SECTION 15. EFFECTIVE DATE

.01 In general . Except as provided in SECTION 15.02, this revenue procedure is effective for Forms 3115 filed on or after January 16, 2015, for a year of change ending on or after May 31, 2014.

.02 Transition rules . (1) Additional time to file Forms 3115 under Rev. Proc. 97–27, Rev. Proc. 2011–14, or this revenue procedure for taxable years ending on or before January 31, 2015.

(a) Notwithstanding § 1.446–1(e)(3)(i), a taxpayer may file a Form 3115 to request the Commissioner’s consent to change a method of accounting for a taxable year- (i) ending on or after November 30, 2014, and on or before January 31, 2015, until March 2, 2015, for a non-automatic change under the procedures of Rev. Proc. 97–27 or this revenue procedure,

(a) The taxpayer must agree, in writing, to accelerate into the revised year of change the percentage of any positive § 481(a) adjustment the taxpayer would have taken into account for each prior taxable year under SECTION 7.03(1) had the taxpayer not revised the year of change, in an amount limited to seventyfive percent of the § 481(a) adjustment. However, the seventy-five percent limitation in this SECTION 13.01(3)(a) for the revised year of change will not apply if the taxpayer requests to revise the year of change to a taxable year for which a provision of this revenue procedure, the Code, or other guidance published in the IRB, requires a § 481(a) adjustment period of two years or less ( see, for example, SECTIONS 7.03(3)(b) and 7.03(4)(a)); and (b) The taxpayer must agree to provide, in a submission of additional information, the § 481(a) adjustment (positive or negative) for the revised year of change within 21 calendar days (or a longer period if agreed to by the national office) after the national office first notifies the taxpayer that its request to revise the year of change is approved.

(4) Examples . Example 1 . A taxpayer requested to revise the year of change for a Form 3115 for a non-automatic change that is pending in the national office to the first succeeding taxable year. The taxpayer must agree to take into account one-half of any positive § 481(a) adjustment in the revised year of change and one-fourth in each of its next two taxable years.

Example 2 . A taxpayer requested to revise the year of change for a Form 3115 for a non-automatic change that is pending in the national office to the third succeeding taxable year. The taxpayer must agree to take into account three-fourths of any positive § 481(a) adjustment in the revised year of change and the remaining one-fourth in the next taxable year.

(5) Multiple applicants on one Form 3115 . If the Form 3115 is for an identical change in method of accounting for more than one applicant, the taxpayer must request to revise the year of change for all applicants to which the Form 3115 relates.

.02 Compelling circumstances . In the case of a taxpayer that does not meet the applicable condition in SECTION 13.01(1)(a), a taxpayer with compelling circumstances may request to revise the year of change for the Form 3115, in lieu of submitting a new Form 3115 for the proposed revised year of change. The taxpayer must demonstrate those compelling circumstances in its written request.

Example . On October 31, 2014, a calendar year partnership with 50 individual partners timely files a

Form 3115 for a non-automatic change under this revenue procedure for its 2014 taxable year. The partnership’s Form 1065, U.S. Return of Partnership Income, and Schedules K–1, Partner’s Share of In- come, Deductions, Credits etc., and the partners’ Forms 1040, U.S. Individual Income Tax Return, for the requested year of change are all due April 15, 2015. The partnership is not extending this due date. On March 17, 2015, the partnership submits a request to revise the year of change for its pending Form 3115 to its 2015 taxable year. Because the Form 3115 is pending in the national office 30 calendar days prior to the due date of the partners’ Forms 1040, the partnership will be unable to provide timely Schedules K–1 that take into account the proposed accounting method change before the partners prepare and file their 2014 Forms 1040 to take into account the partnership’s requested change in method of accounting for the 2014 taxable year. Under these compelling circumstances, the national office will ordinarily allow the partnership to revise the year of change for its Form 3115 to its 2015 taxable year. If the accounting method change is approved for the partnership’s 2015 taxable year, in lieu of taking into account any positive § 481(a) adjustment over four taxable years, the partnership must take into account one-half of any positive § 481(a) adjustment in its 2015 taxable year and one-fourth in each of its next two taxable years.

