The IRS announced that, for forms filed on or before April 19, 2016, the agency will generally accept either the current December 2015 version of Form 3115 or the prior December 2009 version of the form [Announcement 2016-14]. However, the use of the new form will be mandated in those situations where situations where the IRS has mandated the use of new form specifically in guidance published in the Internal Revenue Bulletin.

In the vast majority of cases the form is being filed to be granted automatic consent to a change in method of accounting under provisions promulgated by the IRS well before the December 2015 form was published, so this relief will cover the vast majority of filings, albeit only for a relative short period (on April 19 the new form will become mandated).

Taxpayers using the old form must still submit all information required by Revenue Procedure 2015-13 even if the December 2009 form did not specifically ask for the information in question.

Similarly, the IRS will not enforce the requirement that the IRS copy of automatic change requests be filed with the IRS office in Covington, Kentucy, rather allowing requests filed on the December 2009 version of the form to be filed either at the old Ogden address or the new Covington one.

The reason the IRS gave for granting this option is to “allow a reasonable transition” to the new form. Most likely the IRS discovered that taxpayers had used the 2009 version during 2015 to assemble information they planned to submit with their 2015 return or that some software vendors may not have incorporated the revised form (issued late in 2015) into their software.

Note, though, that beginning with forms filed on or after April 20, 2016 the use of the December 2009 version will not longer be allowed and, presumably, a taxpayer filing that form will not be deemed to have received the automatic approval for a change in accounting methods.