The IRS on January 19, 2016, posted on its website a revised Form 3115, Application for Change in Accounting Method, and Instructions (with a revision date of December 2015) to incorporate changes to the revised procedures for requesting accounting method changes made by Rev. Proc. 2015-13. Form 3115 has been slightly reorganized—a few questions on the prior version of Form 3115 have been removed; and several new questions have been added. The Instructions contain more helpful material and guidance on information needed to respond fully to the questions on the form than the prior version of the instructions.
The following automatic changes must provide the legal basis supporting the proposed method:
|Designated Automatic Accounting Method Change||Description of Automatic Change|
|6||bad debt conformity for banks (section 166)|
|7||impermissible to permissible depreciation or amortization (sections 56, 167, 168, 197, 280F, 1400I, 1400L, 1400N, and former section 168)|
|28||bonus or vacation pay deferred compensation (section 404)|
|51||small taxpayer inventory exception (section 471)
|54||impermissible methods of inventory identification and valuation (section 471)|
|55||core alternative valuation method for remanufactured and rebuilt motor vehicle parts (section 471)|
|64||mark-to-market (section 475)|
|65||dealer status changes (section 475)|
|82||credit card late fees (section 451)|
|94||credit card cash advance fees (section 451)|
|108||change by bank for uncollected interest (section 446)|
|111||advance trade discount method (section 471)|
|114||rolling-average method of accounting for inventories (sections 471 and 472)|
|127||change to overall cash/hybrid method for certain banks (section 446)|
|194||change to a reasonable allocation method for self-constructed assets (section 263A)|
|200 (only for certain changes)||permissible to permissible depreciation of MACRS property (section 168)|
|205 (only for certain changes)||dispositions of a building or structural component (section 168)|
|206 (only for certain changes)||dispositions of tangible depreciable assets other than a building or its structural components (section 168)
|207 (only for certain changes)||dispositions of tangible depreciable assets in a general asset account (section 168)|
|211||bad debt conformity election by bank after previous election automatically revoked (section 166)|
|218||change from the mark-to-market method of accounting to a realization method (section 475)|
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