New IRS Form 3115 is Now Required for Applications for Accounting Method Changes

On April 7th, the IRS informed taxpayers and tax practitioners that it has issued a revised Form 3115, Application for Change in Accounting Method, and its corresponding tax filing instructions.

IRS Announcement 2023-12 states that the Form 3115 (Rev. December 2022) is now the current Form 3115 and replaces the December 2018 version. IRS Announcement 2023-12 further gives guidance to allow for a reasonable period for taxpayers to transition to the December 2022 Form 3115 as follows:

• The IRS will accept either the December 2022 Form 3115 or the December 2018 Form 3115 if filed by a taxpayer on or before April 18, 2023, unless the use of the December 2022 Form 3115 is specifically required by guidance published in the Internal Revenue Bulletin.
• Taxpayers filing Forms 3115 after April 18, 2023, must use the December 2022 Form 3115.

Section 6.03(1)(a)(i) of Rev. Proc. 2015-13 requires that a taxpayer filing a request for an automatic change file its original Form 3115 with its return and a send a duplicate of that Form 3115 to the IRS in Ogden, Utah. See the Address Chart for Form 3115 on page two of the Instructions for the December 2022 Form 3115.

For duplicate Forms 3115 that are mailed, the address is:

• Internal Revenue Service Ogden, UT 84201 M/S 6111

For duplicate Forms 3115 that are delivered by private delivery service, the address is:

• Internal Revenue Service 1973 N. Rulon White Blvd. Ogden, UT 84201 Attn: M/S 6111

For duplicate Forms 3115 that are delivered by facsimile, the number is (844) 249-8134. Delivery by encrypted electronic mail is not available for automatic change requests.

The new form and instructions can be reviewed at https://www.irs.gov/forms-pubs/about-form-3115

Feel free to reach out to our founder A. Chris Ostler, CPA, to set up a time to discuss the impact of this change.