This is archived information that pertains only to the 2006 Tax Year. If you
are looking for information for the current tax year, go to the Tax Prep Help Area.
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. 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 3). 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 3 for more
information and the List of Automatic Accounting Method Changes beginning on page 8.
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 5). If the requested change is approved, the
applicant will receive a letter ruling on the requested change. A user fee is required. See the instructions for Part III
on page 5 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. 2004-1, 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 and, for years after 1995, is available at www.irs.gov.
For more information, see Pub. 538, Accounting Periods and Methods.
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 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 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. However,
a single Form 3115 may
be filed by a parent corporation requesting the identical accounting method change on behalf of more than one member of a consolidated
group.
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 page 2) 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 on page 2 and instructions for lines 4d and 4e on page 4.
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 page 2). 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
applicant's return for the year of change. See also
Late Application on page 2 and instructions for lines 4d and 4e on page 4.
File Form 3115 at the applicable IRS address listed below.
|
For applicants (other than exempt organizations) filing under. . . |
|
Advance consent request procedures |
Automatic change request procedures |
Delivery by mail |
Internal Revenue Service
Attn: CC:PA:LPD
P.O. Box 7604
Ben Franklin Station
Washington, DC 20044
|
Internal Revenue Service
Attn: CC:IT&A (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
Room 5336
1111 Constitution Ave., NW
Washington, DC 20224
|
Internal Revenue Service
Attn: CC:IT&A (Automatic Rulings Branch), Room 4516
1111 Constitution Ave., NW
Washington, DC 20224
|
For exempt organizations filing under the advance consent or automatic change request procedures. .
.
|
By mail |
By designated 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 filer of an automatic change request will not receive an acknowledgment.
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
5.02(2) of Rev. Proc. 2004-1.
In certain circumstances, an automatic extension of time to file is available for automatic change requests. For details,
see section 6.02(3)(b) of
Rev. Proc. 2002-9.
A taxpayer submitting a ruling request for an extension of time to file Form 3115 must pay a user fee for its accounting method
change request and
a separate user fee for its extension request. For the schedule of user fees, see (A)(3)(b) in Appendix A of Rev. Proc. 2004-1.