Delay in 2014 Tax preparation due to a delay IRS Form 3115 - HELP!

DS has applied to 8 colleges for Fall 2015 Freshman Admissions. CSS Profile was done in November. FAFSA done in January. Working to get taxes filed in the next 2 weeks but…

I just received a call from my accountant saying that the IRS is working on form 3115. The IRS says the the final form will not be completed until “March” and any changes a taxpayer makes to the form after filing will result in an “unknown” penalty. This form relates to “Repair and Capitalization Regulation” and will be used for any depreciable assets (desk, computer, camera, etc.). Therefore, my accountant says, we cannot file taxes until the form is made available by the IRS. At this point, my accountant says she has no idea when, in March, if at all, the form will be out. She also does not have any indication as to what the “penalty” will be ($50? $10,000?). If it was known, I’d just take a risk and pay a penalty. This will affect ANYONE who has a depreciable asset.

Has anyone heard this?

I plan to call a Financial Aid office tomorrow (today closed for the day or for weather) to see what they know.

HELP! Anyone with experience in this? Any guidance would be helpful.

The form 3115 on the IRS website was last revised in December, 2009 and was posted online just three days ago. It’s hard to believe that the IRS would have made the form available on its website three days ago if they didn’t want people using it for the current filing season.

Also, the title for form 3115 is “Application for Change in Accounting Method.” Are you sure that form 3115 is the form that you are talking about?

Yes - I saw that too and asked my accountant again. Her response: “Your “change in method” is the one to now comply with the changes to the regulations for repair and capitalization of equipment/assets.”

I asked if there is any way around it and she said no.

OK, so if that’s the right form, the IRS made it available on its website three days ago. Why would they do that if they are still working on the form and the final form will not be completed until March? Makes no sense.

http://www.irs.gov/pub/irs-pdf/f3115.pdf

I get what you are saying. I don’t see, though, where you see it was made available 3 days ago. I see this at the bottom of the IRS website regarding Form 3115: Page Last Reviewed or Updated: 29-Oct-2014

When I click on the link, All Revisions for Form 3115, it says last revision 2012. My understanding is that it is this form that is being revised.

Go here:

http://apps.irs.gov/app/picklist/list/formsPublications.html;jsessionid=J1AxJBZn4dn-SQiTVyoLbA__?value=3115&criteria=formNumber&submitSearch=Find

You will see that the posted date for the form is 1/30/2015.

Hmmmm… I have sent the link and screen shot to my accountant. I’ll let you know what I find out.

This is a list of forms available if a taxpayer uses the IRS free fillable forms to e-file. It says the 3115 is available now.

http://www.irs.gov/uac/List-of-Available-Free-File-Fillable-Forms

I can’t see that it would be available for that and not be generally available.

Ask her again. Guidance is that current form can be used.

Ok! I’ll check on this again. I may call the IRS myself to verify.

There’s a very high chance that that would be a major exercise in frustration.

Thank you all! I have emailed my accountant the links you shared with me. I need to get to the bottom of this since I need my 2014 Taxes in IDOC in a month.

Your CPA’s tax software provider likely can’t ‘instantly’ write, test, and upload the software necessary to accurately incorporate Form 3115!

While you ‘get to the bottom of this’ go easy on your CPA.

@phoenixmomof2

https://■■■■■■■■■■■■■■■■/pulse/20141003225401-313328628-faq-implementing-tangible-property-regulations-tpr-s

gives you an idea what the issues are.

Yes @cptofthehouse‌! That’s it and what I am dealing with. So, my CPA is in agreement with the LinkedIn post. Back to my original issue… my CPA says that the final form is NOT ready and that the IRS says it won’t be ready until March. Therefore, I cannot file my taxes in time for FA processing. I have forwarded my CPA the questions regarding the “new form” that others mentioned above. Hopefully, the answer is that the current 3115 can be used… but, if not, what do I do?

So, as I understand from 2 FA offices, my D’s application will process as scheduled. The FA application would not be reviewed until after the file is complete (Taxes received). As soon as the form is ready (who knows when that will be), the taxes can be filed. When we get admission notification, it may not include FA #s which will be delayed. YIKES! Such a bummer. I’m done everything on time - darned government.

For schools that guarantee to meet full need, and who give consistent packages, it won’t make a difference, but, yes for some schools it could. Once certain funds are depleted, that is it. So the apps processed at the end of the line are at risk for those limited funds.

All you can do is explain the situation to each financial aid office and hope that it helps matters.

Thank you all for your help. The links were very very helpful.

I looked at CPT’s link quickly and don’t know anything about this stuff. But the link did say that a 3115 has to be sent in advance by itself and then one also has to be included with the return. Perhaps the delay has to do with processing of the first 3115 by the IRS before the return can be filed. Just a guess here.

^^^
That sounds like a good guess. I read through the entire linked article, and it didn’t say anything about a delay in updating form 3115 for tax year 2014.