Revenue procedure · 2011
Rev. Proc. 2011-14
Rev. Proc. 2011-14, 2011-4 I.R.B. 330
IRS revenue procedure
Audio summary
A short audio walkthrough of this rule: what it says and why it matters for your study.
What it holds
Amplified and superseded Rev. Proc. 2008-52 as the exclusive automatic method-change procedure. Allowed multiple concurrent depreciation changes on a single Form 3115 and moved most copy-filing to Ogden, Utah. Its Section 6.01 is the primary change number for the impermissible-to-permissible depreciation change used in retroactive cost segregation studies.
Why it matters for your study: This was the governing procedure for all automatic cost segregation Form 3115 filings from 2011 to 2015. Its Section 6.01 change number is still referenced in studies done in that window and is important for audit support on older filings.
Where this comes from
Rev. Proc. 2008-52 had consolidated the automatic method-change framework into one document. But by 2011, the IRS needed to update the procedure to reflect changes in the tax law, administrative practice, and the tangible property regulations that were being finalized.
Rev. Proc. 2011-14 superseded 2008-52 and became the governing procedure for automatic method changes for the next four years.
What it established
The procedure kept the appendix structure from its predecessor but updated the list of automatic changes and their terms. One practical improvement: it allowed multiple concurrent depreciation changes on a single Form 3115. Before this, a study with several reclassified asset groups might have needed multiple filings.
Section 6.01 is the specific change entry for the core cost segregation move: changing from an impermissible depreciation method to a permissible one for property that should have been on a shorter recovery period. That section number appeared on Form 3115 filings for studies done between 2011 and 2015.
Most of the procedure has been superseded by Rev. Proc. 2015-13, but Sections 14.04 through 14.07 remain operative.
How it shows up in a study
A study completed between 2011 and 2015 would have cited this procedure and its Section 6.01 change number on the Form 3115. If you are reviewing an older study or responding to an IRS examination on a property from that period, this is the governing authority for the method change that was filed.
The Ogden, Utah copy-filing address from this procedure is still the IRS center that receives most Form 3115 copies today, carried forward under the current procedures.
What it does not mean
Most of this procedure is superseded. Studies done today use Rev. Proc. 2015-13 and its companion Rev. Proc. 2015-14. The current procedures are more comprehensive and better aligned with the tangible property regulations.
The fact that Sections 14.04 through 14.07 remain operative means the procedure is not entirely historical. Those sections still apply to specific situations, and a licensed tax professional can tell you whether they apply to your filing.
Primary source
Read the official text for yourself, or share it with your advisor.
- 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.