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Hello, Form 3115 is what you would use to make the catch up depreciation. It is a confusing form I admit but well worth the effort. It really isn’t a change in accounting method but that is the form to use. Put all on that form except for current year ...

Sorry, there is one CAA - the FATCA one that the US now has with most countries. The FATCA one prescribes the use of IDES - international data exchange system. I tend to ignore that one. Usually, it is generic, as it seems to be here.. ------------------------------ ...

Hi John, Do keep in mind that the US-Phillppines treaty dates to 1976. It does not reflect any law changes since then. I do not see any US-Philippines Competent Authority Arrangements (CAA) https://www.irs.gov/individuals/international-taxpayers/competent-authority-arrangements ...