SECTION 5. EFFECTIVE DATE

.01 In general . This revenue procedure is effective September 18, 2014.

.02 Transition rules . The following transition rules apply:

(1) Form 3115 filed under Rev. Proc. 97–27 .

(a) Conversion to change under this revenue procedure . If before September 18, 2014, a taxpayer properly filed a Form 3115 under Rev. Proc. 97–27, 1997–1 C.B. 680, 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 September 18, 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

October 6, 2014 702 Bulletin No. 2014–41

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.

(b) Filing requirements . A Form 3115 that is returned to the taxpayer for necessary modifications will be converted to a Form 3115 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 IRS in Ogden, UT (mailing address is provided in section 5.02(2)(c)(iv) of this revenue procedure) within the later of (a) the due date specified in section 6.02(3) of Rev. Proc. 2011–14, or (b) 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. 2014–17 . (a) Scope . This section 5.02(2) applies to a taxpayer that properly filed a Form 3115 to make a change in method of accounting under Rev. Proc. 2014–17, 2014–12 I.R.B. 661, to: (i) Apply § 1.168(i)–1T, § 1.168(i)–7T, § 1.168(i)–8T, Prop. Reg. § 1.168(i)–1, Prop. Reg. § 1.168(i)–7, or Prop. Reg. § 1.168(i)–8, for a taxable year beginning on or after January 1, 2012, and beginning before January 1, 2014; or

(ii) Apply § 1.168(i)–7 for a taxable year beginning on or after January 1, 2012.

(b) General rule . If a taxpayer within the scope of this section 5.02(2) properly filed the Form 3115 with the IRS in Ogden, UT (Ogden Copy) under Rev. Proc. 2014–17 to make a change in method of accounting described in section 3.02(5) (permissible to permissible method of accounting for depreciation of MACRS property under § 1.168(i)–7T or Prop. Reg. § 1.168(i)–7), 3.02(9) (late

general asset account elections), 3.03(1) (late partial disposition election), 3.03(2) (revocation of a general asset account election), 3.03(3) (partial dispositions of tangible depreciable assets to which the IRS’s adjustment pertains), or 3.03(5) (permissible to permissible method of accounting for depreciation of MACRS property under § 1.168(i)–7) of Rev. Proc. 2014–17 and the Form 3115 was either post-marked or received by the IRS on or before September 18, 2014, the taxpayer makes the change under Rev. Proc. 2014–17.

(c) Option to file an amended Form 3115 . If on or before September 18, 2014, a taxpayer within the scope of this section 5.02(2) properly filed a Form 3115 under Rev. Proc. 2014–17, the taxpayer may choose to file an amended Form 3115 under this revenue procedure for the same year of change on the Form 3115 filed under Rev. Proc. 2014–17 if, on or before December 31, 2014, the taxpayer (i) files an amended federal income tax return using the new method of accounting pursuant to this revenue procedure, (ii) attaches the original of the amended Form 3115 filed under this revenue procedure to its amended federal income tax return for the year of change, (iii) writes on the top of page 1 of the Ogden Copy of the amended Form 3115 “FILED UNDER SECTION 5.02(2) OF REV. PROC. 2014–54”; and (iv) sends the Ogden Copy of the amended Form 3115 to the following address no later than the date the amended Form 3115 is filed with the amended federal income tax return: Internal Revenue Service, 1973 North Rulon White Blvd., Mail Stop 4917, Ogden, UT 84404.