New IRS Filing Deadlines for Many Tax and Information Returns

Jim Moran, Tax Senior Manager
September 2016

Background

Several pieces of legislation signed into law during 2015 changed the due dates for certain taxpayers’ Income Tax and Information Returns effective for taxable years beginning after December 31, 2015. The goal of these changes is to allow the IRS to process certain returns and allow better matching capability in advance of individuals filing their 2016 individual income tax returns.

Form 1120 Taxpayers

The due date for taxpayers’ Form 1120-U.S. Corporation Return of Income (other than taxpayers with a June 30 year end) is now 3 ½ months after the end of the corporation’s taxable year. For 2016 calendar year corporate taxpayers filing Form 1120, the due date is now April 15, 2017 (i.e. a month later than the previous due date of March 15). An automatic five-month extension of time to file Form 1120 is available. The extended due date for a calendar year corporation remains September 15 until 2026 (at which time it will become October 15).

The due date for a taxpayer with a fiscal year end filing Form 1120 (except for a taxpayer with a June 30 year end) is 3 ½ months after the end of the taxpayer’s taxable year. Fiscal year taxpayers with a fiscal year end other than a June 30 year end receive an automatic six-month extension of time to file Form 1120.

The due date for corporate taxpayers’ Form 1120 with a June 30 year end filing remains the same (September 15), 2 ½ months after the end of the taxpayer’s taxable year, until tax years beginning after December 31, 2025, when the due date will become October 15. A June 30 year end corporate filer receives a 7-month extension until 2026, at which time the extension period will become 6 months.

Form 1065 Taxpayers

The due date for a taxpayer’s Form 1065-U.S. Partnership Return of Income is now 2 ½ months after the end of the partnership’s taxable year. For 2016 calendar year taxpayers filing Form 1065, the due date is now March 15, 2017 (before this change the due date would have been April 15). An automatic six-month extension of time to file is still available to taxpayers from the original due date of the return. The extended due date remains September 15 for calendar year partnerships. Many banks and other taxpayers rely on information in partnership Schedules K-1 in order to complete their tax returns, and the theory is that this change in partnership due dates will allow them to receive this information sooner.

Form 1120S Taxpayers

The original and extended due dates for taxpayers filing Form 1120S U.S Income Tax Return for an S Corporation remain unchanged.

Form 1041 Taxpayers

There is no change to trust tax returns’ original filing deadlines, but extended deadlines for some are changed. To allow trusts to more easily incorporate partnership K-1 income allocated to them, all calendar year-end trust returns that are extended may file as late as September 30, rather than the historical deadline of September 15. Most non-calendar year-end trust returns that are extended will continue to receive a 5-month extension.

Report of Foreign Bank and Financial Accounts (FBAR Filers)

The due date for all taxpayers filing 2016 FinCEN 114-Report of Foreign Bank and Financial Account (FBAR) has changed for ALL TAXPAYERS from June 30, 2017 to April 15, 2017. However, unlike in the past, there is a provision for an automatic six-month extension until October 15, 2017.

Form 1099 MISC

Taxpayers reporting amounts in Box 7 on Form 1099-MISC (Non-Employee Compensation) must send forms to the payment recipient and the IRS by January 31, 2017; all other 1099s follow the usual IRS filing deadlines (February 28 if paper-filed; March 31 if filed electronically).

Expanded Form 1098 Mortgage Interest Reporting

In addition to the previous information that is required to be included on Form 1098, effective for returns required after December 31, 2016, the following additional information needs to be furnished to a payor with respect to a debt secured by real property:

  1. The amount of outstanding principal on the mortgage as of the beginning of the taxable year;
  2. The loan origination date;
  3. The address (or other description in cases where no address exists) of the property securing the mortgage.

The purpose of these additional reporting requirements is to allow the IRS to better determine whether the amount of interest claimed by individual taxpayers is in excess of the dollar limits applicable to acquisition or home equity indebtedness.

If you have any questions, please contact Jim Moran or your BNN tax professional at 1.800.244.7444.

Disclaimer of Liability: This publication is intended to provide general information to our clients and friends. It does not constitute accounting, tax, or legal advice; nor is it intended to convey a thorough treatment of the subject matter.