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Change to form 3115 filing procedure

de minimis, SSTB, QBI, pass-through, deductionThe IRS has just announced that they are temporarily allowing taxpayers to submit the second/duplicate copy of the Form 3115 via fax instead of mail. This new procedure started on July 31, 2020 and is in effect until further notice.

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As in the past, taxpayers still need to submit two copies of the Form 3115. The first copy is to be attached to the Federal tax return filing. The difference is that the second copy will now be faxed to 844-249-8134 instead of being mailed to the Ogden, UT address. You should include a cover sheet with the fax submission. Per the news release, the cover sheet should include:

  • Subject: Form 3115
  • Sender’s name, title, phone number, address
  • Taxpayer’s name
  • Date
  • Number of pages faxed (including the cover sheet)
  • Do not include sensitive information on the cover sheet

Now, this new procedure only applies to Form 3115’s that are being filed to request consent to make a change in accounting method under the automatic change procedures. This would be things such as small businesses (under $26 million) changing to the overall cash method and also the exemption from Section 263A. The Form 3115 instructions provides a full list of the automatic change requests. So, if you are filing Form 3115 for non-automatic change requests, please follow the original procedures listed in the form instructions.

Two things to keep in mind:

  • The IRS will not provide a confirmation or receipt of the fax
  • If you have already mailed in your Form 3115, do not fax it

Please contact your Henry+Horne advisor with any questions.

Kelsey Phillips, CPA

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