The IRS recently released a new version of the Form 3115,
"Application for Change in Accounting Method," along with
23 pages of instructions. The form was revised to better match Rev.
Proc. 2015-13, which was published about a year ago and made some
major changes to the terms and conditions under which taxpayers
file automatic and nonautomatic method changes.
In addition, the form now requires certain automatic method
changes to include a full explanation of the legal basis supporting
the proposed method. The IRS said that many of the forms it
receives don't include the level of detail the IRS requested in
the automatic procedure under which the change was being requested.
For example, a change from an impermissible to permissible method
of depreciation under Section 6.01 of Rev. Proc. 2015-14 is one of
the changes that require the additional detailed legal basis.