Final Regulations Offer a Reminder of Filing Due Date Changes

| 2/6/2020

The U.S. Department of the Treasury and the IRS recently released final regulations regarding filing due dates and extensions for certain tax returns. The rules implement changes made by legislation enacted in 2015. Although the regulations finalize without change temporary regulations that would have expired this summer, they provide a good reminder of some of the more significant changes to filing due dates enacted in 2015.

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Noteworthy due dates that were changed by the legislation enacted in 2015 include:

  • C corporations. Income tax returns for most C corporations are due the 15th day of the fourth month following the close of the tax year (April 15 for calendar year C corporations). C corporations are eligible for a six-month automatic filing due date extension. The extended due date is Oct. 15 for calendar year C corporations.
    • Through 2025, income tax returns for C corporations with a tax year-end of June 30 are due Sept. 15, but they are eligible for a seven-month automatic filing extension to April 15. A return for a short period that ends on any day in June is treated as the return for a tax year that ends on June 30.
  • S corporations. Income tax returns for S corporations are due the 15th day of the third month following the close of the tax year (March 15 for calendar year S corporations). S corporations are eligible for a six-month automatic filing due date extension. The extended due date is Sept. 15 for calendar year S corporations.
  • Partnerships. Partnership returns are due the 15th day of the third month following the close of the tax year (March 15 for calendar year partnerships). Partnerships are eligible for a six-month automatic filing due date extension. The extended due date is Sept. 15 for calendar year partnerships.
  • Form W-2s and W-3s. Most Form W-2s, “Wage and Tax Statement,” and W-3s, “Transmittal of Wage and Tax Statements,” are due Jan. 31 of the year following the calendar year for which the information is being reported, regardless of whether the form is being filed on paper or electronically.
  • Form 1099-MISCs. Paper-filed Form 1099-MISCs, “Miscellaneous Income,” are due Feb. 28 of the year following the calendar year for which the information is being reported. Electronically filed Form 1099-MISCs are due on March 31 of the year following the calendar year for which the information is being reported.
    • Form 1099-NEC. Beginning in 2020, there is a new Form 1099-NEC, “Nonemployee Compensation,” for reporting compensation paid to nonemployees. Form 1099-NEC is due Jan. 31 of the year following the calendar year for which the information is being reported, regardless of whether the form is being filed on paper or electronically.
In addition, the final regulations remove the requirement to file Form 1065-B, “U.S. Return of Income for Large Electing Partnerships,” for electing large partnerships because the form became obsolete following changes enacted by the Bipartisan Budget Act of 2015.

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