Revised Form 3115 Issued in Draft Form

By Alistair M. Nevius, J.D.

The IRS on Wednesday posted a draft version of a revised Form 3115, Application for Change in Accounting Method, which incorporates revisions to the process for requesting accounting method changes that were made by Rev. Proc. 2015-13. Accompanying draft instructions have not been posted.

Rev. Proc. 2015-13, which was released in January, specifies the procedures taxpayers must use to obtain automatic or advance consent to change an accounting method. Rev. Proc. 2015-13 generally replaces Rev. Proc. 2011-14, the previous revenue procedure governing automatic consent accounting method changes and Rev. Proc. 97-27, the previous revenue procedure governing advance consent for accounting method changes.

Rev. Proc. 2015-13 added new procedural rules for filing accounting method changes, including significant changes for taxpayers under examination. It also shortened the Sec. 481(a) adjustment periods and added a new requirement that Form 3115 be filed with the IRS office in Ogden, Utah, instead of with the IRS National Office.

When finalized, the form will replace the current version, which was issued in 2009. The IRS asks that comments on the draft form be made on its website.

Alistair M. Nevius ( is the JofA’s editor-in-chief, tax.

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