Rev. Proc. 2008-52

Audio summary

A short audio walkthrough of this rule: what it says and why it matters for your study.

What it holds

Consolidated all automatic accounting method changes into a single procedure with one master appendix listing every automatic change and its terms, including all depreciation changes. It was the exclusive automatic-consent vehicle for cost segregation reclassifications from 2008 to 2011.

Where this comes from

By 2008, the automatic method-change framework had grown over more than a decade into a collection of separate procedures, each covering different types of changes. Finding the right procedure for a given situation required looking through multiple documents.

Rev. Proc. 2008-52 cleaned this up. It collected all automatic accounting method changes into a single procedure with a single appendix, giving practitioners one place to look.

What it established

The procedure served as the sole automatic method-change vehicle starting in 2008. Its appendix listed each approved change by number, describing the scope, the terms, and the Section 481(a) treatment. Depreciation changes, including the impermissible-to-permissible changes that cost segregation creates, had their own appendix entries.

For cost segregation practitioners, this meant a clear, cited appendix entry for the reclassification change. The change number from the appendix went on the Form 3115, giving examiners a direct path to the governing authority.

How it shows up in a study

A cost segregation study done between 2008 and 2011 would have cited this procedure on the Form 3115. The appendix entry number confirmed automatic consent was available and identified the specific terms for the depreciation change.

The structure it created is still the model. Rev. Proc. 2011-14 and then Rev. Proc. 2015-13 superseded it, but they kept the appendix-based framework. So knowing this procedure explains why today's Form 3115 still references an appendix change number.

What it does not mean

This procedure is superseded. Rev. Proc. 2011-14 replaced it in 2011, and Rev. Proc. 2015-13 replaced that in 2015. The current procedure governs new method changes today.

The appendix structure also does not make every depreciation change automatic. The procedure only covered changes listed in the appendix. Changes not on the list still required the non-automatic advance consent path.

Category

Methodology & procedure

Applies to

All property types

Status

Vetted

This page explains a tax authority in plain words. It is not tax advice for your situation. The way this authority applies to your property is reviewed by a licensed tax professional. Citation is provided so you or your advisor can read the primary source.