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?