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General Instructions

Purpose of Form

File Form 3115 to request a change in either an overall accounting method or the accounting treatment of any item. File a separate Form 3115 for each unrelated item or submethod, unless the IRS specifically permits (in published guidance) a change for more than one unrelated item or submethod to be requested on a single Form 3115.

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

Automatic Change Request. Unless otherwise provided in published guidance, you must file under the automatic change request procedures if (a) the accounting method change 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 on page 4). 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 on page 4 for more information and the List of Automatic Accounting Method Changes beginning on page 9.

Advance Consent Request. If you are not within the scope of the 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 on page 6). If the requested change is approved, the filer will receive a letter ruling on the requested change. A taxpayer may not take an advance consent change in accounting method into account in any federal income tax return until the taxpayer receives the letter ruling granting permission to make the accounting method change and the taxpayer signs and returns the Consent Agreement copy of that letter ruling. See Regulations section 1.446-1(e)(2)(i) and section 9.17 of Rev. Proc. 2006-1. A user fee is required. See the instructions for Part III on page 6 for more information.

For general rules on changing an accounting method under:

Automatic change request procedures See Rev. Proc. 2002-9, as modified by Announcement 2002-17, Rev. Proc. 2002-19, and Rev. Proc. 2002-54.
Advance consent request procedures See Rev. Proc. 97-27, as modified by Rev. Proc. 2002-19 and Rev. Proc. 2002-54.
For more information, see Rev. Proc. 2006-1, particularly section 9.

When filing Form 3115, applicants must determine if the IRS has published an accounting method 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 years after 1995, Internal Revenue Bulletins are available at www.irs.gov.

For more information, see Pub. 538, Accounting Periods and Methods.

Who Must File

Generally, a Form 3115 must be filed by or on behalf of each applicant seeking consent to change an accounting method. An “applicant” is a taxpayer or a separate and distinct trade or business of a taxpayer (for purposes of Regulations section 1.446-1(d)), including a qualified subchapter S subsidiary (QSUB) or a single-member limited liability company (single-member LLC), whose accounting method is being changed.

For a consolidated group of corporations, the parent corporation must file the Form 3115 for a change in accounting method for itself or any member of the consolidated group. For a controlled foreign corporation (CFC) or 10/50 corporation without a U.S. trade or business, the Form 3115 must be filed, respectively, by the controlling U.S. shareholder(s) or majority domestic corporate shareholder(s). If the U.S. shareholder(s) is a member of a consolidated group, the parent corporation must file Form 3115 for the U.S. shareholder on behalf of the foreign corporation.

Generally, a separate Form 3115 must be filed for each applicant that is part of a related group of corporations or that is a separate and distinct trade or business of a taxpayer, including a QSUB or single-member LLC. However, a single Form 3115 may be filed for multiple applicants in the following situations.

  1. A taxpayer requesting an identical accounting method change for two or more separate and distinct trades or businesses (for purposes of Regulations section 1.446-1(d)) of that taxpayer, including a QSUB or single-member LLC;

  2. A common parent of a consolidated group requesting an identical accounting method change on behalf of two or more members of the consolidated group;

  3. A common parent of a consolidated group requesting an identical accounting method change on behalf of two or more CFCs that do not engage in a trade or business within the United States where all controlling U.S. shareholders of the CFCs are members of the consolidated group; or

  4. A taxpayer requesting an identical accounting method change on behalf of two or more CFCs 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.

See section 15.07(4) of Rev. Proc. 2006-1 for what is an identical accounting method change.

When and Where To File

Automatic change requests.   A Form 3115 that is filed under the automatic change request procedures is filed in duplicate. The original must be attached to the filer's timely filed (including extensions) federal income tax return for the year of change. A copy of the Form 3115 must be filed with the IRS National Office (see below) no earlier than the first day of the year of change and no later than when the original is filed with the federal income tax return for the year of change. See also Late Application below and the instructions for lines 4d and 4e on page 5.

Advance consent requests.   A Form 3115 that is filed under the advance consent request procedures must be filed during the tax year for which the change is requested. If the tax year is a short period, file Form 3115 by the last day of the short tax year. File the Form 3115 with the IRS National Office (see below). Form 3115 should be filed 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. See also Late Application below and the instructions for lines 4d and 4e on page 5.

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
Delivery by mail Internal Revenue Service
Attn: CC:PA:LPD:DRU
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044
Internal Revenue Service
Attn: CC:PA:LPD:DRU (Automatic Rulings Branch)
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044
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
Attn: CC:PA:LPD:DRU (Automatic Rulings Branch)
Room 5336
1111 Constitution Ave., NW
Washington, DC 20224

For exempt organizations filing an advance consent request or the National Office copy of an automatic change request . . .
By mail By private delivery service. . .
Internal Revenue Service
Tax Exempt & Government Entities
Attn: TEGE:EO
P.O. Box 27720
McPherson Station
Washington, DC 20038
Internal Revenue Service
Tax Exempt & Government Entities
Attn: TEGE:EO
1750 Pennsylvania Ave., NW
Washington, DC 20038

The IRS normally acknowledges receipt of a filed Form 3115 for an advance consent request within 60 days after receipt. If an acknowledgement has not been received within 60 days of filing Form 3115, the filer of an advance consent request 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 acknowledgements 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. 2006-1.

However, a limited 6-month extension of time to file Form 3115 is sometimes available for automatic change requests. For details, see section 6.02(3)(b) of Rev. Proc. 2002-9 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) and (A)(5)(d) in Appendix A of Rev. Proc. 2006-1.


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