Regulation 3115s by Tax Year 2014
Comprehensive Tangible Property Toolkit - Extensive tools and templates to assist CPA firms and large companies in implementing the highly complex tangible property regulations (TPRs) issued by the IRS. They are a compilation of Word, pdf, Excel, and voice files covering TPR examples (completed 3115s to client communications), tools, templates, and related supporting training for a firm or large business to use to implement the TPRs for its clients or Company. Free trial available; call for pricing.

News & Updates

Regulations, Procedures, and More from the IRS
  • IRS Publication 538, Accounting Periods and Methods
  • 2014 Form 3115 and instructions
  • Tangible Property FAQs
  • Notice 2015-82: addresses the increase in the de minimis safe harbor limit for taxpayers without an applicable financial statement, Nov. 24, 2015
  • Rev. Proc. 2015-20: the new simplified procedure is generally available to small businesses, including sole proprietors, with assets totaling less than $10 million or average annual gross receipts totaling $10 million or less, Feb. 13, 2015
  • Rev. Proc. 2015-13: provides general procedures to obtain both the advance (non-automatic) and automatic consent to change a method of accounting, Jan. 16, 2015
  • Rev. Proc. 2014-54: provides procedures for taxpayers to adopt the new disposition regulations, Sep. 18, 2014
  • Final regulations (T.D.9689) regarding dispositions of depreciable property, Aug. 14, 2014
  • Second part of guidance on accounting method change (Rev. Proc. 2014-17) which superseded Rev. Proc. 2012-20, Feb. 28, 2014
  • Rev. Proc. 2014-16 provides procedures for taxpayers to adopt the final "repair" regulations, Jan. 24, 2014
  • Proposed regulations (REG-110732-13) under section 168 regarding dispositions of tangible depreciable properties, Sep. 13, 2013
  • IRS finalized "repair" regulations (T.D. 9636) under sections 162 and 263, Sep. 13, 2013

Advocacy Efforts
  • April 21, 2015 - AICPA Recommends Increasing the Safe Harbor De Minimis Threshold
  • Nov. 7, 2014, AICPA submitted a letter to the IRS
  • Oct. 23, 2014: Congressmen Rice and Murphy submitted a letter to the IRS
  • Oct. 8, 2014: AICPA submitted a letter to the IRS

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