By: Steven D. Beaucaire, MST, CCSP
While the IRS has revised Form 3115, Announcement 2016-14 was issued last week to address the particulars associated with the new form and instructions. By way of reference, the new form replaces the December 2009 version. Note that the IRS will accept either the new or the old form for filings on or before April 19, 2016, except where the use of the current version is specifically required in guidance published in the Internal Revenue Bulletin. Irrespective of which form is filed, if the tax payer is using certain transition rules, they must provide all information required by Rev. Proc. 2015-13, or Rev. Proc. 2011-14. If filing the Form 3115 after April 19, 2016, the new version of the 3115 must be used.
Beginning in January 2016, the duplicate copy of Form 3115 for an automatic change request should be filed with the IRS at: Internal Revenue Service, 201 West Rivercenter Blvd., PIN Team Mail Stop 97, Covington, Kentucky. 41011-1424. A taxpayer that filed its duplicate copy of Form 3115 (using the Rev. December 2009 version) before April 20, 2016 with the IRS in either Ogden, Utah, or Covington, Kentucky, may file its original Form 3115 with its tax return on either version of the form.