Form 3115 Preparation Services

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Form 3115 Preparation Services

What is IRS Form 3115?

Form 3115, Application for Change in Accounting Method, is a key IRS filing used by taxpayers to implement changes in how income and expenses are recognized for tax purposes. These changes may relate to a taxpayer’s overall method of accounting (such as transitioning from the cash method to the accrual method, or vice versa) or to the treatment of specific material items that impact the timing of income or deductions (such as depreciation or revenue recognition).

Accounting method changes are governed by IRS procedural guidance, including Revenue Procedure 2015-13 and Revenue Procedure 2025-23, which outline the requirements, eligibility, and filing procedures for taxpayers seeking to make a change. These resources can be accessed directly below:

There are two main types of method changes:

Automatic Changes

The IRS publishes a list of common changes that qualify for automatic consent. For these, Form 3115 is filed with your tax return for the year of change, and a copy is sent to the IRS. No user fee is required.

Non-Automatic Changes

If the change is not on the automatic list, a separate application is filed with the IRS National Office, a user fee is paid, and IRS approval must be received before the change is implemented. The Form 3115 must be filed before the end of the proposed tax year of change for non-automatic changes.

Changes must be made in the current tax year; you generally cannot retroactively change your method for a prior year by amending a return. Most changes require a calculation of a Section 481(a) adjustment to prevent duplication or omission of income or deductions. This adjustment is generally spread over four years for positive adjustments (unfavorable) or taken in one year for negative adjustments (favorable). A listing and description of the most commonly filed accounting method changes is provided below.

Depreciation and Amortization Changes

a) Impermissible to Permissible Depreciation

Changing from an impermissible to a permissible method of accounting for depreciation or amortization for property owned at the beginning of the year of change. This is one of the most common changes, as taxpayers often discover errors in depreciation methods, recovery periods, or conventions and need to correct them. Common fact patterns include:
  • Assets placed in-service but never depreciated
  • Assets acquired but never capitalized/depreciated
  • Incorrect depreciable life
  • Changes to depreciable basis or incorrect cost capitalization

b) Dispositions

Changes related to the treatment of dispositions of tangible depreciable assets, including buildings and structural components. The most common example are “ghost assets” where assets are disposed of in prior years but never removed from the depreciation ledger.

Expense Recognition and Tangible Property Regulations

a) Repairs vs. Capitalization

Changes to deduct repair and maintenance costs or to capitalize improvement costs under the final tangible property regulations. This is a very common area for method changes, especially after the issuance of the tangible property regulations.

b) Materials and Supplies

Changes in the treatment of materials and supplies, including when to deduct or capitalize such costs. The most common example is changing to a method of deducting items with a cost of $200 or less on a per item basis.

Revenue Recognition

a) Advance Payments and Revenue Recognition

Changes to the timing of income recognition for advance payments, including changes to comply with §451(b) and (c), the AFS (applicable financial statement) income inclusion rule, and the deferral method for advance payments. The most common example of a revenue recognition change is for advance payments and/or deferred revenue where the taxpayer recognizes revenue for financial statement purposes in a later period (e.g. gift cards, warrant contracts, subscriptions, services, etc.).

Overall Method Changes (Cash vs. Accrual)

a) Cash to Accrual or Accrual to Cash

Changes in the overall method of accounting, such as from the cash method to the accrual method or vice versa, are common, especially for businesses that grow and exceed or fall below the gross receipts threshold ($31M for 2025) for required methods.

Other Common Changes

  • Cash to Accrual Specific Items – Common examples include deductions for items by accrual method taxpayers when payment is made vs. when services are provided (e.g. legal/accounting fees, marketing fees, consulting fees, etc.).
  • Capitalization of certain costs as intangibles – Common examples include items capitalized over contractual terms when allowed a current deduction (e.g. prepaid expenses, commissions, service fees, etc.).
  • Changes to a proper Section 461 liability accrual – Common examples include items deducted before property economic performance or before liability is fixed and determined or expensed on a cash basis when performance has occurred (e.g. liability reserves, compensation accruals, self-insured medical expenses, rebates, payroll taxes on bonus compensation, property taxes, etc.).

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Accounting Method Change Filings

Depreciation and Amortization Changes

a) Impermissible to Permissible Depreciation

Changing from an impermissible to a permissible method of accounting for depreciation or amortization for property owned at the beginning of the year of change. This is one of the most common changes, as taxpayers often discover errors in depreciation methods, recovery periods, or conventions and need to correct them. Common fact patterns include:
  • Assets placed in-service but never depreciated
  • Assets acquired but never capitalized/depreciated
  • Incorrect depreciable life
  • Changes to depreciable basis or incorrect cost capitalization

b) Dispositions

Changes related to the treatment of dispositions of tangible depreciable assets, including buildings and structural components. The most common example are “ghost assets” where assets are disposed of in prior years but never removed from the depreciation ledger.

Expense Recognition and Tangible Property Regulations

a) Repairs vs. Capitalization

Changes to deduct repair and maintenance costs or to capitalize improvement costs under the final tangible property regulations. This is a very common area for method changes, especially after the issuance of the tangible property regulations.

b) Materials and Supplies

Changes in the treatment of materials and supplies, including when to deduct or capitalize such costs. The most common example is changing to a method of deducting items with a cost of $200 or less on a per item basis.

Revenue Recognition

a) Advance Payments and Revenue Recognition

Changes to the timing of income recognition for advance payments, including changes to comply with §451(b) and (c), the AFS (applicable financial statement) income inclusion rule, and the deferral method for advance payments. The most common example of a revenue recognition change is for advance payments and/or deferred revenue where the taxpayer recognizes revenue for financial statement purposes in a later period (e.g. gift cards, warrant contracts, subscriptions, services, etc.).

Overall Method Changes (Cash vs. Accrual)

a) Cash to Accrual or Accrual to Cash

Changes in the overall method of accounting, such as from the cash method to the accrual method or vice versa, are common, especially for businesses that grow and exceed or fall below the gross receipts threshold ($31M for 2025) for required methods.

Other Common Changes

  • Cash to Accrual Specific Items – Common examples include deductions for items by accrual method taxpayers when payment is made vs. when services are provided (e.g. legal/accounting fees, marketing fees, consulting fees, etc.).
  • Capitalization of certain costs as intangibles – Common examples include items capitalized over contractual terms when allowed a current deduction (e.g. prepaid expenses, commissions, service fees, etc.).
  • Changes to a proper Section 461 liability accrual – Common examples include items deducted before property economic performance or before liability is fixed and determined or expensed on a cash basis when performance has occurred (e.g. liability reserves, compensation accruals, self-insured medical expenses, rebates, payroll taxes on bonus compensation, property taxes, etc.).

Source Advisors Services

Source Advisors partners with CPA firms and their clients to identify, evaluate, and implement accounting method changes in a manner that is efficient, technically sound, and fully compliant with IRS requirements. Our team assists in determining whether a method change is appropriate, identifying whether the change qualifies as automatic or non-automatic, and preparing all required Form 3115 filings in accordance with applicable guidance, including Revenue Procedure 2015-13 and Revenue Procedure 2025-23.

In addition to preparation and filing, Source Advisors supports clients with the calculation of Section 481(a) adjustments and provides insight into the potential tax impact of each change. Our team brings significant experience in accounting methods, including professionals who have served in leadership roles within Big Four national accounting methods practices, allowing us to deliver practical, high-quality solutions tailored to each client’s facts and circumstances.
We welcome the opportunity to collaborate with your team—please contact us to discuss how we can assist with current or prospective accounting method change opportunities.

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