Form 3115 - Missed Depreciation Page 6
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Form 3115
To make a change under Rev. Proc. 2015-13, the taxpayer must attach Form 3115 to a timely
filed (including extensions) original return for the year of the change. In addition, the taxpayer
must file a copy of Form 3115 with the IRS National Office no earlier than the first day of the
year of change and no later than when Form 3115 is filed with the federal income tax return for
the year of change.
NOTE: The Form 3115 instructions provide that the automatic change number is “7” for
changes from an impermissible method to a permissible method of depreciation for depreciable
property owned at the beginning of the year of change.
An automatic six-month extension from the due date of the return (excluding any extensions) for
the year of change is available if the taxpayer:
Timely filed its federal income tax return for the year of change.
Files an amended return within the six-month extension period in a manner consistent
with the new method of accounting.
Attaches the original Form 3115 to the amended return.
Files a copy of Form 3115 with the National Office no later than when the original is filed
with the amended return.
Attaches a statement to Form 3115 that it is being filed pursuant to Reg. §301.9100-2.
In general, there are no other extensions of time to file Form 3115, except in unusual and
compelling circumstances. See Reg. §301.9100-3 for the standards that must be met.
Understated Depreciation on Disposed Assets
Rev. Proc. 2007-16 allows taxpayers to change their method of accounting for depreciation for
property that has been disposed of if they used an impermissible method of accounting under
which they did not claim any depreciation or less than the amount allowable in the “year of
change” or any prior years. For this purpose, the year of change is the year the property was
disposed of by the taxpayer.
Under Rev. Proc. 2015-13, this automatic change can be made:
On a timely-filed (including extensions) original tax return for the year the property was
disposed of by the taxpayer.
On an amended tax return for the year the property was disposed of if the taxpayer files
the original Form 3115 with the amended return prior to the expiration of the statute of
limitations for such year (generally three years from the due date, including extensions).
A copy of Form 3115 must be filed with the IRS National Office no later than when the
original Form 3115 is filed with the amended return. The amended return must include
the adjustments to taxable income and any collateral adjustments to taxable income or
tax liability resulting from this change in method of accounting.
NATP
*
P.O. Box 8002
*
Appleton, Wisconsin 54912
*
800.558.3402
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