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Many bills that Congress passes contain provisions that affect items that aren’t related to the main bill. The “Surface Transportation and Veteran’s Health Care Choice Improvement Act of 2015” is one such bill. Primarily a stopgap extension of the Highway Trust Fund, this bill also includes tax provisions that impact the due dates of a number of returns and other required filings.
The due date changes with the most impact will likely be those changes for partnership tax returns (Form 1065) and C Corporation tax returns. Essentially the due dates have swapped. The significant reorganization of due dates is intended to assist individuals involved in pass-through entities in receiving information required to prepare their individual returns in a more timely fashion.
For tax returns reporting 2016 information that are due in 2017, the following due date changes will apply. These changes are effective for tax years beginning after December 31, 2015 for calendar year filers (tax year 2016 and beyond):
|Form||2016 Filing Due Date
(Tax Year 2015)
|2017 Filing Due Date
(Tax Year 2016)
|Form 1065 – Partnerships||April 15th||March 15th|
|C Corporations||March 15th||April 15th|
|Form 1065 Extension||September 15th||September 15th|
|Form 1041 Extension||September 15th||September 30th|
|Form 5500 series – Employee Benefit Plan Extension||October 15th||November 15th|
|FinCEN 114 – FBAR (will be allowed to extend)||June 30th||April 15th|
For fiscal year filers:
- Partnership and S Corporation tax returns will be due the 15th day of the third month after the end of their tax year. The filing date for S Corporations is unchanged.
- C Corporation tax returns will be due the 15th day of the fourth month after the end of the tax year. A special rule to defer the due date change for C Corporations with fiscal years that end on June 30 defers the change until December 31, 2025 – a full ten years.
Other changes include:
- Filers of U.S. Return of Partnership Income (Form 1065) will have a longer extension period, a maximum of six months, rather than the current five month extension, leaving the current (2015 and prior years) extended due date in place (September 15th for calendar year taxpayers.)
- U.S. Income Tax Return for Estates and Trusts (Form 1041) will have a maximum extension of five and a half months, two weeks longer than the current (2015 and prior years) five month extension.
- Annual Return/Report of Employee Benefit Plans will have a maximum automatic extension of three and a half months.
- Report of Foreign Bank and Financial Accounts (FinCEN 114, FBAR) will be due on April 15th and permitted to extend for six months, thus aligning the FBAR reporting with the individual tax return reporting. Additionally, the IRS may waive the penalty for failure to file a timely extension request for any taxpayer required to file for the first time.
If you have any questions about these new due dates and the impact on your tax filings, please contact one of our qualified tax professionals at 703.385.8888.
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