SECTION 9. WHAT

ARE THE SPECIFIC AND ADDITIONAL PROCEDURES FOR A REQUEST FOR A CHANGE IN METHOD OF ACCOUNTING FROM THE ASSOCIATE OFFICES?

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(1) Substantially identical letter rulings. For letter ruling requests qualifying for the user fee provided in paragraph (A)(5)(a) of Appendix A of this revenue procedure for substantially identical letter rulings, a separate letter ruling will generally be issued for each requester or entity as the Associate office deems necessary.

(2) Related § 301.9100 letter rulings.

(a) For a § 301.9100 letter ruling request for an extension of time to file a Form 3115 qualifying under section 15.07(4) for the user fee provided in paragraph (A)(5)(d) of Appendix A of this revenue procedure for an identical change in method of accounting, the Associate office generally will issue a single letter on behalf of all applicants on Form 3115 that are the subject of the request.

(b) For a § 301.9100-3 letter ruling request for an extension of time to file an entity classification election for multiple entities qualifying under section 15.07(2) for the user fee provided in paragraph (A)(5)(a) of Appendix A of this revenue procedure, the Associate office generally will issue a single letter on behalf of all entities that are the subject of the request. The taxpayer may request that separate letters be issued to each entity that is the subject of the request. See generally section 5.03 of this revenue procedure.

(3) Related § 1362(f) letter rulings. For a § 1362(f) letter ruling request from multiple S corporations qualifying under section 15.07(2) for the user fee provided in paragraph (A)(5)(a) of Appendix A of this revenue procedure, the Associate office generally will issue a single letter on behalf of all the S corporations that are the subject of the request. The taxpayer may request that separate letters be issued to each S corporation that is the subject of the request.

.09 The Associate office will send a copy of the letter ruling, whether favorable or adverse, to the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer's tax return.

This section provides the specific and additional procedures applicable to a request for a change in method of accounting under Rev. Proc. 2015-13, 2015-5 I.R.B. 419 (or any successor), as clarified and modified by Rev. Proc. 2015-33, 2015-24 I.R.B. 1067, as modified by Section 17.02 (b) and (c) of Rev. Proc. 2016-1, 2016-1 I.R.B. 1, as modified by Rev. Proc. 2017-59, 2017-48 I.R.B. 543, as modified by Rev. Proc. 2021-26, 2021-22 I.R.B. 543, and as modified by Rev. Proc. 2021-34, 2021-35 I.R.B. 337, or other automatic change request procedures.

A request for a change in method of accounting under Rev. Proc. 2015-13 (or any successor) or other automatic change request procedures is a type of request for a letter ruling. See section 2.01 of this revenue procedure.

Automatic and non- automatic change in .01 method of accounting requests

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Automatic change in method of accounting under Rev. Proc. 2015-13 (or any successor), or other automatic change request procedures

Non-automatic change in method of accounting

Ordinarily only one change in method of accounting on a Form 3115, Application for Change in Accounting Method , and a separate Form 3115 for each taxpayer and for each separate and distinct trade or business

Information required with a Form 3115

Facts and other information

(1) Automatic change in method of accounting. Certain changes in methods of accounting must be made under automatic change request procedures. A change in method of accounting provided for in an automatic change request procedure must be made using that procedure if the taxpayer requesting the change is within the scope of the procedure, the change is an automatic change for the requested year of the change, and the taxpayer is eligible to make the change. The Commissioner’s consent to an otherwise qualifying automatic change in method of accounting is granted only if the taxpayer timely complies with the applicable automatic change request procedures. But see section 9.19 of this revenue procedure concerning review by an Associate office and a field office. In general, a taxpayer requests an automatic change by filing a current Form 3115, Application for Change in Accounting Method .

An application filed under the automatic change procedures in Rev. Proc. 2015-13 (or any successor) or other automatic change request procedure, and this revenue procedure, is hereinafter referred to as an “automatic change request.” See section 9.22 of this revenue procedure for a list of automatic change request procedures. See section 9.23 for a list of the sections and Appendices of this revenue procedure in addition to this section 9 that apply to an automatic change request. No user fee is required for a change made under an automatic change request procedure.

(2) Non-automatic change in method of accounting. If a change in method of accounting may not be made under an automatic change request procedure, the taxpayer may request a nonautomatic letter ruling by filing a current Form 3115, Application for Change in Accounting Method, under the non-automatic change procedures in Rev. Proc. 2015-13 (or any successor), and this revenue procedure. A Form 3115 filed under Rev. Proc. 2015-13 (or any successor) and this revenue procedure for a non-automatic change request is hereinafter referred to as a “non-automatic Form 3115.” A taxpayer filing a non-automatic Form 3115 must submit the required user fee with the completed Form 3115. See section 15 and Appendix A of this revenue procedure for information about user fees. See section 9.23 for a list of the sections and Appendices of this revenue procedure in addition to this section 9 that apply to a non-automatic Form 3115.

