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year(s)” includes any tax years for which the applicant’s present

statement, see section 6.01(2) of Rev. Proc. 97-27 or 6.03(2) of

or former consolidated group is under examination, before an

Rev. Proc. 2002-9, as applicable.

•

Appeals office, and/or before a Federal court if the applicant

120-day window period. This exception applies during the

was a member of the group in those tax years. For each of the

120-day period following the date an examination ends

applicable lines (4a, 4b, 4c, 5a, 5c, and/or 6), attach to the

regardless of whether a subsequent examination has

Form 3115 a list of the beginning and ending dates of the tax

commenced. For the definition of when an examination ends,

year(s) that the applicant (including its present and former

see section 3.07 of Rev. Proc. 97-27 or section 3.08 of Rev.

consolidated group) is under examination, before an Appeals

Proc. 2002-9, as applicable. The 120-day window period

office, and/or before a Federal court. If the method of

exception does not apply if the method the applicant is

accounting the applicant is requesting to change is an issue

requesting to change is an issue under consideration or placed

either under consideration, placed in suspense, or pending for

in suspense by the examining agent. Applicants should include

any tax year under examination, or if the method of accounting

the ending date of the examination that qualifies the applicant to

the applicant is requesting to change is an issue under

file under the 120-day window. For further details, including the

consideration by an Appeals office or by a Federal court,

required statement, see section 6.01(3) of Rev. Proc. 97-27 or

indicate the applicable tax year(s).

section 6.03(3) of Rev. Proc. 2002-9, as applicable.

Line 4a. The applicant is under examination if it has a federal

Line 5a. If the applicant has any federal income tax return

income tax return under examination on the date the Form 3115

before an Appeals office and/or a Federal court, refer to

is filed. For the definition of “under examination,” see section

sections 6.02 and 6.03 of Rev. Proc. 97-27 or sections 6.04 and

3.07 of Rev. Proc. 97-27 or section 3.08 of Rev. Proc. 2002-9,

6.05 of Rev. Proc. 2002-9, both as modified by Rev. Proc.

both as modified by Rev. Proc. 2002-19, as applicable.

2002-19, as applicable.

Line 5c. Except as otherwise provided in published guidance,

Line 4b. The applicant’s method of accounting is an issue

an applicant that is requesting to change a method of

under consideration if the applicant receives written notification

accounting that is an issue under consideration by an Appeals

from the examining agent specifically citing the treatment of the

office and/or a Federal court will not receive audit protection for

item as an issue under consideration. For further details, see

the requested change. For further details, see sections 6.02

section 3.08 of Rev. Proc. 97-27 or section 3.09 of Rev. Proc.

and 6.03 of Rev. Proc. 97-27 or 6.04 and 6.05 of Rev. Proc.

2002-9, as applicable. The applicant’s method of accounting is

2002-9, both as modified by Rev. Proc. 2002-19, as applicable.

an issue placed in suspense if the examining agent has given

the applicant written notification that the issue is placed in

Line 6. The information requested on line 6 may be provided in

suspense.

an attachment that includes the information requested on line 4f

and/or line 5a, as applicable.

Line 4c. The applicant’s method of accounting is an issue

pending if the IRS has given the applicant written notification

Line 8. Indicate the lack of audit protection by checking the

indicating that an adjustment is being made or will be proposed

“Yes” box. An applicant filing under the automatic change

with respect to the applicant’s method of accounting for the tax

request procedures should review the applicable accounting

year(s) under examination. Attach a copy of this written

method change section in the Appendix of Rev. Proc. 2002-9,

notification to Form 3115. For further details, see section

or the procedures in other published guidance, if applicable, to

6.01(5) of Rev. Proc. 97-27 or section 6.03(6) of Rev. Proc.

determine if, under the specific change in accounting method

2002-9, both as modified by Rev. Proc. 2002-19, as applicable.

requested, the applicant will not receive audit protection in

connection with the change. Applicants filing under either the

Line 4d. A taxpayer under examination may request to change

automatic change or advance consent request procedures must

an accounting method if the operating division director consents

also indicate lack of audit protection for their change if audit

to the filing of the Form 3115. The operating division director

protection does not apply under the provisions of sections

will consent to the filing of the Form 3115 unless, in the opinion

6.01(5), 6.02, or 6.03 of Rev. Proc. 97-27, or under sections

of the operating division director, the method of accounting to

6.03(6), 6.04, or 6.05 of Rev. Proc. 2002-9, both as modified by

be changed would ordinarily be included as an item of

Rev. Proc. 2002-19.

adjustment in the year(s) for which the applicant is under

Line 9. For further details, see section 9.03(6)(a) of Rev. Proc.

examination. The applicant should submit its request for the

2006-1 and either section 8.05 of Rev. Proc. 97-27 or section

consent of the operating division director to the examining

4.02(6) of Rev. Proc. 2002-9, as applicable.

agent. If the operating division director consents to the filing of

the Form 3115, the consent must be attached to the Form 3115

Line 10. For further details, see section 9.03(6)(b) of Rev.

filed with the IRS National Office. Also, the applicant must

Proc. 2006-1.

submit the operating division director copy of Form 3115 to the

Line 13. Each applicant, including each member of a

examining agent at the same time the Form 3115 is filed with

consolidated group and each eligible CFC filing a single Form

the IRS National Office. For applicants filing under the

3115 requesting the identical accounting method change, must

automatic change request procedures, attach to the Form 3115

attach a schedule describing its trade(s) or business(es) for

submitted with the filer’s income tax return a written statement

each separate and distinct trade or business of the applicant,

certifying that (a) the written consent was obtained from the

including any QSUB or single-member LLC. For guidance

director and (b) the applicant will retain a copy of the consent

regarding the phrase “separate and distinct trade or business,”

for inspection by the IRS. For further details, see section

see Regulations section 1.446-1(d). Entering the PBA code in

6.01(4) of Rev. Proc. 97-27 or section 6.03(4) of Rev. Proc.

the box at the top of page 1 satisfies the requirement to submit

2002-9, as applicable.

the PBA code for each trade or business.

Line 4e. The following exceptions apply to the “under

Line 14. Insurance companies must also state whether the

examination” scope limitations:

proposed method of accounting will be used for annual

•

90-day window period. This exception applies during the

statement accounting purposes.

first 90 days of any tax year if the applicant has been under

Line 16. For details on requesting and scheduling a conference

examination for at least 12 consecutive months as of the first

of right, see sections 9.04(4) and 10 of Rev. Proc. 2006-1.

day of the tax year. The 90-day window period exception does

not apply if the method the applicant is requesting to change is

Line 17. For an applicant changing to or from the cash method

an issue under consideration or placed in suspense by the

or changing its method of accounting under sections 263A, 448,

examining agent. For further details, including the required

460, or 471, enter the gross receipts, as determined under the

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Instructions For Form 3115 - Application For Change In Accounting Method - Internal Revenue Service - 2006 Page 5

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