Instructions for Form 3115 (03/2012)

What's New

Future developments. The IRS has created a page on IRS.gov for information about Form 3115 at www.irs.gov/form3115. Information about any future developments affecting Form 3115 (such as legislation enacted after we release it) will be posted to that page.

Purpose of Form

File Form 3115 to request a change in either an overall method of accounting or the accounting treatment of any item.

Two procedures exist under which an applicant may request a change in method of accounting.

Automatic change request procedures. Unless otherwise provided in published guidance, you must file under the automatic change request procedures if (a) the change in method of accounting is included in those procedures for the requested year of change, and (b) you are within the scope of those procedures for the requested year of change. See Automatic Change Request Scope Limitations, later. A Form 3115 filed under these procedures may be reviewed by the IRS and you will be notified if information in addition to that requested on Form 3115 is required or if your request is denied. No user fee is required. An applicant that timely files and complies with an automatic change request procedure is granted consent to change its accounting method, subject to review by the IRS National Office and operating division director. See the instructions for Part I and the List of Automatic Accounting Method Changes, later.

Ordinarily, a taxpayer is required to file a separate Form 3115 for each change in method of accounting. However, in some cases you are required or permitted to file a single Form 3115 for particular concurrent changes in method of accounting. Further, in some cases you are required or permitted to file a statement in lieu of a Form 3115 for particular changes in method of accounting. See section 6.02(1)(a) and (b) of Rev. Proc. 2011-14 for more information.

Advance consent request procedures. If you are not within the scope of any automatic change request procedures for the requested year of change or the accounting method change you are requesting is not included in those procedures for the requested year of change, you may be able to file under the advance consent request procedures. See Advance Consent Request Scope Limitations, later. If the requested change is approved, the filer will receive a letter ruling on the requested change. File a separate Form 3115 for each unrelated item or submethod. A user fee is required. See the instructions for
Part III later for more information.

For general rules on changing an accounting method under:

Automatic change request procedures	See generally Rev. Proc. 2011-14.
Advance consent request procedures	See Rev. Proc. 97-27, as amplified, clarified and modified by Rev. Proc. 2002-19, Rev. Proc. 2002-54, Rev. Proc. 2007-67, Rev. Proc. 2009-39, and Rev. Proc. 2011-14.
For more information, see Rev. Proc. 2012-1 (or its successor), particularly section 9.

When filing Form 3115, you must determine if the IRS has published any new revenue procedure, revenue ruling, notice, regulation, or other published guidance relating to the specific method the applicant is requesting to change. This guidance is published in the Internal Revenue Bulletin. For the latest information, visit IRS.gov.

Who Must File

The entity or person required to file Form 3115, whether on its own behalf or on behalf of another entity, is the filer. The entity, trade or business, or person on whose behalf the change in method of accounting is being requested is the applicant. For example, the common parent corporation of a consolidated group is the filer when requesting a change in method of accounting for another member of that consolidated group (or a separate and distinct trade or business of that member), and the other member (or trade or business) on whose behalf the Form 3115 is filed is the applicant. For information on the difference between a filer and an applicant, see Name(s) and Signature(s), later.

An applicant is an entity or a person, or a separate and distinct trade or business of an entity or a person (for purposes of Regulations section 1.446-1(d)), whose method of accounting is being changed.

For a consolidated group of corporations, the common parent corporation must file Form 3115 for a change in method of accounting for itself or any member of the consolidated group.

For a CFC or 10/50 corporation without a U.S. trade or business, Form 3115 must be filed by the designated (controlling domestic) shareholder who retains the jointly executed consent described in Regulations section 1.964-1(c)(3)(ii). If the controlling domestic shareholder is a member of a consolidated group, the common parent corporation must file Form 3115 for the controlling domestic shareholder on behalf of the foreign corporation. For an automatic change, the controlling domestic shareholder(s) (or its common parent) must attach a copy of the Form 3115 to its income tax return for its tax year with or within which the CFCs or 10/50 corporation's year of change tax year ends.

