Significant changes to Form 3115

The IRS posted a revised Form 3115, “Application for Change in Accounting Method,” and accompanying instructions to its website. The IRS posted a revised Form 3115, “Application for Change in Accounting Method,” and accompanying instructions to its website.

The new Form 3115 and instructions contain revisions that incorporate modifications and additions to the accounting method change procedures outlined in Rev. Proc. 2015-13 and Rev. Proc. 2015-14.

Some of the more significant changes contained in the Form 3115 and instructions include:

  • New address for filing the duplicate copy of Form 3115 for an automatic accounting method change request:
    Internal Revenue Service
    201 West Rivercenter Blvd.
    PIN Team Mail Stop 97
    Covington, KY 41011-1424
  • Space allotted to list multiple automatic method change numbers on a single Form 3115, where multiple changes are permitted to be requested on one Form 3115 (Page 1, Part I, Question 1a)
  • Questions revised for applicant(s) subject to the special accounting method rules under section 381 and the regulations thereunder to reflect recent changes to these rules (Page 1, Part II, Question 5)
  • Expanded questions regarding audit protection to reflect changes made by Rev. Proc. 2015-13, including the requirement to disclose the audit protection provisions applicable to the requested change(s) (Page 2, Part II, lines 7a and 7b)
  • A requirement to provide the legal basis for certain automatic method changes enumerated in the Form 3115 filing instructions; previously such disclosures were required only for non-automatic accounting method changes ( Page 3, Part II, lines 16a and 16b)
  • Additional questions pertaining to the new elections to accelerate a positive section 481(a) adjustment for a de minimis adjustment of less than $50,000 or when an eligible transaction occurs during the year of change or in the subsequent year (Page 4, Part IV, line 27)

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