What is a “Qualifying Taxpayer” under the Repair Regulations?
The final repair regulations1 which were similar but not identical to the temporary repair regulations,2 were to be followed by all taxpayers commencing in taxable years beginning on or after January 1, 2014.3 The temporary regulations were to become effective, generally, for taxable years beginning on or after January 1, 2012 but Ann. 2013-7 stated that the effective date for T.D. 9564 would be January 1, 2014.4 That aspect created considerable confusion among taxpayers and tax practitioners. However, one question posed for the various regulations has been – do small taxpayers have to meet the same classification and reporting requirements as large taxpayers? The answer came, not in the regulations, except for a hint,5 but in Rev. Proc. 2014-166 and Rev. Proc. 2014-54.7