Form 3115 & Rev Proc 2015-20

[mactoolsix]

I have two questions about the form 3115 considering the rev proc 2015-20 . . .

1.) If we do a 3115 to claim previous year repairs (which were capitalized), do we need to submit a “protective 3115” to comply with the balance of the new regs?



2.) Do we need a separate 3115 for DCN 177 & DCN 196 – While most DCNs can be combined on one 3115 form, I’ve read that these two will require separate 3115 forms- problem is I can't find where I read this.


Helps is much appreciated!!
Mike

[Lion]

I think you're looking for Rev Proc 2015-13 and 2015-14 which gave permission to combine more DCNs on one Form 3115. I do know you can combine 184, 186, 187, and an optional 196 if you have PADs. But, I don't know about 177. I think 2015-13 is the explanation and 2015-14 is the list of DCNs.

I think if you're in for one, you're in for all. That if you're using a Form 3115 you cannot use the relief in 2015-20 that allows you to start with 2014. That by using 3115, you're saying you're going back to depreciation schedules and supplies/materials/repairs and making any needed 481(a) adjustment.

But, it's how the IRS thinks that matters. And, they keep changing how they think!

[mactoolsix]

I think you're looking for Rev Proc 2015-13 and 2015-14 which gave permission to combine more DCNs on one Form 3115. I do know you can combine 184, 186, 187, and an optional 196 if you have PADs. But, I don't know about 177. I think 2015-13 is the explanation and 2015-14 is the list of DCNs.

For those interested - Concurrent automatic change for each of these is in 2015-14 (pages 88 for DCN 177 & 118 for DCN 196).

I think if you're in for one, you're in for all. That if you're using a Form 3115 you cannot use the relief in 2015-20 that allows you to start with 2014. That by using 3115, you're saying you're going back to depreciation schedules and supplies/materials/repairs and making any needed 481(a) adjustment.

But, it's how the IRS thinks that matters. And, they keep changing how they think!

Rita,
As usual your a great help!

[mactoolsix]

I think if you're in for one, you're in for all. That if you're using a Form 3115 you cannot use the relief in 2015-20 that allows you to start with 2014. That by using 3115, you're saying you're going back to depreciation schedules and supplies/materials/repairs and making any needed 481(a) adjustment.

But, it's how the IRS thinks that matters. And, they keep changing how they think!

This thinking is also indicated by Boyer & Ritter:

http://tprtoolsandtemplates.com/the-new-rules-and-consequences-of-rp-2015-20/