How do I correctly file the Form 3115 for 2018?

[Chris268]

This is the first instance for a change and the change is for accrual to overall cash basis. In ProSeries it says I can file it as an attachment OR mail it, but in the government instructions it says I can file it electronically but I still have to mail it with the Form 8453 or whatever it was.  It also says the 3115 has to be mailed prior to filing the tax return.

Which set of directions is correct?  Can I have the client sign it, and then attach it to the return as a PDF file and be done with it?  Or do I have to mail the signed copy right now and probably file an extension?

[TaxGuyBill · Accepted solution]

The IRS needs two copies.

One goes with the tax return.  That one can be (a) e-filed as a PDF with the rest of the tax return, (b) e-file the tax return and mail the 3115 with Form 8453, or (c) mail the entire tax return with Form 3115.  The instructions say this one does not need to be signed, but I would have it signed anyways.  It also says it must be an "original", which puts into question if it should be attached as a PDF, but the IRS specifically allows 3115 attachments to the tax return so it should be fine.

The second copy is mailed to a different address by itself.

https://www.irs.gov/instructions/i3115#idm140516454118016

[Chris268]

Thank you very much.  

The instructions specifically say to send a copy to the mailing address, so I should be able to email the client the 3115, have them sign it and return it directly to me, rather than to the IRS.  Correct?  That would make the process much faster and I would not have to file an extension.

Thanks again.

[TaxGuyBill]

Yes, then you would attach it to the tax return AND mail it to the IRS (and keep a copy for yourself).

If this is for a 1040, I would not e-mail it to the client unless you have the proper encryption, as it has their Social Security Number.  Using a secure file upload or mailing it to the taxpayer may be a better idea.

[Chris268]

Thank you very much.

[Chris268]

The address in the IRS publication is for Ogden, UT, but the address on ProSeries Form 8453 is for Austin TX.  I suppose I should send it to Ogden, right?  Is this just one more way that ProSeries is not accurate this year?

[Bill12]

Hello Bill.

     I filed a Change Of Accounting Method Form 3115 to change a 1120S client from Accrual To Cash in 2019. I filed the signed paper 3115 with Ogden back in January. My question, I'm going to efile the 1120S now & have the 3115 attached as a PDF. But Proseries is showing a diagnostic that I have added a pdf attachment  for electronic filing but if the category is Other, electronic filing is not allowed.  There is no type available showing Form 3115. Any suggestions as to how I can resolve this without having to mail the 3115 into IRS again?