.02 Ordinarily, a taxpayer may request only one change in method of accounting on a Form 3115, Application for Change in Accounting Method . If the taxpayer wants to request a change in method of accounting for more than one unrelated item or submethod of accounting, the taxpayer must submit a separate Form 3115 for each unrelated item or submethod, except in certain situations in which the Service specifically permits certain unrelated changes to be included on a single Form 3115. For an example of such a situation, see section 15.01(3) of Rev. Proc. 2024-23, 2024-23 I.R.B. 1334 (or its successor).

A separate Form 3115 (and, therefore, a separate user fee pursuant to section 15 and Appendix A of this revenue procedure) must be submitted for each taxpayer and each separate trade or business of a taxpayer, including a qualified subchapter S subsidiary (QSub) or a single-member limited liability company (single-member LLC), requesting a change in method of accounting, except as specifically permitted or required in guidance published by the Service. See, e.g., section 15.07(4) of this revenue procedure.

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(1) Facts and other information requested on Form 3115 and in applicable revenue procedures. In general, a taxpayer requesting a change in method of accounting must file a current Form 3115, unless the procedures applicable to the specific type of change in method of accounting do not require a Form 3115 to be submitted.

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Statement of authorities contrary to taxpayer’s views

To be eligible for approval of the requested change in method of accounting, the taxpayer must provide all information requested on the Form 3115 and in its instructions and in Rev. Proc. 201513 (or any successor), and, if applicable, the automatic change request procedure. In addition, the taxpayer must provide all information requested in the applicable sections of this revenue procedure, including a detailed and complete description of the item being changed and of the taxpayer’s trade(s) or business(es), the taxpayer’s present and proposed method for the item being changed, information regarding whether the taxpayer has claimed any federal tax credit relating to the cost being changed, information regarding whether the taxpayer is under examination, or before Appeals or a Federal court, and a summary of the computation of the net § 481(a) adjustment, along with an explanation of the methodology used to determine the adjustment, sufficient to demonstrate that the net § 481(a) adjustment is computed correctly.

For a non-automatic Form 3115 or an automatic change request specified in the instructions for line 16 of the Form 3115, the taxpayer must also include a full explanation of the legal basis and relevant authorities supporting the proposed method, and a detailed and complete description of the facts and explanation of how the law applies to the taxpayer’s situation.

For a non-automatic Form 3115, the taxpayer must also include a statement of the applicant’s reasons for the proposed change, copies of all documents related to the proposed change, and a discussion of whether the law related to the request is uncertain or inadequately addresses the issue.

The taxpayer must provide the requested information to be eligible for approval of the requested change in method of accounting. The taxpayer may be required to provide information specific to the requested change in method of accounting, such as an attached statement. The taxpayer must provide all information relevant to the requested change in method of accounting, even if not specifically requested, including an explanation of all material facts relevant to the requested change in method of accounting.

See also sections 7.01(1) and 7.01(9) of this revenue procedure.

(2) Statement of contrary authorities. For a non-automatic Form 3115, the taxpayer is encouraged to inform the Associate office about, and discuss the implications of, any authority believed to be contrary to the proposed change in method of accounting, including statutes, court decisions, regulations, notices, revenue rulings, revenue procedures, or announcements.

If the taxpayer does not furnish either contrary authorities or a statement that none exist, the Associate office may request submission of contrary authorities or a statement that none exist. Failure to comply with this request may result in the Associate office’s refusal to issue a change in method of accounting letter ruling.

Documents (3) Copies of all contracts, agreements, and other documents. True copies of all contracts, agreements, and other documents relevant to the requested change in method of accounting must be submitted with a non-automatic Form 3115. Original documents should not be submitted because they become part of the Associate office’s file and will not be returned.

Analysis of material facts (4) Analysis of material facts. When submitting any document with a Form 3115 or in a supplemental letter, the taxpayer must explain and provide an analysis of all material facts in the document. The taxpayer may not merely incorporate the document by reference. The analysis of the facts must include their bearing on the requested change in method of accounting and must specify the provisions that apply.

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Same issue in an earlier return under examination

Issue previously submitted or currently pending

Statement identifying pending legislation

(5) Information regarding whether same issue is in an earlier return under examination. A Form 3115 must state whether, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, any earlier return of the taxpayer (or any return of a current or former consolidated group in which the taxpayer is or was a member) in which the taxpayer used the method of accounting being changed is under examination, before Appeals, or before a Federal court. See Rev. Proc. 2015-13 (or any successor).

(6) Statement regarding prior requests for a change in method of accounting and other pending requests.

(a) Other requests for a change in method of accounting within the past five years. A Form 3115 must state, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, whether the taxpayer, a related party within the meaning of § 267(b) or § 707(b)(1), or a member of a current or former affiliated group of which the taxpayer is or was a member within the meaning of § 1504, or a predecessor requested or made within the past five years (including the year of the requested change), or is currently filing, any request for a change in method of accounting.

