SECTION 6. CHANGE IN METHOD

OF ACCOUNTING

.01 In general. A change to the safe harbor method for linear property and/ or a change to the safe harbor method for non-linear property under this revenue procedure is a change in method of accounting to which the provisions of §§ 446 and 481, and the corresponding regulations, apply. However, section 6.04 of this revenue procedure allows certain taxpayers to choose to change to these methods of accounting on a cut-off basis. A taxpayer that wants to change to the methods of accounting described in this revenue procedure must, if eligible, use the automatic change procedures in Rev. Proc. 2015-13, 2015-5 I.R.B. 419, as clarified and modified by Rev. Proc. 2015-33, 2015-24 I.R.B. 1067, and as modified by Rev. Proc. 2021-34, 2021-35 I.R.B. 337, by Rev. Proc. 2021-26, 2021-22 I.R.B. 1163, by Rev. Proc. 2017-59, 2017-48 I.R.B. 543, and by section 17.02(b) and (c) of Rev. Proc. 2016-1, 2016-1 I.R.B. 1.

.02 Statistical sampling. A taxpayer changing to the NGSH Method may use statistical sampling in determining the § 481(a) adjustment amount attributable to any single taxable year by following the guidance provided in Rev. Proc. 2011-42.

.03 Extrapolation. A taxpayer changing to the NGSH Method may use the extrapolation methodology provided in Appendix B of this revenue procedure (Appendix B) in determining the § 481(a) adjustment amount, if the taxpayer is within the scope of section 1.02 of Appendix B. Extrapolation methodologies not permitted in Appendix B are not permitted under the NGSH Method.

.04 Optional cut-off basis for first 3 taxable years .

(1) Availability of change on a cut- off basis . A taxpayer that changes to the

safe harbor method for linear property for the taxpayer’s first, second, or third taxable year ending after May 1, 2023, may choose to change to this method of accounting on a cut-off basis. See section 2.07 of Rev. Proc. 2015-13. A taxpayer that chooses to change to the safe harbor method for linear property on a cut-off basis under this section 6.04, and also changes to the safe harbor method for non-linear property for the taxpayer’s first, second, or third taxable year ending after May 1, 2023, also must change to the safe harbor method for non-linear property on a cut-off basis, regardless of the year of this change. A taxpayer that changes to the safe harbor method for linear property for the taxpayer’s first, second, or third taxable year ending after May 1, 2013, and does not make this change on a cut-off basis is not permitted to change to the safe harbor method for non-linear property on a cut-off basis.

(2) Effect of change on a cut-off basis . A taxpayer that chooses to change to the NGSH Method on a cut-off basis is not eligible to use the NGSH Method rules under sections 5.02, 5.03, 5.04, 5.05, 5.06, and 5.07 of this revenue procedure for any linear property costs and non-linear property costs paid or incurred prior to the year of change, but must make the late general asset account election for the property described in section 5.08(2)(a)(ii) of this revenue procedure. A § 481(a) adjustment is neither required nor permitted for the change to the NGSH Method on a cut-off basis. Further, a taxpayer that chooses to make this change on a cut-off basis under this section 6.04 does not receive audit protection under section 8.01 of Rev. Proc. 2015-13 in connection with this change. See section 8.02(2) of Rev. Proc 2015-13.

.05 Automatic change. Rev. Proc. 2022-14 is modified to add new section 3.12, to read as follows: 3.12 Natural gas transmission and dis- tribution property method of accounting under Rev. Proc. 2023-15 .

(1) Description of change . (a) Applicability . This change applies to a taxpayer that is within the scope of Rev. Proc. 2023-15 and wants to change its treatment of natural gas transmission and distribution property costs to use the natural gas transmission and distribution property safe harbor method of account

ing (NGSH Method) described in Rev. Proc. 2023-15. Specifically, this change applies to a taxpayer that wants to change to “the safe harbor method for linear property” or “the safe harbor method for non-linear property” and other applicable rules in accordance with Rev. Proc. 2023-15, including the making of a late general asset account election as required under section 5.08(2) of Rev. Proc. 202315. This change also applies to a taxpayer that previously changed to the safe harbor method for linear property and wants to change to the safe harbor method for non-linear property for a subsequent taxable year.

(b) Inapplicability . This change does not apply to the making of a late general asset account election other than in accordance with section 5.08(2) of Rev. Proc. 2023-15. (2) Certain eligibility rules temporarily inapplicable .

