SECTION 6. EFFECTIVE DATE

.01 In general . Except as otherwise provided in this section 6, sections 7, 19.01, and 19.03 of Rev. Proc. 2025-23, as modified by this revenue procedure, are effective for a Form 3115 filed after September 4, 2026.

.02 Transition rule for taxpayers that properly file the duplicate copy of Form 3115 on or before November 15, 2026, for a change described in sections 7 and 19.01 of Rev. Proc. 2025-23, prior to mod- ification by this revenue procedure .

(1) In general . If, on or before November 15, 2026, a taxpayer properly files the duplicate copy of a Form 3115 for a change described in section 7 or 19.01 of Rev. Proc. 2025-23, prior to modification by this revenue procedure, the Form 3115 is not subject to the effective date provided in section 6.01 of this revenue procedure.

(2) Option to implement change as described in sections 7 and 19.01 of Rev. Proc. 2025-23, as modified by this revenue

procedure . If, on or before November 15, 2026, a taxpayer properly files the duplicate copy of a Form 3115 for a change in method of accounting described in section 7 or 19.01 of Rev. Proc. 2025-23, prior to modification by this revenue procedure, that continues to be eligible for the automatic change procedures under section 7 or 19.01 of Rev. Proc. 2025-23, as modified by this revenue procedure, but has not filed its timely filed (including extensions) original Federal income tax return for the year of change implementing the change, the taxpayer may choose to implement the change as described in either (1) section 7 or 19.01 of Rev. Proc. 2025-23, prior to modification by this revenue procedure, or (2) section 7 or 19.01 of Rev. Proc. 202523, as modified by this revenue procedure, but not both.

(a) Procedure to implement change as described in section 7 or 19.01 of Rev. Proc. 2025-23, prior to modification by this revenue procedure . A taxpayer who meets the requirements of section 6.02(2) of this revenue procedure and chooses to implement the change as described in section 7 or 19.01 of Rev. Proc. 2025-23, prior to modification by the revenue procedure, is not required to resubmit a duplicate copy of the Form 3115 to the IRS in Ogden, UT. However, if requested by the Director, the taxpayer must provide written substantiation that the duplicate copy of the Form 3115 was filed on or before November 15, 2026, pursuant to section 6.03(1)(a)(i)(B) of Rev. Proc. 2015-13. Such written substantiation may include proof of mailing or faxing, as appropriate, of the duplicate copy of the Form 3115.

(b) Procedure to implement the change as described in section 7 or 19.01 of Rev. Proc. 2025-23, as modified by this reve- nue procedure . A taxpayer who meets the requirements of section 6.02(2) of this revenue procedure and chooses to implement the change as described in section 7 or 19.01 of this Rev. Proc. 2025-23, as modified by this revenue procedure, must resubmit a duplicate copy (with signature) of the Form 3115 to the IRS in Ogden, UT, for the year of change under this revenue procedure, pursuant to the requirements of section 6.03(1)(a)(i)(B) of Rev. Proc. 2015-13. The resubmitted duplicate copy must include the following statement on the top of page 1 of the Form 3115:

“FILED UNDER REV. PROC. 2026-32, AS PROVIDED IN SECTION 6.02(2)(b) OF REV. PROC. 2026-32”. For purposes of the eligibility rules in section 5 of Rev. Proc. 2015-13, the duplicate copy of the resubmitted Form 3115 will be considered filed as of the date the taxpayer originally filed the duplicate copy of the Form 3115 requesting the change under Rev. Proc. 2025-23, prior to modification by this revenue procedure. This section 6.02(2) (b) does not extend the date the taxpayer must file either the resubmitted duplicate copy or original Form 3115 under section 6.03(1)(a) of Rev. Proc. 2015-13. If requested by the Director, the taxpayer must provide written substantiation that the duplicate copy of the Form 3115 requesting the change under Rev. Proc. 2025-23, prior to modification by this revenue procedure, was filed on or before November 15, 2026, pursuant to section 6.03(1)(a)(i)(B) of Rev. Proc. 2015-13. Such written substantiation may include proof of mailing or faxing, as appropriate, of the duplicate copy of the Form 3115.

.03 Limited time period to convert a Form 3115 filed under the non-automatic change procedures in Rev. Proc. 2015-13 .

(1) If, before September 21, 2026, a taxpayer properly filed a Form 3115 under the non-automatic change procedures in Rev. Proc. 2015-13 requesting the Commissioner’s consent for a change in method of accounting described in section 7, 19.01, or 19.03 of Rev. Proc. 2025-23, as modified by this revenue procedure, and the Form 3115 is pending with the national office on September 21, 2026, the taxpayer may choose to make the change in method of accounting under the automatic change procedures in Rev. Proc. 2015-13 if the taxpayer is otherwise eligible to use the automatic method changes described in section 7, 19.01, or 19.03 of Rev. Proc. 2025-23, as modified by this revenue procedure, and the automatic change procedures in Rev. Proc. 2015-13. The taxpayer must notify the national office contact person for the Form 3115 (if unknown, fax the notification to 855-576-2341 or send the notification to the attention of Management Assistant (OA), CC:ITA:B07, Room 4136, at the address specified in section 9.08(6) of Rev. Proc. 2026-1, 2026-1 I.R.B. 1 (or any successor)), of

Bulletin No. 2026–39 411 September 21, 2026

the taxpayer’s intent to make the change in method of accounting under the automatic change procedures in Rev. Proc. 2015-13 before the later of (a) October 21, 2026 , 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 the automatic change procedures in Rev. Proc. 2015-13. If the taxpayer timely notifies the national office that it chooses to convert the Form 3115 to the automatic change procedures in Rev. Proc. 2015-13, the national office will send a letter to the taxpayer acknowledging its request and will return the user fee submitted with the Form 3115.

(2) A taxpayer converting a Form 3115 to the automatic change procedures in Rev. Proc. 2015-13 for a change in method of accounting described in section 7, 19.01, or 19.03 of Rev. Proc. 2025-23, as modified by this revenue procedure, 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 attached, to the IRS in accordance with section 9.06 of Rev. Proc. 2026-1 (or its successor), by the earlier of (a) the 30th calendar day after the date of the national office’s letter acknowledging the taxpayer’s request or (b) the date the taxpayer is required to file the duplicate copy of the Form 3115 under section 6.03(1)(a)(i)(B) of Rev. Proc. 2015-13. See section 6.03(3) of Rev. Proc. 2015-13 regarding additional required copies of Form 3115.

(3) For purposes of the eligibility rules in section 5 of Rev. Proc. 2015-13, the duplicate copy of the timely resubmitted Form 3115 will be considered filed as of the date the taxpayer originally filed the converted Form 3115 under the non-automatic change procedures in Rev. Proc. 2015-13. This section 6.03 does not extend the date the taxpayer must file the original (converted) Form 3115 under section 6.03(1)(a)(i)(A) of Rev. Proc. 2015-13. (4) A Form 3115 filed under the non-automatic change procedures in Rev. Proc. 2015-13 before September 21, 2026, for a change in method of accounting described in sections 7, 19.01 and 19.03 of Rev. Proc. 2025-23, as modified by this revenue procedure, will be disregarded for purposes of the prior five-year change rules in section 5.04 and 5.05 of Rev. Proc. 2015-13 if the taxpayer converts the Form 3115 to the automatic change procedures pursuant to this section 6.03.