If the statement is affirmative, for each separate and distinct trade or business, the Form 3115 must give a description of each request and the year of change and whether consent was obtained. If any application was withdrawn, not perfected, or denied, or if a Consent Agreement was sent to the taxpayer but was not signed and returned to the Associate office, or if the change was not made in the requested year of change, the Form 3115 must give an explanation.

(b) Any other pending request(s). A Form 3115 must state, to the best of the knowledge of both the taxpayer and the taxpayer’s representatives, whether the taxpayer, a related party within the meaning of § 267(b) or § 707(b)(1), or a member of a current or former affiliated group of which the taxpayer is or was a member within the meaning of § 1504, or a predecessor currently have pending any request (including any concurrently filed request) for a letter ruling, a change in method of accounting, or technical advice.

If the statement is affirmative, the Form 3115 must give the name(s) of the taxpayer, identification number(s), the type of request (letter ruling, request for change in method of accounting, or request for technical advice), and the specific issues in each such request.

(7) Statement identifying pending legislation. At the time the taxpayer files a non-automatic Form 3115, the taxpayer must identify any pending legislation that may affect the proposed change in method of accounting. The taxpayer also must notify the Associate office if any such legislation is introduced after the request is filed but before a change in method of accounting letter ruling is issued.

Authorized representatives (8) Authorized representatives. To appear before the Service in connection with a request for a change in method of accounting, the taxpayer’s authorized representative must be an attorney, a certified public accountant, an enrolled agent, an enrolled actuary, a person with a “Letter of Authorization,” an employee, general partner, bona fide officer, administrator, trustee, etc., as described in section 7.01(14) of this revenue procedure.

Power of Attorney and Declaration of Representative

(9) Power of Attorney and Declaration of Representative. Any authorized representative, whether or not enrolled to practice, must comply with Treasury Department Circular No. 230, which provides the rules for practice before the Service, and the conference and practice requirements of the Statement of Procedural Rules, which provide the rules for representing a taxpayer before the Service. See section 7.01(15) of this revenue procedure. A taxpayer should use Form 2848, Power of Attorney and Declaration of Representative, to provide the representative’s authority.

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Tax Information Authorization

Penalties of perjury statement

(10) Tax Information Authorization. A taxpayer may use Form 8821, Tax Information Authorization, to authorize an individual to receive a copy of the taxpayer's change in method of accounting letter ruling and other related correspondence. If the taxpayer wishes to authorize a corporation, firm, organization, or partnership to receive the correspondence, an individual, identified by either name or title, must be specified on the Form 8821. A Form 8821 does not authorize the taxpayer's appointee to advocate the taxpayer's position or to otherwise represent the taxpayer before the Service.

(11) Penalties of perjury statement.

(a) Format of penalties of perjury statement. A Form 3115, and any change to a Form 3115 submitted at a later time, must be accompanied by the following declaration: “ Under penalties of perjury, I declare that I have examined this application, including accompanying schedules and statements, and to the best of my knowledge and belief, the application contains all the relevant facts relating to the application, and it is true, correct, and complete. ”

See section 9.08(3) of this revenue procedure for the penalties of perjury statement required for submissions of additional information.

(b) Signature by taxpayer. A Form 3115 must be signed in a manner consistent with section 7.01(13) of this revenue procedure by, or on behalf of, the taxpayer requesting the change by an individual who has personal knowledge of the facts of, and authority to bind the taxpayer in, such matters. For example, an officer must sign on behalf of a corporation, a general partner on behalf of a state law partnership, a member-manager on behalf of a limited liability company, a trustee on behalf of a trust, or an individual taxpayer on behalf of a sole proprietorship. If the taxpayer is a member of a consolidated group, a Form 3115 should be submitted on behalf of the taxpayer by the common parent and must be signed by a duly authorized officer of the common parent. Refer to the signature requirements set forth in the instructions for the current Form 3115 regarding those who are to sign. See also section 6.02(8) of Rev. Proc. 2015-13 (or any successor).

(c) Signature by preparer. If a Form 3115 is prepared by an individual other than the taxpayer, the preparer must also sign the Form 3115 in a manner consistent with section 7.01(13) of this revenue procedure. A declaration of preparer (other than the taxpayer) is based on all information of which the preparer has any knowledge.

Additional procedural .04 information required in certain circumstances

Recipients of original and copy of correspondence

(1) Recipients of original and copy of change in method of accounting correspondence. The Service will send the signed original of the change in method of accounting letter ruling and other related correspondence to the taxpayer, and copies to the taxpayer’s representative, if so instructed on Form 2848. See section 7.02(2) of this revenue procedure for how to designate alternative routing of the copies of the letter ruling and other correspondence.

