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3. A common parent of a consolidated group requesting an

an acknowledgement has not been received within 60 days of

identical accounting method change on behalf of two or more

filing Form 3115, the filer of an advance consent request can

CFCs that do not engage in a trade or business within the

inquire to: Internal Revenue Service, Control Clerk, CC:IT&A,

United States where all controlling U.S. shareholders of the

Room 4516, 1111 Constitution Ave., NW, Washington, DC

CFCs are members of the consolidated group; or

20224.

4. A taxpayer requesting an identical accounting method

Note: The IRS does not send acknowledgements for automatic

change on behalf of two or more CFCs that do not engage in a

change requests.

trade or business within the United States for which the

Late Application

taxpayer is the sole controlling U.S. shareholder of the CFCs.

In general, a taxpayer that fails to timely file a Form 3115 will

See section 15.07(4) of Rev. Proc. 2006-1 for what is an

not be granted an extension of time to file except in unusual

identical accounting method change.

and compelling circumstances. See Regulations section

301.9100-3 for the standards that must be met. For information

When and Where To File

on the period of limitations, see section 5.03(2) of Rev. Proc.

Automatic change requests. A Form 3115 that is filed under

2006-1.

the automatic change request procedures is filed in duplicate.

However, a limited 6-month extension of time to file Form

The original must be attached to the filer’s timely filed

3115 is sometimes available for automatic change requests.

(including extensions) federal income tax return for the year of

For details, see section 6.02(3)(b) of Rev. Proc. 2002-9 and

change. A copy of the Form 3115 must be filed with the IRS

Regulations section 301.9100-2.

National Office (see below) no earlier than the first day of the

A taxpayer submitting a ruling request for an extension of

year of change and no later than when the original is filed with

time to file Form 3115 must pay a user fee for its extension

the federal income tax return for the year of change. See also

request and, in the case of an advance consent request, also a

Late Application below and the instructions for lines 4d and 4e

separate user fee for its accounting method change request.

on page 5.

For the schedule of user fees, see (A)(3)(b) and (A)(5)(d) in

Advance consent requests. A Form 3115 that is filed under

Appendix A of Rev. Proc. 2006-1.

the advance consent request procedures must be filed during

the tax year for which the change is requested. If the tax year is

a short period, file Form 3115 by the last day of the short tax

Specific Instructions

year. File the Form 3115 with the IRS National Office (see

below). Form 3115 should be filed as early as possible during

the year of change to provide adequate time for the IRS to

Name(s) and Signature(s)

respond prior to the due date of the filer’s return for the year of

Enter the name of the filer on the first line of page 1 of Form

change. See also Late Application below and the instructions

3115. In the case of an advance consent request, the Form

for lines 4d and 4e on page 5.

3115 and any attached statements required to be signed must

File Form 3115 at the applicable IRS address listed below.

be signed and dated by, or on behalf of, the filer. In the case of

an automatic consent request, the copy of the Form 3115 that is

sent to the IRS National Office must be signed and dated by, or

For applicants (other than exempt organizations)

on behalf of, the filer; the Form 3115 attached to the income tax

filing . . .

return (including any additional statements) does not need to be

An advance consent request The National Office copy of an

signed. The name and signature requirements are discussed

automatic change request

below.

Delivery Internal Revenue Service

Internal Revenue Service

In general, the filer of the Form 3115 is the applicant.

by mail

Attn: CC:PA:LPD:DRU

However, for certain corporations discussed in the following

P.O. Box 7604

(Automatic Rulings Branch)

paragraphs, Form 3115 is filed on behalf of the applicant. If

Ben Franklin Station

P.O. Box 7604

such an exception applies, enter the filer’s name and

Washington, DC 20044

Ben Franklin Station

identification number on the first line of Form 3115 and enter

Washington, DC 20044

the applicant’s name and identification number on the fourth

line. If Form 3115 is filed for multiple applicants in a

Delivery Internal Revenue Service

Internal Revenue Service

consolidated group of corporations, multiple controlled foreign

Attn: CC:PA:LPD:DRU

corporations (CFCs), or multiple separate and distinct trades or

private

Room 5336

(Automatic Rulings Branch)

businesses of a taxpayer (including QSUBs or single-member

delivery 1111 Constitution Ave., NW Room 5336

LLCs), attach a schedule listing each applicant and its

service

Washington, DC 20224

1111 Constitution Ave., NW

Washington, DC 20224

identification number (where applicable). This schedule may be

combined with the information requested for Part III, line 23a

(regarding the user fee) and Part IV (section 481(a)

adjustment). If multiple names and signatures are required (for

For exempt organizations filing an advance consent request or the

example, in the case of CFCs — see instructions on page 3),

National Office copy of an automatic change request . . .

attach a schedule labeled “SIGNATURE ATTACHMENT” to the

By mail . . . . . . . . . . . . . . . . . . By private delivery service. . .

Form 3115, signed under penalties of perjury using the same

language as in the declaration on page 1 of Form 3115.

Internal Revenue Service

Receivers, trustees, or assignees must sign any Form 3115

Tax Exempt & Government Entities Tax Exempt & Government Entities

they are required to file.

Attn: TEGE:EO

P.O. Box 27720

1750 Pennsylvania Ave., NW

Individuals. If Form 3115 is filed for a husband and wife who

McPherson Station

Washington, DC 20038

file a joint income tax return, enter the names of both on the first

Washington, DC 20038

line and the signatures of both on the signature line.

Partnerships. Enter the name of the partnership on the first

The IRS normally acknowledges receipt of a filed Form 3115

line of Form 3115. In the signature section of Form 3115, enter

for an advance consent request within 60 days after receipt. If

the signature of one of the general partners or limited liability

-2-

Instructions For Form 3115 - Application For Change In Accounting Method - Internal Revenue Service - 2006 Page 2

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