Who Must File

The filer is the entity or person required to file Form 3115, whether on its own behalf or on behalf of another entity. An applicant is an entity, a person, or a separate and distinct trade or business of an entity or a person (for purposes of Regulations section 1.446-1(d)), whose accounting method is being changed.

For a consolidated group of corporations, the common parent corporation must file Form 3115 for an accounting method change for itself and for any member of the consolidated group. For example, the common parent corporation of a consolidated group is the filer when requesting an accounting method change for another member of that consolidated group (or a separate and distinct trade or business of that member), and the other

Feb 7, 2023 Cat. No. 63215H

member (or trade or business) on whose behalf Form 3115 is filed is the applicant.

For information on the difference between a filer and an applicant, see Name(s) and Signature(s), later.

For information on a controlled foreign corporation (CFC) or 10/50 corporation without a U.S. trade or business, see section 6.02(6) of Rev. Proc. 2015-13.

Generally, a filer must file a separate Form 3115 for each applicant seeking consent to change an accounting method. A separate Form 3115 and user fee (for non-automatic change requests) must be submitted for each applicant and each separate trade or business of an applicant, including a qualified subchapter S subsidiary (QSub) or a single-member limited liability company (LLC), requesting an accounting method change. See section 9.02 of Rev. Proc. 2023-1.

However, identical accounting method changes for two or more of the following in any combination may be included in a single Form 3115.

1. Entities with a common sponsor.

2. Members of a consolidated group;

3. Separate and distinct trades or businesses (for purposes of Regulations section 1.446-1(d)) of that entity or member(s) of a consolidated group. Separate and distinct trades or businesses include QSubs and single-member LLCs;

4. Partnerships that are wholly owned within a consolidated group; and

5. CFCs and 10/50 corporations that do not engage in a trade or business within the United States where (i) all controlling domestic shareholders (as provided in Regulations section 1.964-1(c)(5)) of the CFCs and of the 10/50 corporations, as applicable, are members of a consolidated group; or (ii) the taxpayer is the sole controlling domestic shareholder of the CFCs or of the 10/50 corporations.

For information on what is an identical accounting method change, see section 15.07(4) of Rev. Proc. 2023-1.