Expedited handling (2) To request expedited handling. The Associate offices ordinarily process non-automatic Forms 3115 in order of the date received. A taxpayer with a compelling need to have a nonautomatic Form 3115 processed on an expedited basis may request expedited handling. See section 7.02(4) of this revenue procedure for procedures regarding expedited handling. Requesting form of any document related to Form 3115 provided to taxpayer (3) To request the receipt of the change in method of accounting letter ruling or any or taxpayer’s authorized other correspondence related to a Form 3115 by fax, electronic facsimile, or encrypted email representative attachment. If the taxpayer wants a copy of the change in method of accounting letter ruling or

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any other correspondence related to a Form 3115, such as a request for additional information, to be provided to the taxpayer or the taxpayer’s authorized representative by fax, electronic facsimile, or encrypted email attachment, the taxpayer must submit a written request, preferably as part of the Form 3115. The request may be submitted at a later date, but it must be received prior to the mailing of correspondence other than the letter ruling and prior to the signing of the change in method of accounting letter ruling. The Service has the discretion to determine the form in which it will correspond with the taxpayer, but will generally comply with a taxpayer’s request for a particular form.

If the taxpayer requests to have correspondence relating to the Form 3115 provided by fax or electronic facsimile to the taxpayer or taxpayer’s authorized representative, the request must contain the fax number of the taxpayer or the taxpayer’s authorized representative to whom the correspondence is to be provided.

A document other than the change in method of accounting letter ruling will be faxed by a branch representative. A change in method of accounting letter ruling may be faxed by either a branch representative or the Disclosure and Litigation Support Branch of the Legal Processing Division of the Office of Associate Chief Counsel (Procedure and Administration) (CC:PA:LPD:DS).

If the taxpayer requests documents by encrypted email attachment, the request must specify which email encryption method is to be used and, if the taxpayer has not already provided the appropriate memorandums of understanding (MOUs) to use encrypted email attachments, must include those MOUs. See section 9.05(3) of this revenue procedure for acceptable email encryption methods and procedures.

For purposes of § 301.6110-2(h), a change in method of accounting letter ruling is not issued until the change in method of accounting letter ruling is mailed.

Requesting a conference (4) To request a conference. The taxpayer must complete the appropriate line on the Form 3115 to request a conference, or must request a conference in a later written communication, if an adverse response is contemplated by the Associate office. See section 11.03(1) of Rev. Proc. 2015-13 (or any successor), and sections 10.01 and 10.02 of this revenue procedure.

Submitting non-automatic Forms 3115

.05 Non-automatic Forms 3115 may be submitted by mail, by electronic facsimile, or by encrypted email attachment.

(1) Submission by mail. A taxpayer submitting a non-automatic Form 3115 by mail should submit the original to the appropriate address below. To use the paper method, first submit the full user fee payment set forth in Appendix A of this revenue procedure through www.pay.gov, and include a copy of the receipt for this payment with the request. See section 15.08 of this revenue procedure.

If a private delivery service is not used, a taxpayer, including an exempt organization, must send the original completed Form 3115 to:

Internal Revenue Service Attn: CC:PA:LPD:TSS P.O. Box 7604 Benjamin Franklin Station Washington, DC 20044

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If a private delivery service is used, a taxpayer, including an exempt organization, must send the original completed Form 3115 to:

Internal Revenue Service Attn: CC:PA:LPD:TSS Room 5336 1111 Constitution Ave., NW Washington, DC 20224

For taxpayers, including an exempt organization, the original completed Form 3115 may be hand delivered between the hours of 8:00 a.m. and 4:00 p.m. to the courier’s desk at 1111 Constitution Ave., NW, Washington, DC. A receipt will be given at the courier’s desk. The package should be addressed to:

Courier’s Desk Internal Revenue Service Attn: CC:PA:LPD:TSS, Room 5336 1111 Constitution Ave., NW Washington, DC 20224

(2) Submission by electronic facsimile. Taxpayers and their representatives are encouraged to use a secure electronic facsimile service for transmitting requests for advice. To use the secure electronic facsimile method, first submit the full user fee payment set forth in Appendix A of this revenue procedure through www.pay.gov, and include a copy of the receipt for this payment with the request. See section 15.08 of this revenue procedure.

Transmit the Form 3115, along with a cover sheet, to the secure electronic facsimile line:

(877) 773-4950

(3) Submission by encrypted email attachment. There are more risks associated with email than with electronic facsimile, such as the possibility that sensitive taxpayer information could be intercepted. Accordingly, the Service encourages taxpayers to use a secure electronic facsimile service for transmitting requests for advice. As an alternative, this section provides procedures for using encrypted email attachments for transmitting a non-automatic Form 3115.