Generally, a filer must file a separate Form 3115 for each applicant seeking consent to change a method of accounting. For example, a filer must file a separate Form 3115 for each corporation (with a single trade or business) that is part of a related group of corporations. A filer also must file a separate Form 3115 for each separate and distinct trade or business (including a QSub or single-member LLC) of each corporation or other entity, even if the requested change in method of accounting will be used by all separate and distinct trades or businesses of an entity.

Each partnership entity must file on its own behalf even if multiple related or tiered partnership entities are filing for identical changes in method of accounting.

There are three limited exceptions to the requirement to file a separate Form 3115 for each applicant seeking consent to change a method of accounting. The filer may file a single Form 3115 for multiple applicants in each of the 3 following situations (separately, but not in any combination):

A common parent of a consolidated group or other entity requesting an identical change in method of accounting for two or more (a) members of that consolidated group, or (b) separate and distinct trades or businesses (for purposes of Regulations section 1.446-1(d)) of that entity or members of the consolidated group, including a QSub or single-member LLC.
A common parent of a consolidated group requesting an identical change in method of accounting on behalf of two or more controlled foreign corporations (CFCs) or noncontrolled section 902 corporations (10/50 corporations), or separate and distinct trades or businesses of a CFC or 10/50 corporation, that do not engage in a trade or business within the United States where all controlling U.S. shareholders of the CFC and all majority domestic corporate shareholders of the 10/50 corporations are members of the consolidated group.
A taxpayer requesting an identical change in method of accounting on behalf of two or more CFCs or 10/50 corporations, or separate and distinct trades or businesses of a CFC or 10/50 corporation, that do not engage in a trade or business within the United States for which the taxpayer is the sole controlling U.S. shareholder of the CFCs or the sole domestic corporate shareholder of the 10/50 corporation (or any separate and distinct trade or businesses of any such CFC or 10/50 corporation).

For information on what is an identical change in method of accounting, see section 15.07(4) of Rev. Proc. 2012-1.

When and Where To File

Automatic change requests. Except as otherwise specifically provided, you must file a Form 3115 under the automatic change request procedures in duplicate as follows.

Attach the original to the filer's timely filed (including extensions) federal income tax return for the year of change.
Attach an original filed on behalf of a CFC or 10/50 corporation to the filer's timely filed federal income tax return for the tax year of the filer with or within which the CFCs or 10/50 corporation's year of change tax year ends.

File a copy of the Form 3115 with the IRS National Office, unless the Appendix of Rev. Proc. 2011-14 or other published guidance requires you to file the copy with the IRS office in Ogden, UT, instead of the IRS National Office. File the copy no earlier than the first day of the year of change and no later than the date the original is filed with the federal income tax return for the year of change (or if applicable, for the tax year in which the CFCs or 10/50 corporation's year of change tax year ends).

If you are making more than one change in method of accounting on the same Form 3115 (when permitted) and (1) one method change requires you to file a copy of the Form 3115 with the IRS Office in Ogden, UT, and (2) the other method change(s) being requested requires you to file a copy of Form 3115 with the IRS National Office, file only one copy of the Form 3115 with the IRS Office in Ogden, UT. However, if Rev. Proc. 2011-14 or other published guidance describing the requested change in method of accounting specifically requires you to file a copy of the Form 3115 with both the IRS National Office and the IRS office in Ogden, UT, you must file a copy with each office. See section 3.06 of the Appendix of Rev. Proc. 2011-14 for an example of when published guidance specifically requires you to file a copy with both offices.

Example:

You are requesting consent for a change in method of accounting described in section 6.01 of the Appendix of Rev. Proc. 2011-14 and for a concurrent change to a UNICAP method, as permitted in section 6.01(7)(b) of the Appendix of Rev. Proc. 2011-14. File the copy of the Form 3115 with the IRS office in Ogden, UT.

In specified circumstances you are required to send additional copies of the Form 3115 to another IRS address. For example, you must file additional copies if the applicant is under examination, before an Appeals office, and/or before Federal Court. See section 6.03(c) of Rev. Proc. 2011-14 for more information. See also Late Application below, and, if the applicant is under examination for purposes of Rev. Proc. 2011-14, the instructions for Part II, lines 4d and 4e.