(a) In general . The eligibility rules in section 5.01(1)(d) and (f) of Rev. Proc. 2015-13 do not apply to a taxpayer that changes to the NGSH Method provided in Rev. Proc. 2023-15 for its first, second, or third taxable year ending after May 1, 2023. (b) Concurrent automatic change . (i) If a taxpayer makes both a change under this section 3.12 and a change under section 6.12(3)(b) and/or section 6.15 of this revenue procedure for linear property and/or non-linear property for its first, second, or third taxable year ending after May 1, 2023, on a single Form 3115 for the same asset for the same year of change in accordance with section 3.12(6)(b) of this revenue procedure, the eligibility rules in section 5.01(1)(d) and (f) of Rev. Proc. 2015-13 do not apply to the taxpayer for these changes.

(ii) If a taxpayer makes both a change under this section 3.12 and a change under section 11.08, 12.01, 12.02, 12.08, and/or 12.12 of this revenue procedure, as applicable, for its linear property or non-linear property costs in its first, second, or third taxable year ending after May 1, 2023, on a single Form 3115 for the same year of change in accordance with section 3.12(6) of this revenue procedure, the eligibility rules in section 5.01(1)(d) and (f) of Rev. Proc. 2015-13 do not apply to the taxpayer for these changes.

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(3) Manner of making change . (a) Late general asset account election . (i) The late general asset account election change described in section 5.08(2) of Rev. Proc. 2023-15 is made using a modified cut-off method under which the unadjusted depreciable basis and the depreciation reserve of the asset as of the beginning of the year of change are accounted for using the proposed method of accounting. The late general asset account election change requires each general asset account to include a beginning balance for both the unadjusted depreciable basis and the depreciation reserve. The beginning balance for the unadjusted depreciable basis of each general asset account is equal to the sum of the unadjusted depreciable basis as of the beginning of the year of change for all assets included in that general asset account. The beginning balance of the depreciation reserve of each general asset account is equal to the sum of the greater of the depreciation allowed or allowable as of the beginning of the year of change for all assets included in that general asset account.

(ii) For the late general asset account election change described in section 5.08(2) of Rev. Proc. 2023-15, the taxpayer must attach to its Form 3115 a statement providing that the taxpayer agrees to the following additional terms and conditions:

(A) The taxpayer consents to, and agrees to apply, all the provisions of § 1.168(i)-1 to the assets that are subject to the election specified in section 5.08(2) of Rev. Proc. 2023-15; and

(B) Except as provided in § 1.168(i)-1(c)(1)(ii)(A), (e)(3), (g), or (h), the election made by the taxpayer under section 5.08(2) of Rev. Proc. 2023-15 is irrevocable and will be binding on the taxpayer for computing taxable income for the year of change and for all subsequent taxable years with respect to the assets that are subject to this election.

(b) Cut-off basis for certain changes . Except for changes to make a late general asset account election described in section 3.12(3)(a) of this revenue procedure, a change to the NGSH Method described in Rev. Proc. 2023-15 is made on a cut-off basis and applies only to natural gas transmission and distribution property costs

paid or incurred beginning in or after the year of change if–

(i) Sections 5.08(2)(a)(ii) and 6.04 of Rev. Proc. 2023-15 apply (the taxpayer changes to the NGSH Method described in Rev. Proc. 2023-15 for the first, second, or third taxable year ending after May 1, 2023, on a cut-off basis); or (ii) Section 5.08(2)(a)(iii) of Rev. Proc. 2023-15 applies (the taxpayer changes to the NGSH Method described in Rev. Proc. 2023-15 for the fourth taxable year ending after May 1, 2023, or for any subsequent taxable year).

(4) Section 481(a) adjustment . (a) In general . Except as provided in section 3.12(3)(b) of this revenue procedure, a taxpayer changing its methods of accounting under this section 3.12 must take the entire net § 481(a) adjustment into account, whether positive or negative, in computing taxable income for the year of change in the manner provided in section 7.03 of Rev. Proc. 2015-13. The entire net § 481(a) adjustment includes all aspects of the NGSH Method described in Rev. Proc. 2023-15, including a change to the methods of accounting permitted under § 1.168(i)-1 pursuant to section 5.08(2) of Rev. Proc. 2023-15. However, a § 481(a) adjustment is neither required nor permitted for the late general asset account election described in section 5.08(2) of Rev. Proc. 2023-15. Further, a § 481(a) adjustment is neither required nor permitted if the taxpayer chooses to change to the NGSH Method on a cutoff basis under section 6.04 of Rev. Proc. 2023-15 or if the taxpayer changes to this method during the time described in section 5.08(2)(a)(iii) of Rev. Proc. 2023-15.

