SECTION 1. PURPOSE

This revenue procedure updates and revises the general procedures under § 446(e) of the Internal Revenue Code and § 1.446– 1(e) of the Income Tax Regulations to obtain the consent of the Commissioner of

Internal Revenue (Commissioner) to change a method of accounting for federal income tax purposes. Specifically, this revenue procedure provides the general procedures to obtain the advance (nonautomatic) consent of the Commissioner to change a method of accounting and

provides the procedures to obtain the automatic consent of the Commissioner to change a method of accounting described in Rev. Proc. 2015–14, 2015–5 I.R.B. 450, (or successor) (List of Automatic Changes).

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or by statute, a taxpayer may not change an established method of accounting by amending its prior federal income tax return(s). See Rev. Rul. 90–38, 1990–1 C.B. 57. A taxpayer must secure the consent of the Commissioner regardless of whether the taxpayer’s established or proposed method is a permissible method or clearly reflects the taxpayer’s income and regardless of the administrative guidance used to request consent or to change the established method of accounting. If a taxpayer changes a method of accounting without complying with all the applicable procedures, the taxpayer has initiated a change in method of accounting without obtaining the consent of the Commissioner as required by § 446(e).

(2) Under § 1.446–1(e)(3)(i), to obtain the Commissioner’s consent to change a method of accounting, a taxpayer generally must file a Form 3115, Application for Change in Accounting Method, during the taxable year for which the taxpayer desires to make the proposed change in method of accounting, except as otherwise provided in administrative guidance. Section 1.446–1(e)(3)(ii) provides that the Commissioner may prescribe the administrative procedures under which a taxpayer will be permitted to change its method of accounting. Many Forms 3115 filed under the non-automatic change procedures require additional information and development. Therefore, the IRS recommends that taxpayers file a Form 3115 under the non-automatic change procedures as early as possible during the requested year of change. See also, SECTION 13.01(1)(b).

(3) Rev. Proc. 2011–14, 2011–4 I.R.B. 330, as clarified and modified by Rev. Proc. 2012–39, 2012–41 I.R.B. 470, previously provided procedures for automatic changes in method of accounting listed in its APPENDIX. Rev. Proc. 97–27, 1997–1 C.B. 680, as amplified and modified by Rev. Proc. 2002–19, 2002–1 C.B. 696, as amplified and clarified by Rev. Proc. 2002–54, 2002–2 C.B. 432, as modified by Rev. Proc. 2007–67, 2007–2 C.B. 1072, as clarified and modified by Rev. Proc. 2009–39, 2009–38 I.R.B. 371, as modified by Rev. Proc. 2011–14, 2011–4 I.R.B. 330, and as modified by Rev. Proc. 2012–39, 2012–41 I.R.B. 470, previously provided procedures for non-automatic