Advance consent requests. You must file Form 3115 under the advance consent request procedures during the tax year for which the change is requested, unless otherwise provided by other published guidance. For example, see Regulations section 1.381(c)(4)-1(d)(2)(iii) and 1.381(c)(5)-1(d)(2)(iii), which provide different deadlines for filing a Form 3115 in the year of a section 381 transaction. If the tax year for which the change is requested is a short period, file Form 3115 by the last day of the short period unless other published guidance provides another deadline. File the Form 3115 with the IRS National Office (see below). File Form 3115 as early as possible during the year of change to provide adequate time for the IRS to respond prior to the due date of the filer's return for the year of change (or if applicable, for the tax year of the filer in which the CFCs or 10/50 corporation's year of change tax year ends). See Late Application below and, if the applicant is under examination for purposes of Rev. Proc. 97-27, as modified by Rev. Proc. 2009-39, and Rev. Proc. 2011-14, and the instructions for
Part II, lines 4d and 4e.

File Form 3115 at the applicable IRS address listed below.

	For applicants (other than exempt organizations) filing . . .
	An advance consent request	The National Office copy of an automatic change request	Ogden, Utah copy
Delivery by mail	Internal Revenue Service Attn: CC:PA:LPD:DRU P.O. Box 7604 Benjamin Franklin Station Washington, DC 20044	Internal Revenue Service Automatic Rulings Branch P.O. Box 7604 Benjamin Franklin Station Washington, DC 20044	Internal Revenue Service 1973 North Rulon White Blvd. Mail Stop 4917 Ogden, UT 84404
Delivery by private delivery service	Internal Revenue Service Attn: CC:PA:LPD:DRU Room 5336 1111 Constitution Ave., NW Washington, DC 20224	Internal Revenue Service Automatic Rulings Branch Room 5336 1111 Constitution Ave., NW Washington, DC 20224	Internal Revenue Service 1973 North Rulon White Blvd. Mail Stop 4917 Ogden, UT 84404

For exempt organizations filing an advance consent request or the National Office copy of an automatic change request		Ogden, Utah copy
By mail	Internal Revenue Service Tax Exempt & Government Entities P.O. Box 2508 Cincinnati, OH 45201	Internal Revenue Service 1973 North Rulon White Blvd. Mail Stop 4917 Ogden, UT 84404
By private delivery service	Internal Revenue Service Tax Exempt & Government Entities 550 Main Street, Room 4024 Cincinnati, OH 45202	Internal Revenue Service 1973 North Rulon White Blvd. Mail Stop 4917 Ogden, UT 84404

The IRS normally sends an acknowledgment of receipt within 60 days after receiving a Form 3115 filed under the advance consent request procedures of Rev. Proc. 97-27. If the filer does not receive an acknowledgment of receipt for an advance request within 60 days, the filer can inquire to:
Internal Revenue Service, Control Clerk, CC:IT&A, Room 4516, 1111 Constitution Ave., NW, Washington, DC 20224.

Note:

The IRS does not send acknowledgments of receipt for automatic change requests.

Late Application

In general, a taxpayer that fails to timely file a Form 3115 will not be granted an extension of time to file except in unusual and compelling circumstances. See Regulations section 301.9100-3 for the standards that must be met. For information on the period of limitations, see section 5.03(2) of Rev. Proc. 2012-1.

However, a limited 6-month extension of time to file Form 3115 may be available for automatic change requests. For details, see section 6.02(3)(d) of Rev. Proc. 2011-14 and Regulations section 301.9100-2.

A taxpayer submitting a ruling request for an extension of time to file Form 3115 must pay a user fee for its extension request and, in the case of an advance consent request, also a separate user fee for its accounting method change request. For the schedule of user fees, see (A)(3)(b), (A)(4), and (A)(5)(d) in Appendix A of Rev. Proc. 2012-1.

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