The IRS announced[1] that the agency is going to be accepting the duplicate copy of Form 3115, Application for Change in Accounting Method, a taxpayer is required to file as part of a request for an automatic method change via fax beginning on July 31, 2020.

The website provides the following general information:

Until further notice, the IRS is implementing the temporary procedure described below for fax transmission of the duplicate copy of Form 3115, Application for Change in Accounting Method.

Starting on July 31, 2020, the IRS will accept the duplicate copy of Form 3115, Application for Change in Accounting Method, via fax to 844-249-8134. Important note: This change applies only to taxpayers requesting consent to make a change in accounting method under the automatic change procedure. This temporary procedure is in effect until further notice.

Taxpayers will still need to submit two copies of the Form 3115 to the IRS. Taxpayers must continue to file Form 3115 with their tax return (including extensions). However, instead of mailing the duplicate paper copy of Form 3115 to the IRS in Ogden, Utah, taxpayers can now fax it to 844-249-8134.

Who Does This Change Affect?

The IRS provides the following information about specifically who this change will affect:

1. Does this change affect me?

This change applies only to taxpayers filing Form 3115 for an automatic change in accounting method under the provisions of Rev. Proc. 2015-13, 2015-5, I.R.B. 419. For a definition of an automatic change in accounting method see the instructions for Form 3115. For the List of Automatic Changes, refer to Rev. Proc. 2019-43, 2019-48, I.R.B. 1107 (or any successor).

Submitting the Duplicate Copy

One of the key requirements of obtaining permission to change a taxpayer’s accounting method under an automatic change procedure is that two copies of the Form 3115 must be submitted—one with the taxpayer’s income tax return and one sent to an IRS processing center listed in form instructions.

The IRS provides the following information regarding filing a method change:

2. If I want to file for an automatic change in accounting method, how do I file the duplicate copy of the Form 3115?

Until further notice, you may fax your duplicate copy of Form 3115 for an automatic change in accounting method to the IRS at 844-249-8134. You must also file the original Form 3115 with your tax return.

3. How was Form 3115 submitted to the IRS prior to this change?

Previously, taxpayers mailed the paper duplicate copy of Form 3115 to the IRS and filed the original Form 3115 with their tax return.

The fax cover sheet submitted with the Form 3115 should contain the following information:

• Subject: Form 3115

• Sender's name, title, phone number, address

• Taxpayer’s name

• Date

• Number of pages faxed (including cover sheet)[2]

The IRS will not provide a fax transmission confirmation or receipt, suggesting taxpayers check their fax transmission log to verify that all Form 3115 pages were sent.[3]

The page provides that if a taxpayer has previously mailed the duplicate copy of the Form 3115 to the IRS, the taxpayer should not send a fax of that form to this fax number.[4]

Non-Automatic Method Changes

The IRS guidance notes that the fax submission system does not cover non-automatic changes:

7. Does this temporary procedure cover Form 3115 for a non-automatic method change?

This temporary procedure does not apply to requests for a non-automatic change in accounting method. For information regarding temporary electronic submission to request a non-automatic change in accounting method, see Rev. Proc. 2020-29.

Revenue Procedure 2020-29[5] provides a temporary method to electronically submit “requests for letter rulings, closing agreements, determination letters, and information letters under the jurisdiction of the Internal Revenue Service (IRS) Office of Chief Counsel, and for determination letters issued by the IRS Large Business and International Division (LB&I).”

[1] “Temporary procedure to fax automatic consent Forms 3115 due to COVID-19,” IRS website, July 29, 2020, https://www.irs.gov/newsroom/temporary-procedure-to-fax-automatic-consent-forms-3115-due-to-covid-19 (retrieved July 29, 2020)

[2] “Temporary procedure to fax automatic consent Forms 3115 due to COVID-19,” IRS website, July 29, 2020, Q&A 8

[3] “Temporary procedure to fax automatic consent Forms 3115 due to COVID-19,” IRS website, July 29, 2020, Q&A 5

[4] “Temporary procedure to fax automatic consent Forms 3115 due to COVID-19,” IRS website, July 29, 2020, Q&A 4

[5] Revenue Procedure 2020-29, April 30, 2020, https://www.irs.gov/pub/irs-drop/rp-20-29.pdf (retrieved July 29, 2020)