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IRS Rules, Form 3115 & Compliance

The look-back study: how Form 3115 recovers years of missed depreciation

One form, one catch-up, no amended returns. The mechanics in full.

Deprecio 11 January 2026 4 min read

Why it is a method change, not an error

An error is a mistake in applying a correct method — a transposed number, a missed asset. Errors are corrected by amending.

A method of accounting is a consistent treatment of an item. Using an impermissible recovery period on two or more consecutive returns establishes a method, and methods are corrected prospectively through a change in method rather than by amending.

Depreciation is explicitly treated this way, which is the entire reason look-back studies work.

The section 481(a) adjustment

When you change methods, section 481(a) requires a computation preventing amounts from being duplicated or omitted: the cumulative difference between depreciation actually claimed and depreciation that would have been claimed under the correct method from the beginning.

A negative adjustment — additional deductions, the taxpayer-favourable direction — is taken entirely in the year of change. A positive adjustment is generally spread over four years. Cost segregation look-backs almost always produce the favourable kind.

A worked example

An owner bought a $2.4 million retail building in 2016 and put $1.9 million of building basis on a 39-year schedule. By 2026 they have claimed roughly $487,000.

A study finds $520,000 belongs in 5 and 7-year classes and $340,000 in 15-year land improvements. Recomputed from 2016 applying the bonus rules as they stood in each year, cumulative depreciation should have been roughly $1,140,000.

The section 481(a) adjustment is approximately $653,000, deductible in full on the 2026 return.

Automatic consent

Changing from an impermissible to a permissible method of depreciation is generally an automatic change, commonly designated change number 7 on the automatic changes list. No advance consent, no user fee.

Form 3115 is filed with a timely-filed original return including extensions, with a copy sent separately as the governing revenue procedure directs. Both filings matter; missing the separate copy is a common and avoidable problem.

What we prepare

The study establishing correct classification as of the placed-in-service date, the year-by-year recomputation, the 481(a) schedule, the completed Form 3115 with required statements and the change number, filing instructions for both copies, and direct support for your preparer through filing.

The hard boundary

You must still own the property. Sell it and the schedule closes and the opportunity closes with it. There is no retroactive study on a disposed asset.

Where this stops. This article is general information, not tax advice, and it cannot account for your basis, your entity, your participation or your state. A free feasibility review takes twenty minutes and gives you an answer specific to your property.

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The study is one piece. We can handle the rest of the return.

Deprecio is part of the Shurek Accounting & Tax family of brands. If you want the study and the tax work under one roof — the return, the Form 3115, entity structure, quarterly estimates, multi-state filings — that is a single engagement, not a hand-off between two firms.

No-cost feasibility review

Find out what your building is hiding.

A feasibility review is free and takes about twenty minutes. Bring the closing statement and the depreciation schedule; we will tell you plainly whether a study pays for itself.

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