2017 Revision of Comprehensive List of Automatic Accounting Method Changes Issued by IRS

In what now appears to be an annual event, the IRS has released a revised comprehensive list of accounting method changes in Rev. Proc. 2017-30. The new ruling replaces Rev. Proc. 2016‑29, issued approximately one year earlier.

The document is 337 pages long in the original PDF format published by the IRS.  The significant changes section begins on page 325 and continues through to page 330 of the document.  The new revenue procedure is effective for a Form 3115 filed on or after April 19, 2017 for a year of change ending on or after August 31, 2016.

The ruling also provides that if a taxpayer had been applying for a non-automatic change prior to the issuance of this ruling that now would qualify for automatic change treatment, the taxpayer may choose to use the automatic method by notifying the national office contact person of the intent to change to the automatic method by the later of:

  • May 19, 2017 or
  • The issuance of a letter ruling granting or denying the consent for change.

If the contact person is not known, the procedure refers the taxpayer to Section 9.08(6) of Rev. Proc. 2017‑1.

A taxpayer converting to an automatic change must also take the following steps:

A taxpayer converting a Form 3115 to the automatic change procedures in Rev. Proc. 2015‑13 for a change in method of accounting described in this revenue procedure must resubmit a Form 3115 that conforms to the automatic change procedures, with a copy of the national office letter sent acknowledging the taxpayer’s request attached, to the IRS in Covington, KY by the earlier of (a) the 30th calendar day after the date of the national office’s letter acknowledging the taxpayer’s request, or (b) the date the taxpayer is required to file the Duplicate copy of the Form 3115 under SECTION 6.03(1)(a)(i)(B) of Rev. Proc. 2015‑13.

If a change no longer qualifies for automatic approval that did qualify previously, the following transition rules apply:

(a) If before April 19, 2017, a taxpayer properly filed the original, or the Duplicate copy, of a Form 3115 under the automatic change procedures in Rev. Proc. 2015‑13 for a change in method of accounting that can no longer be filed under the automatic change procedures in Rev. Proc. 2015‑13, the taxpayer may make that change in method of accounting under the automatic change procedures in Rev. Proc. 2015‑13 for the year of change.

(b) If before April 19, 2017, a taxpayer did not properly file the original, or the Duplicate copy, of a Form 3115 under the automatic change procedures in Rev. Proc. 2015-13 for a change in method of accounting that can no longer be filed under the automatic change procedures in Rev. Proc. 2015-13, the taxpayer must make that change in method of accounting under the non-automatic change procedures in Rev. Proc. 2015-13. Notwithstanding § 1.446-1(e)(3)(i), the taxpayer may file a Form 3115 to request the Commissioner’s consent to change the method of accounting under the non-automatic change procedures in Rev. Proc. 2015-13 for the taxpayer’s last taxable year ending before April 19, 2017, on or before the due date of the federal income tax return for that taxable year. Solely for purposes of this paragraph (2)(b), the due date of the taxpayer’s federal income tax return includes extensions, notwithstanding that the taxpayer may not have extended the due date.