Who must File Form 3115?

Form 3115 is not supported by the program. 

A person or applicant who needs to change the method of accounting for themselves or on behalf of another entity will need to file Form 3115. According to the IRS, " An applicant is an entity, 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."

When a consolidated group of corporations with a common parent corporation must file, it is on the parent corporation to file Form 3115 to change the method of accounting for themselves and any member of the consolidated group.

However according to the IRS publication", identical changes in methods of accounting for two or more of the following in any combination may be included in a single Form 3115.

1. Members of a consolidated group;
2. Separate and distinct trades or businesses (for purposes of Regulations section 1.446-1(d)) of that entity or member(s) of a consolidated group. Separate and distinct trades or businesses include QSubs and single-member LLCs;
3. Partnerships that are wholly owned within a consolidated group; and
4. CFCs and 10/50 corporations that do not engage in a trade or business within the United States where (i) all controlling domestic shareholders (as provided in Regulations section 1.964-1(c)(5)) of the CFCs and of the 10/50 corporations, as applicable, are members of the consolidated group; or (ii) the taxpayer is the sole controlling domestic shareholder of the CFCs or of the 10/50 corporations."

For information on what is an identical change in method of accounting, see section 15.07(4) of Rev. Proc. 2019-1.

How to file?

 The IRS instructs, for automatic change requests "except if instructed differently, you must file Form 3115 under the automatic change procedures in duplicate as follows.

• Attach the original Form 3115 to the filer's timely filed (including extensions) federal income tax return for the year of change. The original Form 3115 attachment does not need to be signed.
• File a copy of the signed Form 3115 to the address provided in the address chart on this page, 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"

For non-automatic change requests, you must file Form 3115 under the non-automatic change procedures during the tax year for which the change is requested, unless otherwise provided by published guidance. See section 6.03(2) of Rev. Proc. 2015-13.

For information on where to file Form 3115 with the IRS National Office, please see the address chart 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.

Generally the IRS says that they send an acknowledgment of receipt within 60 days after receiving a Form 3115 filed under the non-automatic change procedures. If the filer does not receive an acknowledgment of receipt for a non-automatic change request within 60 days, the filer can inquire to:

Internal Revenue Service
Control Clerk
CC:IT&A, Room 4512
1111 Constitution Ave. NW
Washington, DC 20224

Address Chart for Form 3115