Taxpayers using encrypted email attachments may choose to use a compression utility compatible with SecureZIP (note that many open-source utilities are not compatible with SecureZIP), Adobe Acrobat Pro password encryption, or Microsoft Office 365 Protect Document to encrypt and send password-protected files. Because these programs do not encrypt the subject line or body of an email or the file name of the attachment, all sensitive taxpayer information, including the name of the taxpayer, should be included only in the encrypted attachment.

These programs require that a sender create a password for the recipient to use to decrypt the attachments. The password should never be sent in the same email as the encrypted attachment. Instead, it should be provided to the Service in a separate email with a subject line that makes it easy to connect the password to the encrypted email.

To use encrypted email attachments, first submit the full user fee payment set forth in Appendix A of this revenue procedure through www.pay.gov, and include a copy of the receipt for this payment with the request. See section 15.08 of this revenue procedure.

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Submitting automatic Forms 3115

A Form 3115 transmitted through email must be accompanied by two MOUs: the MOU in Appendix G of this revenue procedure, acknowledging the risks of using email to transmit sensitive taxpayer information, and the appropriate MOU in Appendix H, agreeing to the terms for using the chosen method of encryption to receive sensitive taxpayer information. These MOUs must be signed by the taxpayer, not the taxpayer's representative, in a manner consistent with section 7.01(13) of this revenue procedure. A Counsel representative will countersign and return the second MOU to the requester prior to transmitting any other information by encrypted email attachments.

Transmit the Form 3115 to the following email address:

Userfee@irscounsel.treas.gov

.06 Automatic change request. The duplicate copy of an automatic Form 3115 generally is submitted by mail. A taxpayer that is filing an automatic Form 3115 under the provisions of Rev. Proc. 2015-13 (or any successor) may alternatively submit the duplicate copy of the Form 3115 by fax.

(1) Submission by mail. If the automatic change request procedure requires a taxpayer to file a duplicate copy of the completed Form 3115 for an automatic change request, and if a private delivery service is not used, send the duplicate copy of the automatic change request Form 3115 to:

Internal Revenue Service Ogden, UT 84201 M/S 6111

If a private delivery service is used, send the duplicate copy of the automatic change request Form 3115 to:

Internal Revenue Service 1973 N. Rulon White Blvd. Ogden, UT 84201 Attn: M/S 6111

(2) Submission by fax. Taxpayers submitting the duplicate copy of an automatic Form 3115 by fax should do so to the following fax number:

(844) 249-8134

The submission should include a cover sheet with the following information:

(a) Subject: “Form 3115”

(b) Sender’s name, title, phone number, and address

(c) Taxpayer’s name

(d) Date

(e) Number of pages faxed (inclusive of cover sheet)

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Technical Services Support Branch receives, initially controls, and refers the Form 3115 to the appropriate Associate office

Additional information

Reply period

A taxpayer should not include sensitive information on the cover sheet, such as the taxpayer’s Employer Identification Number or Social Security Number.

.07 A non-automatic Form 3115 is received and controlled by the Technical Services Support Branch, Legal Processing Division of the Associate Chief Counsel (Procedure and Administration) (CC:PA:LPD:TSS) if the required user fee is submitted with the Form 3115. Once controlled, the Form 3115 is forwarded to the appropriate Associate office for assignment and processing.

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(1) Reply period.

(a) Non-automatic Form 3115 –­ 21-day rule. In general, for a non-automatic Form 3115, additional information requested by the Associate office and additional information furnished to the Associate office by telephone must be furnished in writing by mail, fax, or email within 21 calendar days from the date of the information request. The Associate office may impose a shorter reply period for a request for additional information made after an initial request. See section 10.06 of this revenue procedure for the 21-day rule for submitting information after any conference.

(b) Automatic change request – 30-day rule. In general, for an automatic change request, additional information requested by the Associate office, and additional information furnished to the Associate office by telephone must be furnished in writing by mail, fax, or email within 30 calendar days from the date of the information request. The Associate office may impose a shorter reply period for a request for additional information made after an initial request. See section 10.06 of this revenue procedure for the 21-day rule for submitting information after any conference with the Associate office.

Extension of reply period (2) Request for extension of reply period.

(a) Non-automatic Form 3115. For a non-automatic Form 3115, an additional period, not to exceed 15 calendar days, to furnish information may be granted to a taxpayer. Any request for an extension of time must be made in writing and submitted before the end of the original 21-day period. If unusual circumstances close to the end of the 21-day period make a written request impractical, the taxpayer should notify the Associate office within the 21-day period that there is a problem and that the written request for extension will be provided shortly. An extension of the 21-day period will be granted only if approved by a branch reviewer. An extension of the 21-day period ordinarily will not be granted to furnish information requested on Form 3115. The taxpayer will be told promptly, and later in writing, of the approval or denial of the requested extension. If the extension request is denied, there is no right of appeal.