(b) Repair allowance property . A taxpayer changing its method of accounting under this section 3.12 must not include in the § 481(a) adjustment any amount attributable to property for which the taxpayer elected to apply the repair allowance under § 1.167(a)-11(d)(2) for any taxable year in which the repair allowance election was made.

(c) Statistical sampling . A taxpayer changing to the NGSH Method under this section 3.12 may use statistical sampling in determining the § 481(a) adjustment amount attributable to any single taxable year by following the guidance provided in Rev. Proc. 2011-42, 2011-37 I.R.B. 318.

(d) Extrapolation . A taxpayer changing to the NGSH Method under this section 3.12 may use the extrapolation methodology provided in Appendix B to Rev. Proc. 2023-15 (Appendix B) in determining the § 481(a) adjustment amount if the taxpayer is within the scope of section 1.02 of Appendix B. Extrapolation methodologies not permitted in Appendix B are not permitted under the NGSH Method.

(5) No audit protection for certain tax- payers . If a taxpayer chooses to change to the NGSH Method described in Rev. Proc. 2023-15 on a cut-off basis as permitted under section 6.04 of Rev. Proc. 2023-15 or is required to change on a cutoff basis under section 5.08(3)(b)(i) of Rev. Proc. 2023-15, the taxpayer does not receive audit protection under section 8.01 of Rev. Proc. 2015-13 in connection with this change.

(6) Concurrent automatic changes . (a) A taxpayer making changes under this section 3.12 for more than one asset for the same year of change must file a single Form 3115 for all such assets. The single Form 3115 must provide a single net § 481(a) adjustment for all such changes.

(b) A taxpayer making changes under this section 3.12 and changes under section 6.12(3)(b) and/or section 6.15 of this revenue procedure for linear property or non-linear property costs for the same year of change must file a single Form 3115 for all changes and must enter the designated automatic accounting method change numbers for all changes on the appropriate line on the Form 3115. See section 6.03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(c) A taxpayer making changes under this section 3.12 and also making a coordinating change to its linear property or non-linear property costs under section 11.08, 12.01, 12.02, 12.08, and/or 12.12 of this revenue procedure, as applicable, must file a single Form 3115 for the same year of change for all these changes, provided that the taxpayer is not prohibited from filing an automatic change under the eligibility rules under section 5 of Rev. Proc. 2015-13. For changes required to be filed on a single Form 3115 under this section, the taxpayer must enter the designated automatic accounting method

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change numbers for all changes on the appropriate line on the Form 3115. See section 6.03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(d) A taxpayer that changes to a method of accounting under this section 3.12 for taxable years ending after the third taxable year ending after May 1, 2023 and is also required to change its method of accounting to properly capitalize its linear property or non-linear property costs under § 263(a) and/or § 263A under section 5.08(3)(b)(ii) of Rev. Proc. 2023-15, must file a single Form 3115 for the same year of change for all these changes, provided that the taxpayer is not prohibited from filing an automatic change under the eligibility rules set out in section 5 of Rev. Proc. 2015-13, 2015-5 I.R.B. 419. For changes required to be filed on a single Form 3115 under this paragraph, the taxpayer must enter the designated automatic accounting method change numbers for all changes on the appropriate line on the Form 3115. See section 6.03(1)(b) of Rev. Proc. 2015-13 for information on making concurrent changes.

