IRS Releases Updated Draft Form 3115 and Instructions

October 22, 2015

IRS signThe American Institute of CPAs (AICPA) plans to submit formal comments to the Internal Revenue Service (IRS) on the updated draft Form 3115, Application for Change in Accounting Method, released on October 7 and the draft instructions for the form released on September 30. 

A new IRS webpage,, dedicated to the form and instructions, will feature the latest developments related to them.  The webpage, which is not currently active, should be live when the final instructions are released later this year.  In order to allow for more timely updates on the form and instructions, the webpage will include a summary of automatic changes and their respective codes, which were recently removed from the instructions.

The draft instructions highlight a few changes including the new filing address at the Covington, Kentucky Service Center.  They also reference Revenue Procedure 2015-13, which provides procedures for both automatic and non-automatic changes in methods of accounting and Revenue Procedure 2015-14, which provides the list of automatic changes.  The AICPA plans to submit formal comments on both Revenue Procedures to address their impact on taxpayers.

The AICPA continues to press the IRS for relief for small business taxpayers by advocating for an increase in the tangible property regulations de minimis safe harbor from $500 to $2,500.  The AICPA submitted a comment letter to the IRS on this issue in April 2015.