(b) Automatic change request. For an automatic change request, an additional period, not to exceed 30 calendar days, to furnish information may be granted to a taxpayer. Any request for an extension of time must be made in writing and submitted before the end of the original 30-day period. If unusual circumstances close to the end of the 30-day period make a written request impractical, the taxpayer should notify the Associate office within the 30-day period that there is a problem and that the written request for extension will be coming soon. An extension of the 30-day period will be granted only if approved by a branch reviewer. An extension of the 30-day period ordinarily will not be granted to furnish information requested on Form 3115. The taxpayer will be told promptly of the approval or denial of the requested extension. If the extension request is denied, there is no right of appeal.

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Penalties of perjury statement for additional information

Identifying information included in additional information

Transmitting request and submitting additional information by fax, electronic facsimile, or encrypted email attachment

Submitting additional information by mail

(3) Penalties of perjury statement for additional information. Additional information submitted to the Associate office must be accompanied by the following declaration: “ Under penalties of perjury, I declare that I have examined this information, including accompanying documents, and, to the best of my knowledge and belief, the information contains all the relevant facts relating to the request for the information, and such facts are true, correct, and complete. ” This declaration must be signed in accordance with the requirements in section 9.03(11)(b) of this revenue procedure.

(4) Identifying information included in additional information. The additional information should also include the taxpayer's name, the case control number, and the name, office symbols, and room number of the Associate office representative who requested the information. The Associate office representative can provide the latter information to the taxpayer.

(5) Transmitting request and submitting additional information by fax, electronic facsimile, or encrypted email attachment. To facilitate prompt action on a change in method of accounting ruling request, taxpayers may request that the Associate office request additional information by fax, electronic facsimile, or encrypted email attachment. See section 9.04(3) of this revenue procedure.

Taxpayers may also submit additional information by fax, electronic facsimile, or encrypted email attachment as soon as the information is available. The Associate office representative who requests additional information can provide a fax or electronic facsimile number or email address to which the information can be sent.

(6) Submitting additional information by mail.

(a) Address if private delivery service is not used. For a request for change in method of accounting under the jurisdiction of the Associate Chief Counsel (Income Tax and Accounting), if a private delivery service is not used, the additional information should be sent to:

Internal Revenue Service ADDITIONAL INFORMATION Attn: [Name, office symbols, and room number of the Associate office representative who requested the information] P.O. Box 14095 Benjamin Franklin Station Washington, DC 20044

For any other request for change in method of accounting, if a private delivery service is not used, the additional information should be sent to:

Internal Revenue Service ADDITIONAL INFORMATION Attn: [Name, office symbols, and room number of the Associate office representative who requested the information] P.O. Box 7604 Benjamin Franklin Station Washington, DC 20044

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Failure to timely submit additional information to the Associate office

Circumstances in which the taxpayer must notify the Associate office

Determines if proposed method of accounting can be modified to obtain favorable letter ruling

(b) Address if private delivery service is used. For a request for a change in method of accounting, if a private delivery service is used, the additional information should be sent to:

Internal Revenue Service ADDITIONAL INFORMATION Attn: [Name, office symbols, and room number of the Associate office representative who requested the information] 1111 Constitution Ave., NW Washington, DC 20224

(7) Failure to timely submit additional information to the Associate office.

(a) Non-automatic Form 3115. In the case of a non-automatic Form 3115, if the required information is not furnished to the Associate office within the reply period, the Form 3115 will not be processed and the case will be closed. The taxpayer or authorized representative will be so notified in writing.

(b) Automatic change request. In the case of an automatic change request, if the required information is not furnished to the Associate office within the reply period, the request does not qualify for the automatic change request procedure. In such a case, the Associate office will notify the taxpayer that consent to make the change in method of accounting is not granted.

(c) Submitting the additional information at a later date. If the taxpayer wants to submit the additional information at a later date, the taxpayer must submit it with a new completed Form 3115 (and user fee, if applicable) for a year of change for which such new Form 3115 is timely filed under the applicable change in method of accounting procedure.

.09 For a non-automatic Form 3115, the taxpayer must promptly notify the Associate office if, after the Form 3115 is filed but before a change in method of accounting letter ruling is issued, the taxpayer knows that—

(1) a field office has started an examination of the present or proposed accounting;

(2) a field office has started an examination of the proposed year of change;

(3) legislation that may affect the change in method of accounting has been introduced, see section 9.03(7) of this revenue procedure; or

(4) another letter ruling request (including another Form 3115) has been submitted by the taxpayer, a related party within the meaning of § 267(b) or § 707(b)(1), or a member of an affiliated group of which the taxpayer is a member within the meaning of § 1504.

.10 For a non-automatic Form 3115, if a less than fully favorable change in method of accounting letter ruling is indicated, the branch representative will tell the taxpayer whether minor changes in the proposed method of accounting would bring about a favorable ruling. The branch representative will not suggest precise changes that materially alter a taxpayer's proposed method of accounting.

