Common questions about Form 3115 and Regulation Change

Regulations related to Rev. Proc. 2014-16 were effective for tax years beginning on or after January 1, 2014.

• Certain changes in method of account for amounts paid to acquire, produce, or improve tangible property.
• The procedure by which a taxpayer may obtain the automatic consent of the Commissioner of Internal Revenue to change the methods of accounting.
• Provides the procedures by which a taxpayer may obtain the automatic consent of the Commissioner of Internal Revenue to change to a reasonable method described in 1.263A-1(f)(4) for self-constructed assets and to change to a permissible method of accounting under section 283A(b)(2) of the IRC and 1.263A-3(a)(1) for certain costs related to real property acquired through foreclosure, by deed in lieu of foreclosure, or in another similar transaction.
• Section 3.09 of Rev. Proc. 2011-14, 2011-37 I.R.B. 326, for taxpayer in the business of transporting, delivering, or selling electricity .Update- The IRS released a Quick Alert 2/13/2014 regarding Small Businesses to Apply Repair Regulations"Requested by many small businesses and tax professionals, the simplified procedure is available beginning with the 2014 return taxpayers are filling out this tax season. The new procedure allows small businesses to change a method of accounting under the final tangible property regulations on a prospective basis for the first taxable year beginning on or after Jan. 1, 2014.Also, the IRS is waiving the requirement to complete and file a Form 3115 for small business taxpayers that choose to use this simplified procedure for 2014."
• How can I make the following elections:
  • De minimis safe harbor [1.263(a)-1(f)]
  • Capitalize repair and maintenance costs [1.263(a)-3(n)]
  • Safe harbor for small taxpayers [1.263(a)-3(h)]   
• What portions of Form 3115 do I need to complete? For specific guidance on which portions of Form 3115 need to be completed see Rev. Proc. 2014-16 and the 3115 form instructions. 
  •  Time Saving Tip! If you need to create multiple Form 3115s with the same information you can create the first Form 3115 and use the Copy Property/Paste Property to quickly create multiple Form 3115.

For specific guidance on which portions of Form 3115 need to be completed see Rev. Proc. 2014-16 and the 3115 form instructions. 

•  Time Saving Tip! If you need to create multiple Form 3115s with the same information you can create the first Form 3115 and use the Copy Property/Paste Property to quickly create multiple Form 3115.

• Lacerte - Yes, you can attach each instance of Form 3115 separately as PDFs on Screen 4.4.
• ProConnect Tax - Yes, you can attach each instance of Form 3115 separately as PDFs on Screen 4.4.
• ProSeries - Yes, you can attach 1 instance of Form 3115 separately as PDF; additional instances must be mailed with Form 8453. ProSeries does not currently support multiple Form 3115s. Any additional Form 3115s will need to be completed manually then attached as PDFs.

• Lacerte - See Attaching PDF documents to an individual return for e-file (Form 1040) or Attaching PDF documents to a business return for e-file in Lacerte for more information.
• PTO - See How to attach a PDF to a tax return for e-file for more information.
• ProSeries - See How do I attach PDF files to federal or state electronic filing? for more information.

Per the Form 3115 instructions,"For an automatic change request, the filer must send a signed and dated copy of the Form 3115 to the IRS National Office and/or Ogden, UT, office and, in some cases, to an additional IRS office. For each of these copies, submit either the copy with an original signature or a photocopy of the original signed Form 3115. The Form 3115 attached to the income tax return (including any additional statements) does not need to be signed."