How to Fill Out Form 15307: Eligibility, Adequacy, and 30-Day Deadline

To fill out Form 15307, Post-Filing Disclosure for Specified Large Business Taxpayers, you complete the entity header, then build a separate disclosure block for every adjustment you want to disclose (up to 100), sign under penalty of perjury, and furnish the form directly to the IRS examination team within 30 days of their written request. Done properly, it is treated as a qualified amended return under Revenue Procedure 2022-39 and blocks the negligence and substantial understatement penalties on the disclosed items.¹

Confirm You Are Eligible Before You Start

Form 15307 is only available to “eligible taxpayers” under Revenue Procedure 2022-39. That means a taxpayer selected for examination under the Large Corporate Compliance (LCC) program whose returns for at least four of the five taxable years before the audit year were also under examination by LCC, the former Coordinated Industry Case program, or a successor program. Partnerships qualify under the same four-of-five-year test through the Large Partnership Compliance program.¹

You don’t self-certify. The IRS tells you during the examination whether you qualify. If you don’t, Form 15307 is not the right vehicle: a traditional qualified amended return or Forms 8275 and 8275-R remain available for penalty-protective disclosure through other routes.

Complete the Header Fields

The header captures entity-level information that applies to every disclosure on the form.

Name on Return: the entity that filed the return. For a consolidated corporate return, enter the common parent’s name.
EIN on Return: the filing entity’s EIN, or the common parent’s EIN for consolidated filers.
Tax Year: the year the disclosure relates to.
Schedule UTP / Form 8275 / Form 8275-R checkbox: check this if any of those forms were filed with the original return for the year. When checked, attach a copy of the previously filed form and use the explanation box to add context.
Number of disclosures: enter the total at the top. The form allows up to 100, and it generates a separate block for each.

Build a Separate Block for Each Adjustment

Each item you want disclosed gets its own block. Netting adjustments against each other is not permitted, even when they involve the same code section or the same subsidiary. Every block must let the IRS identify what the item is, how much it involves, and why it is or could be controversial.¹

Fields in each disclosure block:

Subsidiary or Legal Entity: for consolidated filers, identify the subsidiary or entity affected. Non-consolidated filers generally skip this, but if the item involves a disregarded entity or a foreign entity not separately shown on the consolidated return, report it here.
Primary Citation: the IRC section or full regulatory citation, such as “IRC § 163(j)” or “Treas. Reg. § 1.861-8.”
Adjustment Type: choose from ordinary income, capital gain or loss, Section 1231 gain or loss, ordinary gain or loss, dividends received deduction, expense deduction, tax credits, or other.
Timing: mark the item as permanent, a short-term temporary difference reversing within one to three years, a longer-term temporary difference reversing within three to ten years, or another timing pattern.
Effect on Other Years: Yes if the item affects a prior or subsequent tax year; otherwise No.
Entity’s EIN: the EIN of the affected subsidiary or disregarded entity, if available.
Form or Schedule, Page, and Line: the specific IRS form, page number, and line number the adjustment hits.
Increase (Decrease) to Taxable Income: the dollar change to taxable income. Required for all non-credit adjustments.
Increase (Decrease) to Tax Credits: complete this instead of the taxable income field when the disclosure relates to credits.
Explanation: a detailed narrative of the facts and circumstances behind the item.

You do not have to recompute total tax liability unless the disclosure relates to tax credits.¹

Write Explanations That Actually Meet the Adequacy Standard

The explanation field is where most disclosures succeed or fail. The IRS evaluates each disclosure for adequacy, and one built on incomplete information, unreasonable assumptions, or noncompliance with the instructions will be deemed inadequate. If that happens, the disclosure gives you no penalty protection. The IRS will notify you, but usually after the 30-day window has closed, so there is little room to fix the problem.¹

To meet the standard, each description has to reasonably apprise the IRS of three things: the identity of the item, its dollar amount, and the nature of the actual or potential controversy. State each adjustment separately, with no netting. Explanations that lay out specific facts and dollar figures rarely have adequacy problems. The ones that get rejected are the bare-bones entries that give a code section and a lump-sum number and nothing else.

Sign Under Penalty of Perjury

Form 15307 includes a perjury declaration. The signer provides name, title, signature, and date. Electronic signatures are accepted. Because the form applies to business entities, the signer is typically a corporate officer or authorized representative with authority to bind the entity.

Meet the 30-Day Deadline and Deliver to the Exam Team

The examination team sends a written request asking for Form 15307 for a particular tax year. You have 30 days from that request to furnish the completed form. The deadline can be extended only if the IRS agrees in writing to a later date for that specific tax year.¹ Missing it means the form is not treated as a qualified amended return, and the penalty protection is gone for anything not disclosed on time.

Delivery goes directly to the IRS personnel running the examination, not to a general mailing address or processing center. Coordinate submission with the assigned LB&I examiner or team manager, and keep proof of the date you furnished it so the 30-day window is documented.

Know What the Form Protects — and What It Doesn’t

A properly completed Form 15307 shields you from two specific accuracy-related penalties under IRC Section 6662: the 20 percent penalty for negligence or disregard of rules and regulations under Section 6662(b)(1), and the 20 percent substantial understatement penalty under Section 6662(b)(2).² For corporations other than S corporations or personal holding companies, a substantial understatement exists when the understatement exceeds the lesser of 10 percent of the tax due (or $10,000 if greater) and $10 million.³

Other Section 6662 penalties stay in play. The 40 percent penalty for gross valuation misstatements and the 40 percent penalty for nondisclosed noneconomic substance transactions are outside the scope of Form 15307.²

Protection also depends on agreement at the end of the audit. The IRS will not assert negligence or substantial understatement penalties on a disclosed adjustment that is agreed upon at the conclusion of the examination.¹ If you don’t ultimately agree to the disclosed adjustments, the additional tax does not reduce the underpayment subject to the negligence penalty, and it does not reduce the substantial understatement penalty unless you had a reasonable basis for the position identified on Form 15307.

1
Internal Revenue Service. Revenue Procedure 2022-39
2
Office of the Law Revision Counsel. 26 USC 6662 – Imposition of Accuracy-Related Penalty on Underpayments
3
Internal Revenue Service. Accuracy-Related Penalty