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Near the completion of processing the Form 3115, advises the taxpayer if the Associate office will rule adversely and offers the taxpayer the opportunity to withdraw Form 3115

.11 Generally, after a conference is held (or offered, in the event no conference is held) and before issuing any change in method of accounting letter ruling that is adverse to the requested change in method of accounting, the taxpayer will be offered the opportunity to withdraw the Form 3115. See sections 9.12 and 10 of this revenue procedure. If, within 10 calendar days of the notification by the branch representative, the taxpayer or the taxpayer’s representative does not notify the branch representative of a decision to withdraw the Form 3115, the adverse change in method of accounting letter ruling will be issued unless an extension is granted. See section 15.10 for information regarding refunds of user fees.

Non-automatic Form 3115 .12 may be withdrawn or Associate office may decline to issue a change in method of accounting letter ruling

In general (1) In general. A taxpayer may withdraw a non-automatic Form 3115 at any time before the change in method of accounting letter ruling is signed by the Associate office. The Form 3115, correspondence, and any documents relating to the Form 3115 that is withdrawn or for which the Associate office declines to issue a letter ruling will not be returned to the taxpayer. See section 9.03(3) of this revenue procedure. In appropriate cases, the Service may publish its conclusions in a revenue ruling or revenue procedure.

Notification of appropriate Service official

How to check status of a pending non-automatic Form 3115

Service is not bound by informal opinion

Single letter ruling issued to a taxpayer or consolidated group for qualifying identical change in method of accounting

Letter ruling ordinarily not issued for one of two or more interrelated items or submethods

(2) Notification of appropriate Service official. If a taxpayer withdraws, or the Associate office declines to grant (for any reason), a request to change a method of accounting, the Associate office will notify, in writing, the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return and the Manager of the Methods of Accounting and Timing Practice Network, and may give its views on the issues in the request to the Service official to consider in any later examination of the return.

If the written notification to the Service official provides more than the fact that the request was withdrawn and the Associate office was tentatively adverse, or that the Associate office declines to grant a change in method of accounting, the memorandum may constitute Chief Counsel Advice, as defined in § 6110(i)(1), and may be subject to disclosure under § 6110.

.13 The taxpayer or the taxpayer’s authorized representative may obtain information regarding the status of a non-automatic Form 3115 by calling the person whose name and telephone number are shown on the acknowledgement of receipt of the Form 3115.

.14 The Service will not be bound by any informal opinion expressed by the branch representative or any other Service representative, and such an opinion cannot be relied upon as a basis for obtaining retroactive relief under the provisions of § 7805(b).

.15 For a non-automatic Form 3115 qualifying under section 15.07(4) for the user fee provided in paragraph (A)(5)(b) of Appendix A of this revenue procedure for identical changes in method of accounting, the Associate office generally will issue a single letter ruling on behalf of all applicants on the Form 3115 that are the subject of the request.

.16 If two or more items or submethods of accounting are interrelated, the Associate office ordinarily will not issue a letter ruling on a change in method of accounting involving only one of the items or submethods.

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Consent Agreement .17 Ordinarily, for a non-automatic Form 3115, the Commissioner’s permission to change a taxpayer’s method of accounting is set forth in a letter ruling (original and a Consent Agreement copy). If transmitting electronically, the issuing office may sign the letter ruling and the Consent Agreement copy electronically. See section 9.04(3) of this revenue procedure. If the taxpayer agrees to the terms and conditions contained in the change in method of accounting letter ruling, the taxpayer must sign and date the Consent Agreement copy of the letter ruling in the appropriate space. The Consent Agreement copy must be signed in a manner consistent with section 7.01(13) of this revenue procedure by an individual with authority to bind the taxpayer in such matters. The Consent Agreement copy must not be signed by the taxpayer’s representative. The signed copy of the letter ruling will constitute an agreement (Consent Agreement) within the meaning of Treas. Reg. § 1.481-4(b). The signed Consent Agreement copy of the letter ruling must be returned to the Associate office within 45 calendar days of the date of the letter ruling. The signed Consent Agreement copy may be submitted under the procedures set forth above for submission of additional information. See section 9.04(3) and 9.08(5) of this revenue procedure.

In addition, a copy of the signed Consent Agreement generally must be attached to the taxpayer’s income tax return for the year of change. See section 11.03(2)(a) of Rev. Proc. 2015-13 (or any successor). A taxpayer filing its return electronically should attach the Consent Agreement as a PDF file named “Form3115Consent.” If the taxpayer has filed its income tax return for the year of change before the letter ruling has been received and the Consent Agreement has been signed and returned, the copy of the signed Consent Agreement should be attached to the amended return for the year of change that the taxpayer files to implement the change in method of accounting.

