In our desire to provide you with the timely instructions to comply with existing IRS guidance on the tangible property regulations, we asked you on Friday, February 13, 2015 to mail in provided Form(s) 3115 to the IRS. Ironically, later on the same day, the IRS provided long-awaited guidance and relief.
Under this new guidance taxpayers are still required to file Form(s) 3115 if they have at least $10M in average gross receipts over the last three years and at least $10M of total assets in 2014.
However, for anyone not meeting the $10M threshold, there is no longer a Form 3115 filing requirement.
If you received a Form 3115 from us and have not yet mailed it to the IRS, we ask that you not file the form in light of this new guidance and wait until your tax preparer reaches out to you directly. If, however, you already mailed in a Form 3115 that is no longer required, do not worry – there is no harm in this.
If you are a taxpayer that is still required to file a Form 3115 under the new guidance and have not received the form from us, know that we will still prepare the form and either send it to you in advance of or with your tax return.
Thank you for your cooperation and PATIENCE in this process and please let us know if you have any questions.