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businesses (for purposes of Regulations section 1.446-1(d)) of

File Form 3115 at the applicable IRS address listed below.

that taxpayer, including a QSub or single-member LLC.

•

A common parent of a consolidated group requesting an

For applicants (other than exempt organizations)

identical change in method of accounting on behalf of two or

filing . . .

more members of the consolidated group.

•

A common parent of a consolidated group requesting an

An advance consent

The National Office copy of an

request

automatic change request

identical change in method of accounting on behalf of two or

more CFCs that do not engage in a trade or business within the

Delivery Internal Revenue Service

Internal Revenue Service

United States where all controlling domestic shareholders of the

by mail

Attn: CC:PA:LPD:DRU

Automatic Rulings Branch

CFCs are members of the consolidated group.

P.O. Box 7604

•

A taxpayer requesting an identical change in method of

Ben Franklin Station

accounting on behalf of two or more CFCs that do not engage

Washington, DC 20044

in a trade or business within the United States for which the

Delivery Internal Revenue Service

Internal Revenue Service

taxpayer is the sole controlling domestic shareholder of the

Attn: CC:PA:LPD:DRU

Automatic Rulings Branch

CFCs.

private

Room 5336

For information on what is an identical change in method of

delivery 1111 Constitution Ave., NW 1111 Constitution Ave., NW

accounting, see section 15.07(4) of Rev. Proc. 2010-1.

service

Washington, DC 20224

When and Where To File

For exempt organizations filing an advance consent request or the

Automatic change requests. You must file a Form 3115

National Office copy of an automatic change request

under the automatic change request procedures in duplicate as

follows.

By mail

By private delivery service

•

Attach the original to the filer’s timely filed (including

extensions) federal income tax return for the year of change.

Internal Revenue Service

•

Attach an original filed on behalf of a CFC or 10/50

Tax Exempt & Government Entities Tax Exempt & Government Entities

P.O. Box 2508

550 Main Street, Room 4024

corporation to the filer’s timely filed federal income tax return for

Cincinnati, OH 45201

Cincinnati, OH 45202

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

corporation’s year of change tax year ends.

•

File a copy of the Form 3115 with the IRS National Office

The IRS normally sends an acknowledgment of receipt

(see below) no earlier than the first day of the year of change

within 60 days after receiving a Form 3115 filed under the

and no later than when the original is filed with the federal

advance consent request procedures of Rev. Proc. 97-27. If the

income tax return for the year of change (or if applicable, for the

filer does not receive an acknowledgment of receipt for an

tax year in which the CFC’s or 10/50 corporation’s year of

advance request within 60 days, the filer can inquire to:

change tax year ends).

Internal Revenue Service, Control Clerk, CC:IT&A, Room 4516,

1111 Constitution Ave., NW, Washington, DC 20224.

In specified circumstances you must send an additional

copy of the Form 3115 to another IRS address. See, for

Note: The IRS does not send acknowledgments of receipt for

example, sections 6.02(11) of Rev. Proc. 2008-52 and section

automatic change requests.

3.06 of the Appendix of Rev. Proc. 2008-52, as modified by

Late Application

Rev. Proc. 2009-39. See also Late Application below and, if the

applicant is under examination for purposes of Rev. Proc.

In general, a taxpayer that fails to timely file a Form 3115 will

2008-52, as modified by Rev. Proc. 2009-39, the instructions for

not be granted an extension of time to file except in unusual

lines 4d and 4e on page 5.

and compelling circumstances. See Regulations section

Advance consent requests. You must file Form 3115 under

301.9100-3 for the standards that must be met. For information

the advance consent request procedures during the tax year for

on the period of limitations, see section 5.03(2) of Rev. Proc.

which the change is requested. If the tax year is a short period,

2010-1.

file Form 3115 by the last day of the short tax year. File the

However, a limited 6-month extension of time to file Form

Form 3115 with the IRS National Office (see below). File Form

3115 is sometimes available for automatic change requests.

3115 as early as possible during the year of change to provide

For details, see section 6.02(3)(b) of Rev. Proc. 2008-52 and

adequate time for the IRS to respond prior to the due date of

Regulations section 301.9100-2.

the filer’s return for the year of change (or if applicable, for the

A taxpayer submitting a ruling request for an extension of

tax year of the filer in which the CFC’s or 10/50 corporation’s

time to file Form 3115 must pay a user fee for its extension

year of change tax year ends). See Late Application below and,

request and, in the case of an advance consent request, also a

if the applicant is under examination for purposes of Rev. Proc.

separate user fee for its accounting method change request.

97-27, as modified by Rev. Proc. 2009-39, the instructions for

For the schedule of user fees, see (A)(3)(b) and (A)(5)(d) in

Part II, lines 4d and 4e on page 5.

Appendix A of Rev. Proc. 2010-1.

Specific Instructions

Name(s) and Signature(s)

Enter the name of the filer on the first line of page 1 of Form

3115. For an advance consent request, the Form 3115 and any

attached statements required to be signed must be signed and

dated by, or on behalf of, the filer. For an automatic change

request, the filer must sign and date the copy of the Form 3115

that is sent to the IRS National Office and any additional copy

that is not attached to an income tax return. The Form 3115

attached to the income tax return (including any additional

statements) does not need to be signed. The name and

signature requirements are discussed below.

In general, the filer of the Form 3115 is the applicant.

However, for certain corporations discussed in the following

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Instructions For Form 3115 - Application For Change In Accounting Method - Internal Revenue Service - 2009 Page 2

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