.03 Submitting a request for a revised year of change . A request to revise the year of change for a Form 3115 pending in the national office must include:

(1) The name of the Form 3115 filer and, if applicable, each applicant, on the Form 3115;

(2) The national office reference number (for example, CAM–123456–14);

(3) The name of the national office contact person for the Form 3115 (if known);

(4) The due date (excluding any extension) for the Form 3115 filer’s federal income tax return for the year of change;

(5) Whether in the proposed revised year of change the taxpayer will cease to engage in the trade or business to which the change in method of accounting relates ( see SECTION 3.04);

(6) A statement agreeing to the applicable conditions in SECTION 13.01(3);

(7) If the request is being submitted pursuant to SECTION 13.02, the compelling circumstances on which the request is based;

(8) The information required in section 9.09 of Rev. Proc. 2015–1 (or successor), as applicable;

(9) The penalties of perjury statement in section 9.08(3) of Rev. Proc. 2015–1 (or successor); and

(10) If applicable, a completed Form 2848, Power of Attorney and Declaration of Representative, for the revised year of change.

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(ii) ending on or after May 31, 2014, and on or before January 31, 2015, (“applicable taxable year”), until the due date of the taxpayer’s timely filed (including any extension) original federal income tax return for the requested year of change for an automatic change under the procedures of Rev. Proc. 2011–14 or this revenue procedure.

(b) A taxpayer applying this transition rule in SECTION 15.02(1) should indicate on the Form 3115 or any attachment that the Form 3115 is filed under the procedures of Rev. Proc. 97–27 or Rev. Proc. 2011–14, as applicable. (c) After March 2, 2015, a taxpayer may not request the Commissioner’s consent to change a method of accounting under the procedures of Rev. Proc. 97–27. After the due date of the taxpayer’s timely filed (including any extension) original federal income tax return for an applicable taxable year a taxpayer may not request the Commissioner’s consent to change a method of accounting under the procedures of Rev. Proc. 2011–14 for such applicable taxable year.

(2) Limited time to convert a Form 3115 filed under Rev. Proc. 97–27 . Unless the national office determines that it would not be in the interest of sound tax administration, a taxpayer may convert a Form 3115 filed under Rev. Proc. 97–27 to a request for consent under this revenue procedure for the same requested change in method of accounting and year of change if the taxpayer is otherwise eligible to use this revenue procedure and:

(a) the Form 3115 was filed before January 16, 2015, and the Form 3115 is pending with the national office on January 16, 2015, or

(b) the Form 3115 was filed on or after January 16, 2015, and on or before March 2, 2015. A taxpayer may convert a Form 3115 under this SECTION 15.02(2) to the nonautomatic change procedures, if eligible, by notifying the national office contact person (if unknown, see section 9.08(6) of Rev. Proc. 2015–1 (or successor)) before the later of (a) March 31, 2015, or (b) the issuance of a letter ruling granting or denying consent for the change. The notification should indicate that the taxpayer chooses to convert the Form 3115 to conform to the nonautomatic change procedures.

A taxpayer may convert a Form 3115 under this SECTION 15.02(2) to the

automatic change procedures, if eligible, by notifying the national office contact person (if unknown, see section 9.08(6) of Rev. Proc. 2015–1 (or successor)) before the later of (a) March 31, 2015, or (b) the issuance of a letter ruling granting or denying consent for the change. The notification should indicate that the taxpayer chooses to convert the Form 3115 to conform to the automatic change procedures. If the taxpayer timely notifies the national office that it chooses to convert the Form 3115 under this SECTION 15.02(2) to the automatic change procedures, the national office will send a letter to the taxpayer acknowledging its request and will return the user fee submitted with the Form 3115.