(7) Examples . The following examples illustrate this section 3.12. In each example, it is assumed that the taxpayer (a) is a C corporation, on an accrual method of accounting and using a calendar taxable year, (b) is within the scope of Rev. Proc. 2023-15, (c) placed in service natural gas transmission property or distribution property that is described in section 4 of Rev. Proc. 2023-15 and is MACRS property, (d) did not make a general asset account election for any natural gas transmission property or distribution property placed in service by the taxpayer in any taxable year before the first taxable year that the taxpayer uses the NGSH Method, (e) is changing its methods of accounting for both linear property and non-linear property under the NGSH Method for the same taxable year, and (f) is not changing to the NGSH Method on a cut-off basis under section 6.04 of Rev. Proc. 2023-15. Unless otherwise stated, it also is assumed that (a) the cost of the replacements before Year 1 were not capitalized under § 263(a), (b) the cost of the replacements before Year 1 would not have been capitalized if the taxpayer used the NGSH Method provided under

sections 5.02, 5.03, 5.04, 5.06, and 5.07 of Rev. Proc. 2023-15 for such prior taxable years, and (c) the taxpayer’s natural gas transmission and distribution property expenditures are not per se capital expenditures under section 5.05(1)(a)-(f), (i), or (j) of Rev. Proc. 2023-15. Further, it is assumed that § 1.168(i)-1(e)(3) (special rules for certain dispositions of assets in general asset accounts) does not apply for the first taxable year that the taxpayer uses the NGSH Method. Moreover, for purposes of these examples, “Year 1” refers to the taxpayer’s first taxable year ending after May 1, 2023, “Year 2” refers to the taxpayer’s second taxable year ending after May 1, 2023, and “Year 4” refers to the taxpayer’s fourth taxable year ending after May 1, 2023.

(a) Example 1 . (i) X is a local natural gas distribution company. Before Year 1, X owned and placed in service natural gas distribution property at a cost of $120 million before any dispositions or additions. Before Year 1, X replaced parts of such property that had an original cost of $10 million and incurred $12 million for the cost of such replacements. On its Federal income tax returns before Year 1, X recognized losses upon the dispositions of that $10 million of property, capitalized $12 million for the cost of the replacements of that property under § 263(a), and deducted depreciation of $800,000 on such $12 million. X files a Form 3115 with its Federal income tax return for Year 1 to change its methods of accounting to use the NGSH Method described in Rev. Proc. 2023-15. (ii) Because Year 1 is X ’s first taxable year ending after May 1, 2023, section 5.08(2)(a)(i) and (3) (a) of Rev. Proc. 2023-15 apply. Pursuant to section 5.08(3)(a) of Rev. Proc. 2023-15, the per se capital expenditure rules in section 5.05(1)(g) and (h) of Rev. Proc. 2023-15 do not apply to the replacement cost of $12 million that X capitalized under § 263(a) on its Federal income tax returns before Year 1. Accordingly, this $12 million cost of the replacements is not treated as a per se capital expenditure under the NGSH Method. Therefore, at the beginning of Year 1, X is treated under Rev. Proc. 2023-15 as owning natural gas distribution property at a cost of $110 million ($120 million - $10 million). Under section 5.08(2)(a)(i) of Rev. Proc. 2023-15, X must make a late general asset account election on its Form 3115 to include in general asset accounts all of the $110 million of natural gas distribution property that X owns at the beginning of Year 1. These general asset accounts also must include the total depreciation allowed or allowable before the beginning of Year 1 for such property as the beginning balances of the depreciation reserves. The late general asset account election change is made on a modified cutoff method and, therefore, a § 481(a) adjustment is neither required nor permitted for the late general asset account election change.

(iii) On its Form 3115 to change to the NGSH Method provided under Rev. Proc. 2023-15, the net negative § 481(a) adjustment for this change is

$11,200,000 (deduction of $12 million for the cost of the replacements before Year 1 less depreciation of $800,000 for such replacement assets before Year

1. and is deducted in computing X ’s taxable income for Year 1.

(b) Example 2 . (i) The facts are the same as in Example 1, except that X files a Form 3115 with its Federal income tax return for Year 2 to change its method of accounting to use the NGSH Method described in Rev. Proc. 2023-15, and, before Year 2, X deducted depreciation of $1,000,000 on the replacement cost of $12 million.

(ii) Because X filed its method change in Year 2, the special rule under section 5.08(3)(a) of Rev. Proc. 2023-15 does not apply to the replacement cost of $12 million that X capitalized under § 263(a) on its Federal income tax returns before Year 1. Accordingly, section 5.05(1)(g) and (h) of Rev. Proc . 2023-15 apply to the replacement cost of $12 million that X capitalized on its Federal income tax returns before Year 2. The total cost of $12 million for this replacement is a per se capital expenditure, and must be capitalized, under the NGSH Method.

