7/3/2014 Daily Tax Report Bloomberg Daily Tax Report® BNA Source: Daily Tax Report: News Archive > 2014 > July > 07/01/2014 > TaxCore® - IRS Documents > Chief Counsel Advice Memorandums > CCA 201426025 - Section 446 - General Rule for Methods of Accounting CCA 201426025 - Section 446 - General Rule for Methods of Accounting Office of Chief Counsel Internal Revenue Service Memorandum Number: 201426025 Release Date: 6/27/2014 CC:ITA:6 POSTF-140487-12 UILC: 446.04-00, 481.00-00 date: January 17, 2014 to: Associate Area Counsel, [redacted data] (CC:LB&I:HMT:[redacted data]) (Large Business & International) from: Senior Counsel, Branch 7 (Income Tax and Accounting) subject: Change in Accounting Method and IRC § 481(a) Adjustment This memorandum responds to your request for assistance. This advice may not be used or cited as precedent. LEGEND Taxpayer = Bank = Years = ISSUES 1. Does a change in accounting method under IRC § 446 occur when Taxpayer no longer treats certain securities transactions as "options?" 2. If a change in accounting method does occur when these transactions that were treated as options no longer are treated as such, does IRC § 481(a) apply and if it does, how should the adjustment be computed? CONCLUSIONS 1. A change in accounting method under IRC § 446 occurs when Taxpayer no longer treats certain securities transactions as options and thus, stops deferring the gains, losses, income, or deductions associated with those transactions. 2. The computation and recognition of an appropriate adjustment under IRC § 481(a) is needed to eliminate any distortions (duplications or omissions of income or deductions) caused by the accounting method change. FACTS Taxpayer (a limited liability company that is treated as a partnership for federal tax purposes) purchases and disposes of positions in securities. Taxpayer generally engages in daily trading of such positions. Taxpayer has conducted much of its securities tradi