Rev. Proc. 2015-13 is the procedural framework that makes Form 3115 a usable instrument. Without it, every change in accounting method under IRC §446(e) would require a private letter ruling — a process that takes months and costs five figures. The automatic-consent procedure lets eligible taxpayers obtain the Service’s consent at the time of filing simply by attaching a completed Form 3115 to a timely-filed original return; no advance approval, no user fee.
It is the document every cost segregation §481(a) catch-up filing depends on. The companion Revenue Procedure listing the current automatic changes — most recently updated by Rev. Proc. 2026-08 — enumerates which Designated Change Numbers (DCNs) are eligible. For impermissible-to-permissible depreciation method changes, the relevant DCN is 7.
What it says
”A taxpayer that wants to change a method of accounting under this revenue procedure must file a Form 3115 in the manner described in section 6.03. The consent of the Commissioner is granted to a taxpayer that changes its method of accounting under this revenue procedure provided the taxpayer complies with all the applicable provisions of this revenue procedure.”
Section 6 is the operational heart of the procedure. Compliance is the condition for consent; deviation forfeits the automatic-consent benefit and requires a private letter ruling fallback. The form is filed in duplicate — one copy attached to the return, one copy to the IRS National Office.
”The section 481(a) adjustment period is the taxable year of change for a negative section 481(a) adjustment and is four taxable years (year of change and the next three taxable years) for a positive section 481(a) adjustment of $50,000 or more.”
This is the timing rule that makes cost segregation catch-up filings economically attractive. A taxpayer reclassifying components from 27.5-year property to shorter recovery periods has been under-depreciating in prior years, which produces a negative §481(a) adjustment — additional depreciation. Under §7.03(3), the entire negative adjustment is deducted in the year of change. Positive adjustments of $50,000 or more (overstated depreciation) are spread over four years; smaller positive adjustments are taken fully in the year of change.
”Subject to the exceptions in section 8.02, a taxpayer that changes its method of accounting under this revenue procedure will receive audit protection for any taxable year prior to the year of change in which the taxpayer used the impermissible method of accounting.”
Audit protection is the second economic engine of the procedure. A taxpayer using an impermissible depreciation method for prior years is not exposed to examination for those years on that issue once the Form 3115 is filed under the automatic-consent procedure (subject to the carve-outs in §8.02, which include taxpayers already under examination on the issue and taxpayers who file for §481(a) adjustment computations contrary to applicable law).
How it operates
A cost segregation §481(a) catch-up filing under Rev. Proc. 2015-13 proceeds in four steps:
- Establish the eligible DCN. Cost segregation reclassification of property from an impermissible 27.5-/39-year depreciation method to the correct shorter-life MACRS classes uses DCN 7 (impermissible-to-permissible depreciation method).
- Compute the §481(a) adjustment. The adjustment equals the cumulative depreciation that would have been claimed under the new method from the placed-in-service date through the year before the year of change, minus depreciation actually claimed under the old method during the same period. For accelerated reclassifications, this is a negative number — additional depreciation.
- File Form 3115 with the timely return. Two copies — one attached, one to the IRS Ogden office. The cost segregation study is attached as an exhibit, supporting the methodology and the per-component reclassifications.
- Take the §481(a) adjustment in the year of change. Negative adjustments are deducted fully; large positive adjustments are spread over four years per §7.03(3).
Cross-references
- Form 3115 topic hub (practitioner-facing procedure)
- §481(a) adjustment glossary entry (cumulative-correction mechanics)
- Rev. Proc. 2026-08 (current annual list of automatic changes)
- Cost segregation topic hub
- IRC §168 (depreciation method being changed)
Sources
- IRS PDF: www.irs.gov/pub/irs-drop/rp-15-13.pdf
- Citation: Rev. Proc. 2015-13, 2015-5 I.R.B. 419
- Statutory authority: 26 U.S.C. § 446(e), § 481(a)
- Current automatic-changes list: Rev. Proc. 2026-08 (companion procedure, updated annually)