(iii) At the beginning of Year 2, X is treated under the NGSH Method as owning natural gas distribution property at a cost of $122 million ($120 million - $10 million + $12 million). Under section 5.08(2)(a)(i) of Rev. Proc . 2023-15, X must make a late general asset account election on its Form 3115 to include in general asset accounts all of the $122 million of natural gas distribution property that X owns at the beginning of Year 2. These general asset accounts also must include the total depreciation allowed or allowable before the beginning of Year 2 for such property as the beginning balances of the depreciation reserves. The late general asset account election change is made on a modified cut-off method and, therefore, a § 481(a) adjustment is neither required nor permitted for the late general asset account election.

(iv) On its Form 3115 to change to the NGSH Method under Rev. Proc. 2023-15, the net § 481(a) adjustment for this change is zero. Under its present method of accounting and under the NGSH Method (proposed method of accounting), X properly capitalized the $12 million for the cost of the replacements before Year 1 and claimed depreciation for such replacement assets before Year 2.

(c) Example 3 . (i) Y is a local natural gas distribution company. Before Year 1, Y owned and placed in service natural gas distribution property at a cost of $120 million before any dispositions or additions. Before Year 1, Y replaced parts of such property that had an original cost of $10 million, and incurred $12 million for the cost of such replacements. On its Federal income tax returns before Year 1, Y recognized losses upon the dispositions of that $10 million of property, and deducted $12 million for the cost of the replacements of such property under § 162(a). During Year 1, Y replaced a part of the natural gas distribution property that had an original cost of $2 million and incurred $3 million for the cost of such replacements. If Y had capitalized the $15 million for the cost of the replacements, the total depreciation allowed or allowable for these assets would have been $1 million before Year 2. On its Federal income tax return for Year 1, Y recognized a loss upon the disposition of that $2 million of property, and

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deducted $3 million for the cost of the replacements under § 162(a). Y files a Form 3115 with its Federal income tax return for Year 2 to change its method of accounting to use the NGSH Method described in Rev. Proc. 2023-15.

(ii) Because Y filed its method change for Year 2, section 5.08(2)(a)(i) of Rev. Proc . 2023-15 applies to this change. However, the special rule under section 5.08(3)(a) of Rev. Proc. 2023-15 would apply only if Y had filed its method change for Year 1. Accordingly, section 5.05(1)(g) and (h) of Rev. Proc. 2023-15 apply to the replacement cost of $12 million that Y deducted under § 162(a) on its Federal income tax returns before Year 1, and to the replacement cost of $3 million that Y deducted under § 162(a) on its Federal income tax return for Year 1. Therefore, the total cost of $15 million for these replacements is a per se capital expenditure, and must be capitalized, under the NGSH Method.

(iii) At the beginning of Year 2, Y is treated under Rev. Proc. 2023-15 as owning natural gas distribution property at a cost of $123 million ($120 million - $10 million + $12 million - $2 million + $3 million). Under section 5.08(2)(a)(i) of Rev. Proc. 2023-15, Y must make a late general asset account election on its Form 3115 to include in general asset accounts all of the $123 million of natural gas distribution property that Y owns at the beginning of Year 2. These general asset accounts also must include the total depreciation allowed or allowable before the beginning of Year 2 for such property as the beginning balances of the depreciation reserves. The late general asset account election change is made on a modified cut-off method and, therefore, a § 481(a) adjustment is neither required nor permitted for the late general asset account election.

(iv) On its Form 3115 to change to the NGSH Method of Rev. Proc. 2023-15, the net positive § 481(a) adjustment for this change is $14 million ($15 million for the cost of the replacements before Year 2 less depreciation allowed or allowable of $1 million for such replacement assets before Year 2) and is taken into account in computing Y ’s income in the manner provided in section 3.12(4)(a) of this revenue procedure.

(d) Example 4 . (i) Z is a local natural gas distribution company. Before Year 4, Z owned and placed in service natural gas distribution property at a cost of $150 million before any dispositions or additions. Before Year 4, Z replaced parts of such property that had an original cost of $30 million and incurred $45 million for the cost of such replacements. On its Federal income tax returns before Year 4, Z recognized losses upon the dispositions of that $30 million of property, capitalized $45 million for the cost of the replacements under § 263(a), and deducted depreciation of $15 million on such $45 million. Z files a Form 3115 with its Federal income tax return for Year 4 to change its method of accounting to use the NGSH Method described in Rev. Proc. 2023-15. Assume Z is eligible to file Form 3115 for Year 4 under the automatic change procedures in Rev. Proc. 2015-13. (ii) At the beginning of Year 4, Z owns natural gas distribution property at a cost of $165 million ($150 million - $30 million + $45 million). Because Year 4 is Z ’s fourth taxable year ending after May 1, 2023, sections 5.08(2)(a)(iii) and 5.08(3)(b) of Rev.

