The Highway to Changing Tax Return Due Dates

Sometimes Congress passes bills that include provisions not related to the main bill. Such was the case when it passed the highway funding bill, “Surface Transportation and Veteran’s Health Care Choice Improvement Act of 2015,” which included provisions that change the due dates of several tax returns and other required filings starting for tax year 2016 (returns and Forms that will generally be filed in 2017). The Act set new due dates for tax returns for partnerships, corporations, trusts and estate extensions, and tax-exempt organization extensions. It also changes the due dates for the FinCEN Form 114, Report of Foreign Bank and Financial Accounts (FBAR).

Partnership Returns

For partnership returns, the new due date for Form 1065 is March 15 for calendar year partnerships and the 15th day of the third month following the close of the fiscal year for fiscal-year partnerships. For 2015, these returns were due on April 15, 2016 for calendar-year partnerships. However, the extended due date remains the same (September 15 for calendar-year filers), as the Act directs the Internal Revenue Service (IRS) to allow an extension of six months for Form 1065, US. Return of Partnership Income.

C-Corporation Returns

For C corporations, it’s a little more involved. The new due date for Form 1120 is the 15th day of the fourth month following the close of the corporation’s tax year. For 2015, these returns were due on the 15th day of the third month following the close of the tax year. C-Corporations will be allowed a six-month extension, except calendar-year corporations will have a five-month extension until 2026. For C-Corporations with June 30 year ends, the new due dates will not apply until tax years beginning after December 31, 2025. Yes, that’s 2025; not 2015.

Trust, Estates, and Tax-Exempt Organizations

For trusts and estates, the initial due dates of Form 1041 remain the same – the 15th day of the fourth month after the year end. However, the extension period is lengthened by half a month. For calendar year trusts and estates, the extended due date changes from September 15 to September 30.

For tax-exempt organizations, the initial due date for Form 990 remains at May 15, or the 15th day of the fifth month after year end for fiscal year ends. The final extended due date also remains the same – at November 15, or the 15th day of the eleventh month after year end for fiscal year ends. For 990 extensions, there is a single automatic six-month extension, which eliminates the need to prepare the second three-month extension.

FBAR Changes

The biggest due date changes are for the Foreign Bank and Financial Accounts Report (FBAR). This is FinCEN Report 114, which is required for individuals and businesses with a financial interest in, or signature authority over, at least one financial account located outside the United States, and the aggregate value of the foreign accounts exceeds $10,000 at any time during the
calendar year. The due date has been changed from June 30 to April 15. Fortunately, there is now an extension available – a six-month extension to October 15.

The following link will prove a chart produced by the American Institute of Certified Public Accounts (AICPA) of due date changes for taxable years starting after December 31, 2015:

https://www.aicpa.org/InterestAreas/Tax/Resources/Compliance/DownloadableDocuments/Due-Dates-SummaryChart.pdf

By: Lewis A. Chabot, CPA | Manager

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