Revenue procedure · 2024

Rev. Proc. 2024-23

2024-23 I.R.B. 1334

IRS revenue procedure

What it holds

The list of accounting method changes the IRS approves automatically. Section 6.01 (change number 7) is the standard cost-seg change from a wrong depreciation method to a right one. Section 6.12 (change number 200) covers regrouping inside MACRS. The IRS refreshes this list about once a year (Rev. Proc. 2025-23 is the most recent update), and the change numbers carry forward.

Why it matters for your study: It is the exact procedure we follow to file a catch-up depreciation change without asking the IRS for special permission each time.

Where this comes from

Rev. Proc. 2015-13 sets the general rules for changing an accounting method, but it does not say which changes qualify for the easy automatic path. That job belongs to a companion list the IRS reissues regularly. Revenue Procedure 2024-23, published in 2024, is one edition of that list. The IRS has since updated it again with Rev. Proc. 2025-23.

Each change on the list carries a designated change number, called a DCN. You write the DCN on Form 3115 so the IRS knows exactly which pre-approved change you are making.

What it established

Section 6 of the list covers depreciation. Section 6.01 is titled impermissible to permissible method of accounting for depreciation or amortization, and its change number is 7. This is the classic cost segregation change: you were depreciating property under a wrong method or life, and you are switching to the correct one. The catch-up flows through a section 481(a) adjustment.

Section 6.12 covers permissible to permissible methods of accounting for depreciation of MACRS property, and its change number is 200. That one applies when both the old and new treatments are allowed and you are reorganizing how assets are grouped or accounted for under the MACRS rules.

Section 6 also includes related changes that matter to building owners, including dispositions of buildings and structural components and partial disposition issues.

How it shows up in a study

When we prepare a look-back study, the Form 3115 almost always cites DCN 7. The form, the section 481(a) computation, and the study's before-and-after depreciation schedules travel together. The DCN is the first field an IRS reviewer checks to confirm the change qualified for automatic consent.

Because the list is refreshed yearly, the citation in a filing should point to whichever edition is in effect for the year of change. The change numbers stay stable across editions, which keeps the process predictable.

What it does not mean

Automatic consent is not automatic approval of your numbers. The IRS agrees you may change methods. It does not agree that your study's allocations are correct, and it can still examine them.

The list also has eligibility limits and timing rules that come from Rev. Proc. 2015-13. Some changes are off the automatic list in certain situations, such as the final year of a trade or business. And this procedure only covers method changes. It does not create deductions on its own. The study has to support every dollar.

Primary source

Read the official text for yourself, or share it with your advisor.

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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.

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