Proc. 2023-15 apply. Accordingly, under section 5.08(2)(a)(iii) of Rev. Proc. 2023-15, Z must make a late general asset account election on its Form 3115 to include in general asset accounts all of the $165 million of natural gas distribution property that Z owns at the beginning of Year 4. These general asset accounts also must include the total depreciation allowed or allowable before the beginning of Year 4 for such property as the beginning balances of the depreciation reserves. The late general asset account election change is made using a modified cut-off method and, therefore, a § 481(a) adjustment is neither permitted nor required for the late general asset account election.

(iii) Because sections 5.08(2)(a)(iii) and 5.08(3) (b) of Rev. Proc. 2023-15 apply, Z ’s change to the NGSH Method described in Rev. Proc. 2023-15, applies only to natural gas transmission and distribution property expenditures paid or incurred by Z beginning in Year 4 and is made on a cut-off basis. Therefore, a § 481(a) adjustment is neither required nor permitted for the change to the NGSH Method described in Rev. Proc. 2023-15.

(e) Example 5 . (i) The facts are the same as in Example 4 except that, on its Federal income tax returns before Year 4, Z improperly deducted $45 million for the cost of the replacements under § 162(a). Such $45 million of replacement costs should have been capitalized under § 263(a). If Z had capitalized the $45 million for the cost of the replacements, the total depreciation allowed or allowable for such assets would have been $15 million before Year 4.

(ii) Because Year 4 is Z ’s fourth taxable year ending after May 1, 2023, sections 5.08(2)(a)(iii) and 5.08(3)(b) of Rev. Proc. 2023-15 apply. Pursuant to section 5.08(3)(b) of Rev. Proc. 2023-15, Z must also change its method of accounting to capitalize under § 263(a) the $45 million for the cost of the replacements incurred before Year 4. The net positive § 481(a) adjustment for this coordinating change is $30 million ($45 million for the cost of the replacements before Year 4 less depreciation allowed or allowable of $15 million for such replacement assets before Year 4). Z takes this net positive § 481(a) adjustment of $30 million into account in computing Z ’s taxable income in the manner provided in section 3.12(4)(a) of this revenue procedure. (iii) Z owns natural gas distribution property at a cost of $165 million ($150 million - $30 million + $45 million) at the beginning of Year 4. Accordingly, Z must make a late general asset account election on its Form 3115 to include in general asset accounts all of the $165 million of natural gas distribution property that Z owns at the beginning of Year 4. These general asset accounts also must include the total depreciation allowed or allowable before the beginning of Year 4 for such property as the beginning balances of the depreciation reserves. The late general asset account election change is made using a modified cut-off method and, therefore, a § 481(a) adjustment is neither permitted nor required for the late general asset account election.

(iv) Because sections 5.08(2)(a)(iii) and 5.08(3) (b) of Rev. Proc. 2023-15 apply, Z ’s change to the NGSH Method provided under sections 5.02, 5.03, 5.04, 5.06, and 5.07 of Rev. Proc. 2023-15, applies only to natural gas transmission and distri

bution property expenditures paid or incurred by Z beginning in Year 4 and is made on a cut-off basis. Therefore, a § 481(a) adjustment is neither required nor permitted for the change to the NGSH Method described in Rev. Proc. 2023-15.

(v) Pursuant to section 3.12(6)(c) and section 5.08(3)(b) of Rev. Proc. 2023-15 the change to capitalize the replacement costs of $45 million, the late general asset account election change, and the change to use the NGSH Method provided under Rev. Proc. 2023-15 must be included on the same Form 3115 filed by Z for Year 4.

(8) Designated automatic accounting method change number . The designated automatic accounting method change number for a change to the methods of accounting under this section 3.12 is “269.”

(9) Contact information . For further information regarding a change under this section, contact Hyowon Lee or Merrill Feldstein at (202) 317-5100 (not a tollfree call).