SECTION 5. GENERAL

APPLICATION PROCEDURES AND AUDIT PROTECTION

.01 Qualifying Same-Year Method Change under Existing Automatic Change Guidance .

A method change that is within the scope of section 4 of this revenue procedure that qualifies as an automatic change in the List of Automatic Changes (under Rev. Proc. 2016–29, 2016–21 I.R.B. 880, or any successor) and otherwise satisfies the requirements of paragraphs 5.01(1) (a)–(d) of Rev. Proc. 2015–13 (or any successor), must be implemented by applying the automatic change procedures in Section 6 of Rev. Proc. 2015–13 (or any successor) and the List of Automatic Changes.

.02 Qualifying Same-Year Method Change that Complies with Income Provisions of the Code or the Regulations .

(1) A method change that is within the scope of section 4 of this revenue procedure that is not described in section 5.01 of this revenue procedure, which satisfies the requirements of sections 5.01(1)(c) and (d) of Rev. Proc. 2015–13 (or any successor), and which complies with § 451 of the Code or other guidance, must be implemented by applying the automatic change procedures in section 6 of Rev. Proc. 2015–13 (or any successor). A taxpayer making a change under this section 5.02 must file a Form 3115, check the box for line 1(b), and write “Rev. Proc. 2017–XX” followed by the applicable income provision of the Code or Income Tax Regulations or the applicable relevant guidance. In addition, the taxpayer must attach a brief description of the change and why it satisfies the applicable income provision or guidance referenced in line 1(b) of the Form 3115. (2) A taxpayer with one or more separate and distinct trade(s) or business(es),

within the meaning of § 1.446–1(d), that individually have (a) total assets of less than $10 million as of the first day of the taxable year for which a change in method of accounting is requested, or (b) average annual gross receipts of $10 million or less for the three preceding taxable years, as determined under § 1.263(a)–3(h)(3) (substituting “separate and distinct trade or business” for “taxpayer”), may make the change for each such separate and distinct trade or business on a cut-off basis. Accordingly, a § 481(a) adjustment is neither permitted nor required for each such separate and distinct trade or business. See section 2.07 of Rev. Proc. 2015–13. (3) A § 481(a) adjustment must be computed for the year of change for all separate and distinct trades or businesses other than those for which paragraph 5.02(2) of this revenue procedure provides otherwise and for taxpayers for which paragraph 5.02(2) of this revenue procedure does not apply. See section 7.02 of Rev. Proc. 2015–13.

.03 Multiple Requests . Multiple requests to make qualifying same-year method changes may be made in one request.