Important Changes to Tax Filing Deadlines

Christopher D. Daniel, CPA (Jul, 2016)

Have you thought about how the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 will impact your 2016 Federal tax return? It may seem like an odd question considering the title of the act, but buried within it are several provisions that could change your tax return filing deadlines. The 2016 deadlines may seem a long way off, but it's never too early to start tax planning.

First, what isn't changing? S Corporations will continue to file their Form 1120S on the 15th day of the third month following the end of its tax year. If your S Corporation is a calendar year filer, mark your calendars for March 15, 2017. April 15th will also remain as the filing deadline for individuals filing their Form 1040. (Take note that in 2017, due to the 15th falling on a Saturday, individual tax returns will be due on April 17, 2017.) Extended due dates for calendar year filers will remain unchanged for both of these types of taxpayers as well (September 15th for S Corporations and October 15th for individuals).

The change to Partnership tax returns, Federal Form 1065, is very important. If you are one of these taxpayers, you now have less time to file your return by the original due date. Under the old rules, partnership returns were due on the 15th day of the fourth month following the end of its tax year. Now they are due on the 15th day of the third month (March 15th for calendar year filers). There is no change to the extended due date of September 15th for partnerships.

Calendar year C Corporations have an extra month to file their Form 1120. These returns will now be due on April 15th, instead of March 15th.  Pushing back the initial due date does not also push back the extended due date. Extended C Corporation returns will continue to be due on September 15th (at least until 2026 when some additional provisions in the law kick in and push back the due date to October 15th).

Now here is where things get a little more complicated. If a C Corporation has a June 30th year-end, due dates will change, but it will be slightly delayed. The return you are working on now, that is for the year ended June 30, 2016, will continue to be due on September 15, 2016, or March 15, 2017 if you extend. In fact, there is no change to the initial due date for quite some time. You can keep September 15th circled on your calendar for the next ten years, but after that, things change. Beginning in 2027, there is a bit more wiggle room and you will have until October 15th to file. The good news is you don't have to wait until 2027 to get extra extended time. Starting with next year's Form 1120, the extended due date is April 15th.

All other fiscal year-end C Corporation filers will need to figure out their due dates based on their specific year-end. These returns will be due on the 15th day of the fourth month after the year-end. A timely filed extension request will buy you an extra six months beyond that initial due date.

So, why did Congress make these changes? By-in-large it has to do with the Form K-1 generated by a partnership or Limited Liability Company (LLC) when it files its Form 1065. Under the old rules, calendar year C Corporation returns were due in March, while individual and partnership returns were due in April. This created a system with built in delays. Corporate and individual partners need the partnership information provided on Form K-1 to prepare their returns. This almost always put these taxpayers in a position of having to extend if a partnership waited until the April 15th due date to file its return. By flip-flopping partnership and C Corporation filing due dates, a partnership will be required to file its K-1s a full month before an individual's or C Corporation's return is due. This will allow time for these taxpayers to incorporate the K-1 information into their tax returns.

"Wait," you say, "where's the love for exempt organizations filing Form 990"? Well, there is good news for you as well. The old system allowed for up to 6 months of extra time to submit your return if you needed an extension, however it was a two-step process. You would first file for a 90-day extension and then you could file for a second 90-day extension, if you still needed more time. Those days are now behind us and for all taxable years beginning after December 31, 2015 you can now file for a single automatic 6-month extension.

There are a few other deadline changes buried in the new law that affect benefit plans, trusts, foreign accounts and certain information returns. Please feel free to contact a Dermody, Burke & Brown tax professional if you file one of these returns or have questions related to your specific situation. Despite the best of intentions to streamline and simplify, changes in the law can be confusing and it can never hurt to have a little guidance along the way.

Tax Return Filing Deadlines for Tax Years Beginning After December 31, 2015
 
      Prior Due Date   New Law Calculations   New Due Date  
  Individuals – No Change              
  Original Filing Deadline   April 15   15th day of 4th month   April 15  
  Extended Filing Deadline   October 15   15th day of the 10th month   October 15  
                 
  Partnerships – December 31 year-end              
  Original Filing Deadline   April 15   15th day of 3rd month   March 15  
  Extended Filing Deadline   September 15   15th day of the 9th month   September 15  
                 
  S Corporations – No Change              
  Original Filing Deadline   March 15   15th day of 3rd month   March 15  
  Extended Filing Deadline   September 15   15th day of the 9th month   September 15  
                 
  C Corporations – December 31 year-end              
  Original Filing Deadline   March 15   15th day of 4th month   April 15  
  Extended Filing Deadline   September 15   15th day of the 9th month *   September 15  
                 
  C Corporations – June 30 year-end              
  Original Filing Deadline   September 15   15th day of 3rd month *   September 15  
  Extended Filing Deadline   March 15   15th day of the 10th month   April 15  
                 
  C Corporations – All other fiscal year-ends              
  Original Filing Deadline   15th day of 3rd month   15th day of 4th month   Varies  
  Extended Filing Deadline   15th day of the 9th month   15th day of the 10th month   Varies  
                 

* These deadlines will be one month later for tax years beginning after December 31, 2025

 

The information reflected in this article was current at the time of publication.  This information will not be modified or updated for any subsequent tax law changes, if any.

 

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