A taxpayer must secure the consent of the Commissioner before changing a method of accounting for Federal income tax purposes. See Treas. Reg. § 1.446-1(e)(2)(i). For a change in method of accounting requested on a non-automatic Form 3115, a taxpayer has secured the consent of the Commissioner when the taxpayer timely signs and returns the Consent Agreement copy of the letter ruling from the Associate office granting permission to make the change in method of accounting and otherwise complies with Rev. Proc. 2015-13 (or any successor).

A taxpayer that timely files a non-automatic Form 3115 and takes the requested change in method of accounting into account in its federal income tax return for the year of change (and any subsequent taxable year) prior to receiving a letter ruling granting consent for that change has made a change in method of accounting without obtaining the consent of the Commissioner as required by § 446(e) (an “unauthorized change”). As provided in section 12.02 of Rev. Proc. 201513 (or any successor), the Director may determine when a change is not made in compliance with all applicable provisions of Rev. Proc. 2015-13 (or any successor) and may deny the unauthorized change. However, the Commissioner’s consent, issued subsequent to the requested year of change, applies back to the year of change (and any subsequent taxable year) as of the date of the letter ruling granting consent for that change if the taxpayer timely signs and returns the Consent Agreement copy and implements the change in accordance with all applicable provisions of Rev. Proc. 2015-13 (or any successor) and section 11 of this revenue procedure. If the Commissioner does not grant consent under Rev. Proc. 2015-13 (or any successor) for the change in method of accounting taken into account by the taxpayer, the taxpayer is subject to any interest, penalties, or other adjustments resulting from improper implementation of the change. See § 446(f). A taxpayer who timely files a non-automatic Form 3115 and takes the requested change into account in the taxpayer’s Federal income tax return for the year of change (and any subsequent taxable year), prior to receiving the letter ruling granting permission for the requested change, may nevertheless rely on the letter ruling received from the Associate office after it is received, as provided in section 9.19 of this revenue procedure. If, however, the requested change is modified or is withdrawn, denied, or similarly closed without the Associate office having granted consent, taxpayers are not relieved of any interest, penalties, or other adjustments resulting from improper implementation of the change.

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A copy of the change in method of accounting letter ruling is sent to appropriate Service officials

Consent to change a method of accounting may be relied on subject to limitations

.18 The Associate office will send a copy of each change in method of accounting letter ruling, whether favorable or adverse, to the appropriate Service official in the operating division that has examination jurisdiction of the taxpayer’s tax return and the Manager of the Methods of Accounting and Timing Practice Network.

.19 A taxpayer may rely on a change in method of accounting letter ruling received from the Associate office, subject to certain conditions and limitations. See sections 7, 8, 10, 11, and 12 of Rev. Proc. 2015-13 (or any successor).

A qualifying taxpayer complying timely with an automatic change request procedure may rely on the consent of the Commissioner as provided in the automatic change request procedure to change the taxpayer’s method of accounting, subject to certain conditions and limitations. See generally sections 7, 8, 10, 11, and 12 of Rev. Proc. 2015-13 (or any successor). An Associate office may review a Form 3115 filed under an automatic change request procedure and will notify the taxpayer if additional information is needed or if consent is not granted to the taxpayer for the requested change. See section 11 of Rev. Proc. 2015-13 (or any successor). Further, the field office that has jurisdiction over the taxpayer’s return may review the Form 3115. See section 12 of Rev. Proc. 2015-13 (or any successor).

Change in method of .20 A taxpayer may not rely on a change in method of accounting letter ruling issued to another accounting letter ruling taxpayer. See § 6110(k)(3). does not apply to another taxpayer

Associate office discretion to permit requested change in method of accounting

List of automatic change in method of accounting request procedures

.21 The Associate office reserves the right to decline to process any non-automatic Form 3115 in situations in which it would not be in the best interest of sound tax administration to permit the requested change or it would not clearly reflect income. In this regard, the Associate office will consider whether the change in method of accounting would clearly and directly frustrate compliance efforts of the Service in administering the income tax laws. See section 11.02 of Rev. Proc. 2015-13 (or any successor).

.22 For procedures regarding requests for an automatic change in method of accounting, refer to the following published automatic change request procedures. The Commissioner’s consent to an otherwise qualifying automatic change in method of accounting is granted only if the taxpayer complies timely with the applicable automatic change request procedure.

The automatic change request procedures for obtaining a change in method of accounting include:

(1) Rev. Proc. 2015-13 (or any successor). Rev. Proc. 2015-13 applies to the changes in method of accounting described in Rev. Proc. 2024-23, 2024-23 I.R.B. 1334 (or its successor).

(2) The following automatic change request procedures, which require a completed Form 3115, provide both the procedures under which a change may be made automatically and the procedures under which such change must be made:

Treas. Reg. § 1.166-2(d)(3) (bank conformity for bad debts);

Treas. Reg. § 1.458-1 and -2 (exclusion for certain returned magazines, paperbacks, or records);

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Other sections of this revenue procedure that are applicable to Form 3115