Form 3115 (Automatic Depreciation Change) – Can I Re-Enter in TurboTax Desktop and E-File?

[mikendamaddawg66]

I’m filing my 2025 return and need to attach Form 3115 for an automatic change in accounting method (late depreciation on a residential rental property).

Details of my situation:

• I did not claim depreciation in 2023 and 2024.
• My CPA prepared Form 3115 to change from “no depreciation” to standard 27.5-year residential rental (S/L, mid-month).
• The total Section 481(a) adjustment is about $40,000 (2023 + 2024 missed depreciation).
• The CPA already faxed a signed copy of Form 3115 to the IRS National Office (as required for automatic changes).
• I was told that a second copy must also be attached to my 2025 tax return when I file in Spring 2026.

I have TurboTax Home and Business and I would like to e-file which I have always done.

My understanding is:

1. I cannot just upload the signed PDF of Form 3115 into TurboTax.
2. I should recreate Form 3115 inside TurboTax in Forms Mode so that it transmits with the e-file.
3. I should enter $0 for “prior depreciation claimed” (since I actually claimed none).
4. I should enter the full ~$40K Section 481(a) adjustment as a separate expense on Schedule E in 2025.

Is that the correct approach?

[M-MTax]

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@mikendamaddawg66 wrote:

Is that the correct approach?

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Yes, and ensure that you complete the 3115 in Forms Mode carefully (identically to your account's filing).

[mikendamaddawg66]

Thanks. I've filled out Form 3115 going into Forms view in TurboTax Desktop.

The one follow-up question that I have is my accountant also gave me an "attachment" page. It looks like this

Attachment 1

Form 3115 Part II, Line 7b

Required Statement Concerning Audit Protection

Attachment 2

Form 3115 Part IV, Line 26

Methodology used to determine the section 481(A) Adjustment

How do I include this additional attachment in TurboTax? Should I use this "Blank Form" page?

[M-MTax]

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@mikendamaddawg66 wrote:

How do I include this additional attachment in TurboTax? 

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Yeah, that's a problem because TurboTax (desktop at least) doesn't support attachments to returns, such as PDFs. 

You could, however, e-file your return and then immediately print and mail the 3115 with attachments to the IRS (along with Form 8453).

[mikendamaddawg66]

Can I use the "Blank Form" page or at this point should I just not fill out Form 3115 at all in Turbo Tax and just mail a copy along with Form8453 as you say https://www.irs.gov/pub/irs-pdf/f8453.pdf

My accountant said they've already faxed over the form to the IRS when they helped me prepare this form. My understanding is that I also need to attach the Form 3115 with my return. If I'm going to mail the entire Form 3115 with Form 8453, it's not clear to me that I should even fill out Form 3115 manually in Turbotax

[M-MTax]

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@mikendamaddawg66 wrote:

If I'm going to mail the entire Form 3115 with Form 8453, it's not clear to me that I should even fill out Form 3115 manually in Turbotax

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It's not clear to me either and, frankly, if I were to do it I'd simply print and mail the entire return complete with the 3115 and attachments.

[Rick19744]

I agree that you should not complete a form 3115 manually in TT.

Form 8453 allows you to send in the form separately from a return that has been efiled.  Make sure you check the appropriate box.

I'm sure this happens frequently, however, in this day and age of the IRS lack of employees (25% reduction in workforce), who knows how this works anymore.

If you do send it in separate, with form 8453, send it certified mail so you have proof of mailing.

Otherwise, send everything together (paper file) as noted by @M-MTax 

Also make sure your paper copy of the filed return is sent certified as well.