Under the new tangible property regulations published last December, private companies should review their current methods of accounting in light of the temporary regulations to determine if a Form 3115 is required for the years beginning on or after January 1, 2012. If an accounting method change is required, then they should review the new revenue procedures to assess which method changes should be filed in 2012 and/or 2013 to comply with the temporary regulations.

Private companies also should consider calculating the amount deductible under the de minimis rule and ensure all requirements are satisfied (e.g., written accounting procedures at the beginning of the tax year) if they believe they will rely on the safe harbor rule.