Tax Accounting Corner: Rev. Proc. 2015-13 and Foreign Partnerships

Prior to the issuance of Rev Procs 2015-13 and 2015-14, there was little procedural guidance for taxpayers seeking to obtain consent for a change in method of accounting for foreign partnerships. The predecessors to Rev. Proc. 2015-13, Rev. Proc. 2011-14 and Rev. Proc. 97-27, were silent on the procedures for foreign partnerships, which often caused confusion for tax practitioners and taxpayers given the unique fact pattern surrounding their tax filings. Tax practitioners and taxpayers are often still unaware of the updated guidance that provides clarity to most situations. Accordingly, this column provides a brief discussion of the application of the procedural rules set forth in Rev. Proc. 2015-13 to foreign partnerships. The procedures for filing a Form 3115, Application for Change in Accounting Method, depend on whether the method change is an automatic or non-automatic method change.