A taxpayer converting a Form 3115 under this SECTION 15.02(2) to the automatic change procedures must resubmit a Form 3115 that conforms to the automatic change procedures, with a copy of the national office letter sent acknowledging the taxpayer’s request under this SECTION 15.02(2) attached, to the IRS in Ogden, UT by the earlier of (a) the 30th calendar day after the date of the national office’s letter acknowledging the taxpayer’s request under this SECTION 15.02(2), or (b) the date the taxpayer is required to file the Ogden copy of the Form 3115 under SECTION 6.03(1)(a)(i)(B). See SECTION 6.03(3) regarding additional required copies of Form 3115.

For purposes of the eligibility rules in SECTION 5, the Ogden copy of the timely resubmitted Form 3115 under this SECTION 15.02(2) will be considered filed as of the date the taxpayer originally filed the converted Form 3115 under Rev. Proc. 97– 27. This SECTION 15.02(2) does not extend the date the taxpayer must file the original (converted) Form 3115 under SECTION 6.03(1)(a)(i)(A).

A Form 3115 filed under Rev. Proc. 97–27 or Rev. Proc. 2011–14 before January 16, 2015, will be disregarded for purposes of the prior five year change rules in SECTIONS 5.04 and 5.05 if the taxpayer converts the Form 3115 pursuant to this SECTION 15.02(2).

(3) Early election of one-year § 481(a) adjustment period for certain Forms 3115 filed under Rev. Proc. 97–27 and Rev. Proc. 2011–14 . If a taxpayer filed a Form 3115 under Rev. Proc. 97–27 or the na

tional office or Ogden copy of a Form 3115 filed under Rev. Proc. 2011–14 for a taxable year ending on or after May 31, 2014, and has not filed its original federal income tax return for the year of change implementing the change in method of accounting, the taxpayer may:

(a) apply the de minimis election in SECTION 7.03(3)(c), which permits a one-year § 481(a) adjustment period (year of change) for a positive § 481(a) adjustment that is less than $50,000 to that Form 3115. A taxpayer applying this SECTION 15.02(3)(a) must include a statement with its federal income tax return for the year of change indicating that the Form 3115 is filed under the provisions of SECTION 15.02(3)(a) of Rev. Proc. 2015–13.

(b) apply the eligible acquisition transaction election in SECTION 7.03(3)(d), which permits a one-year § 481(a) adjustment period (year of change) for a positive § 481(a) adjustment if, during the year of change or in the subsequent taxable year on or before the due date (including any extension), for filing the taxpayer’s federal income tax return for the year of change, an eligible acquisition transaction, as defined in SECTION 7.03(3)(d)(iii), occurs. A taxpayer applying this SECTION 15.02(3)(b) must include a statement with its federal income tax return for the year of change indicating that the Form 3115 is filed under the provisions of SECTION 15.02(3)(b) of Rev. Proc. 2015–13.

(4) Request to revise the year of change for a Form 3115 filed under Rev. Proc. 97–27 on or before the last day of the 6th month of the year of change . A taxpayer with a Form 3115 filed under Rev. Proc. 97–27 pending with the national office on January 16, 2015, may request to revise the year of change under SECTION 13.01(1)(b), subject to the taxpayer satisfying the other conditions of SECTION 13.

(5) Open 90-day window period . If, on January 16, 2015, a taxpayer is within the 90-day window period provided in section 6.01(2) of Rev. Proc. 97–27 or section 6.03(2) of Rev. Proc. 2011–14, the taxpayer may file a Form 3115 under this revenue procedure during the remainder of that 90-day window period, if the taxpayer is otherwise eligible to file under

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both (a) section 6.01(2) of Rev. Proc. 97–27 or section 6.03(2) of Rev. Proc. 2011–14 and (b) this revenue procedure on the date the taxpayer files the Form 3115. All provisions of this revenue procedure, including the terms and conditions, will apply to a Form 3115 filed pursuant to this SECTION 15.02(5) on or after January 16, 2015, except as provided in SECTIONS 15.02(1) and 15.02(2). If the taxpayer files a Form 3115 during the remainder of an open 90-day window period pursuant to this SECTION 15.02(5), the taxpayer should include a statement with its Form 3115 indicating that it is filed under the provisions of SECTION 15.02(5) of Rev. Proc. 2015–13.