SECTION 4. EFFECTIVE DATE

.01 In general . Except as provided in section 4.02 of this revenue procedure, this revenue procedure is effective January 24, 2014.

.02 Transition rules . The following transition rules apply:

(1) Form 3115 filed under Rev. Proc. 97–27 . If before January 24, 2014, a taxpayer properly filed an application under Rev. Proc. 97–27 requesting consent for a change in method of accounting described in section 3 of this revenue procedure, and the Form 3115 is pending with the national office on January 24, 2014, the taxpayer may choose to make the change under this revenue procedure if the taxpayer is otherwise eligible under this revenue procedure. The taxpayer must notify the national office of its intent to make the change under this revenue procedure prior to the issuance of a letter ruling granting or denying consent for the change. If the taxpayer timely notifies the national office that it will make the change under this revenue procedure, the national office ordinarily will return the Form 3115 to the taxpayer to make the necessary modifications to comply with the applicable provisions of this revenue procedure and will refund the user fee submitted with the Form 3115.

A Form 3115 that is returned to the taxpayer for necessary modifications will be converted to an application under this revenue procedure if the taxpayer resubmits the Form 3115 with the necessary modifications, along with a copy of the national office letter sent with the returned Form 3115, to the national office within 30 calendar days after the date of the IRS’s letter returning the Form 3115 to the taxpayer.

(2) Form 3115 filed under Rev. Proc. 2012–19 . (a) General rule . If a taxpayer properly files an application with the IRS in Ogden,

UT (Ogden Copy) under Rev. Proc. 2012–19 to make a change in method of accounting described in Rev. Proc. 2012–19 and the application was either post-marked or received by the IRS on or before January 24, 2014, the taxpayer makes the change under Rev. Proc. 2012– 19. (b) Option to file an amended applica- tion . If on or before January 24, 2014, a taxpayer properly filed an application under Rev. Proc. 2012–19, the taxpayer may choose to file an amended application for that year of change under this revenue procedure if, by the due date of the federal income tax return for the year of change (excluding extensions), the taxpayer (i) files an original or amended return using the new method of accounting pursuant to this revenue procedure, (ii) attaches the original amended application filed under this revenue procedure to its original or amended return for the year of change, (iii) writes on the top of page 1 of the Ogden Copy of the amended application “FILED UNDER SECTION 4.02(2) OF REV. PROC. 2014–16”; and (iv) sends the Ogden Copy of the amended application to the following address no later than the date the original amended application is filed with the original or amended return: Internal Revenue Service, 1973 North Rulon White Blvd., Mail Stop 4917, Ogden, UT 84404.