SECTION 6. CHANGE IN METHOD

OF ACCOUNTING

.01 In general . The making of a late election under section 4.01(2) or 4.02(2) of this revenue procedure is treated as a change in method of accounting to which §§ 446(e) and 481, and the corresponding regulations, apply. A taxpayer that wants to make a late election under section 4.01(2) or 4.02(2) of this revenue procedure must use the automatic change procedures in Rev. Proc. 2015-13, 2015-5 I.R.B. 419, or its successor.

.02 New automatic change . Rev. Proc. 2022-14, 2022-7 I.R.B. 502, is modified to add new section 6.23 to read as follows:

6.23 Late elections under § 168(j)(8), § 168(l)(3)(D), and § 181(a)(1) .

(1) Description of Change . (a) Applicability . This change applies to:

(i) A taxpayer within the scope of section 3.01 of Rev. Proc. 2022-23, 2022-18 I.R.B. XXX, that wants to make the late election provided in section 4.01(2) of Rev. Proc. 2022-23 under § 168(j)(8) or § 168(l)(3)(D); or

(ii) A taxpayer within the scope of section 3.02 of Rev. Proc. 2022-23 that wants to make the late election provided

May 2, 2022 1054 Bulletin No. 2022–18

in section 4.02(2) of Rev. Proc. 2022-23 under § 181(a)(1).

(b) Inapplicability . The IRS will treat the making of a late election provided in section 4 of Rev. Proc. 2022-23 under §§ 168(j)(8), 168(l)(3)(D), and 181(a)(1) as a change in method of accounting with a § 481(a) adjustment only for the taxable years specified in section 6.23(2) of this revenue procedure. This treatment does not apply to a taxpayer that makes these late elections before or after the time specified in section 6.23(2) of this revenue procedure, and any such late election is not a change in method of accounting.

(2) Time for making the change . The change under section 6.23(1)(a)(i) or (ii) of this revenue procedure must be made with the taxpayer’s first or second timely filed original Federal income tax return or Form 1065, as applicable, that is filed after April 19, 2022.

(3) Certain eligibility rules inapplicable . The eligibility rules in section 5.01(1)(d) and (f) of Rev. Proc. 2015-13, 2015-5 I.R.B. 419, do not apply to a change under section 6.23(1)(a)(i) or (ii) of this revenue procedure.

(4) Certain audit protection excep- tion temporarily inapplicable . Sections 8.02(1) and (7) of Rev. Proc. 2015-13 do not apply to a change in method of accounting made under section 6.23(1)(a)(i) or (ii) of this revenue procedure. However, sections 8.02(1) and (7) of Rev. Proc. 2015-13 continue to apply for purposes of determining the § 481(a) adjustment

period provided in section 7.03(3)(b) of Rev. Proc. 2015-13.

(5) Short Form 3115 . (a) A taxpayer making a change under section 6.23(1)(a)(i) of this revenue procedure is required to complete only the following information on Form 3115 (Rev. December 2018):

(i) The identification section of page 1 (above Part I);

(ii) The signature section at the bottom of page 1;

(iii) Part I; (iv) Part II, lines 6, 7, 8, 9, 14, and 18; (v) Part IV, all lines except line 25; and (vi) Schedule E, all lines except lines 1, 4b, 5, and 6. (b) A taxpayer making the change under section 6.23(1)(a)(ii) of this revenue procedure is required to attach to the taxpayer’s Form 3115 the statement required under § 1.181-2(c)(2)(i) and, if applicable, the statement required under § 1.181-2(c)(2)(ii), and to complete only the following information on Form 3115 (Rev. December 2018):

(i) The identification section of page 1 (above Part I);

(ii) The signature section at the bottom of page 1;

(iii) Part I; (iv) Part II, lines 6, 7, 8, 9, 14, and 18; and

(v) Part IV, all lines except line 25. (6) Concurrent automatic change . A taxpayer making one or more late elections under section 4.01(2) or 4.02(2) of Rev. Proc. 2022-23 for the same year of change should file a single Form 3115 for

all such changes. The single Form 3115 must provide a single net § 481(a) adjustment for all such changes. See section 6.03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(7) Designated automatic accounting method change number . The designated automatic accounting method change number for a change to the method of accounting under this section 6.23 is “264.”

(8) Contact information . For further information regarding a change under this section 6.23, contact James Liechty at (202) 317-7005 (not a toll-free number).