With the recent flurry of activity regarding 2014 tax returns and the Section 263(a) Tangibles Regulations (Rev. Proc. 2015-20), I find myself feeling conflicted about what I should be doing ... Should I be applying myself to mastering the ins and outs of the new Regulations and the safe harbor that will impact my clients?
Or, should I just put the pedal down and focus on processing clients 2014 tax returns, adding the required Section 263(a) statement where necessary or appropriate, and deal with Forms 3115 later?
I have fleeting thoughts about this example in the Regs or that nuance of the Safe Harbor, but I find that I have to push it all off to chase down a truant K-1 or clarify a December dividend payment. And, this lack of attention to the recent guidance renders me uneasy.
I know a lot of folks have thought about and developed plans for dealing with these changes (and are doing so) - especially if your firm has a "team" or department devoted to the Tangibles Regs. But for the smaller firms or practitioners like myself ... where do you put your resources and where do you devote your time?
Have you developed a plan? Are you executing that plan? Or, are you just cranking out the 1040s and extending 1120s with no intention of dealing with the T-Regs after April 15th?