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Department of the Treasury

Instructions for Form 3115

Internal Revenue Service

(Rev. December 2009)

Application for Change in Accounting Method

For general rules on changing an accounting method under:

Section references are to the Internal Revenue Code unless

otherwise noted.

Automatic change

See Rev. Proc. 2008-52, as amplified,

request procedures . . . clarified and modified by Rev. Proc.

All references to Rev. Proc. 97-27 are to Rev. Proc. 97-27,

2009-39.

1997-1 C.B. 680 (as modified and amplified by Rev. Proc.

Advance consent

See Rev. Proc. 97-27, as amplified,

2002-19, 2002-1 C.B. 696, as amplified and clarified by Rev.

request procedures . . . clarified and modified by Rev. Proc.

Proc. 2002-54, 2002-2 C.B. 432), as modified by Rev. Proc.

2002-19, Rev. Proc. 2002-54, Rev. Proc.

2007-67, 2007-48 I.R.B. 1072), and as clarified and modified by

2007-67, and Rev. Proc. 2009-39.

Rev. Proc. 2009-39, 2009-38 I.R.B. 371, or its successor.

For more information, see Rev. Proc. 2010-1, particularly section 9.

All references to Rev. Proc. 2008-52 are to Rev. Proc.

2008-52, 2008-36 I.R.B. 587 as amplified, clarified and modified

by Rev. Proc. 2009-39, 2009-38 I.R.B. 371, or its successor.

When filing Form 3115, you must determine if the IRS

has published any new revenue procedure, revenue

All references to Rev. Proc. 2010-1 are to Rev. Proc.

ruling, notice, regulation, or other published guidance

CAUTION

2010-1, 2010-1 I.R.B. 1, or its successor.

relating to the specific method the applicant is requesting to

change. This guidance is published in the Internal Revenue

General Instructions

Bulletin. For the latest information, visit

Who Must File

Purpose of Form

The entity or person required to file Form 3115, whether on its

File Form 3115 to request a change in either an overall method

own behalf or on behalf of another entity, is the filer. The entity

of accounting or the accounting treatment of any item.

or person on whose behalf the change in method of accounting

is being requested is the applicant. For example, the common

Two procedures exist under which an applicant may request

parent corporation of a consolidated group is the filer when

a change in method of accounting.

requesting a change in method of accounting for another

member of that consolidated group, and the other member on

Automatic change request procedures. Unless otherwise

whose behalf the Form 3115 is filed is the applicant. For

provided in published guidance, you must file under the

information on the difference between a filer and an applicant,

automatic change request procedures if (a) the change in

see Name(s) and Signature(s) on page 2.

method of accounting is included in those procedures for the

Generally, a Form 3115 must be filed by or on behalf of each

requested year of change, and (b) you are within the scope of

applicant seeking consent to change a method of accounting.

those procedures for the requested year of change. See

An applicant is a taxpayer, a controlled foreign corporation

Automatic Change Request Scope Limitations on page 4. A

(CFC) or 10/50 corporation not engaged in a U.S. trade or

Form 3115 filed under these procedures may be reviewed by

business, or a separate and distinct trade or business of a

the IRS and you will be notified if information in addition to that

taxpayer (for purposes of Regulations section 1.446-1(d)),

requested on Form 3115 is required or if your request is denied.

including a qualified subchapter S subsidiary (QSub) or a

No user fee is required. An applicant that timely files and

single-member limited liability company (single-member LLC),

complies with an automatic change request procedure is

whose method of accounting is being changed.

granted consent to change its accounting method, subject to

For a consolidated group of corporations, the common

review by the IRS National Office and operating division

parent corporation must file Form 3115 for a change in

director. See the instructions for Part I on page 4 and the List of

accounting method for itself or any member of the consolidated

Automatic Accounting Method Changes beginning on page 9.

group.

Ordinarily, file a separate Form 3115 for each change in

For a CFC or 10/50 corporation without a U.S. trade or

method of accounting. However, in some cases you are

business, Form 3115 must be filed by the designated

(controlling domestic) shareholder who retains the jointly

required or permitted to file a single Form 3115 for particular

executed consent described in Regulations section

changes in method of accounting. Further, in some cases you

1.964-1(c)(3)(ii). If the controlling domestic shareholder is a

are required or permitted to file a statement in lieu of a Form

member of a consolidated group, the common parent

3115 for particular changes in method of accounting. See

corporation must file Form 3115 for the controlling domestic

section 6.02(1)(a) and (b) of Rev. Proc. 2008-52, as modified by

shareholder on behalf of the foreign corporation. The controlling

Rev. Proc. 2009-39 for more information.

domestic shareholder(s) (or its common parent) must attach a

Advance consent request procedures. If you are not within

copy of the Form 3115 to its income tax return for its tax year

with or within which the CFC’s or 10/50 corporation’s year of

the scope of any automatic change request procedures for the

change tax year ends.

requested year of change or the accounting method change

you are requesting is not included in those procedures for the

Generally, you must file a separate Form 3115 for each

requested year of change, you may be able to file under the

applicant that is part of a related group of corporations or that is

advance consent request procedures. See Advance Consent

a separate and distinct trade or business of a taxpayer,

Request Scope Limitations on page 6. If the requested change

including a QSub or single-member LLC. However, you may file

is approved, the filer will receive a letter ruling on the requested

a single Form 3115 for multiple applicants in the following

change. File a separate Form 3115 for each unrelated item or

situations.

•

submethod. A user fee is required. See the instructions for Part

A taxpayer requesting an identical change in method of

III on page 6 for more information.

accounting for two or more separate and distinct trades or

Cat. No. 63215H

Instructions For Form 3115 - Application For Change In Accounting Method - Internal Revenue Service - 2009

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