Now that we are past the extended deadlines for calendar year entities, we can look forward to the changes in store for tax year 2016. The Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 changed the due dates for partnerships and C corporations’ returns beginning with the 2017 filing season (2016 year-end). There is also a welcome change for individuals with foreign assets who are required to file FINCEN Form 114. The rules are in effect for tax years beginning after December 31st, 2015. This will affect upcoming 2016 returns filed in the spring and also will apply to any short-year returns filed this year.
With both partnership and individual returns due on April 15th, a filing time crunch would occur as individual partners need partnership information (Schedule K-1) for the completion of their returns, usually necessitating the extension of their personal return. The new filing deadline for a Partnership’s Form 1065 is the 15th day of the third month after the fiscal year-end (March 15th for calendar year companies). This is a change from the historical due date of April 15th for calendar year entities. In theory, this may provide some partners with the information necessary to file their individual returns a month later without the need for extension. Those partnerships requiring additional time to file will be able to request a six-month extension of time to file (September 15th for calendar year entities) which is consistent with existing rules.
Given the complexity of many C corporations, and the fact that financial statement reports (audits, reviews, etc.) usually conclude two to three months after year end, the Internal Revenue Service (IRS) has moved the filing deadline to the 15th day of the fourth month after year end (April 15th for calendar year companies). C corporations requiring additional time to file their returns may request a five-month extension of time to file their returns (September 15th for calendar year companies) which is consistent with the existing deadline.
Individuals with foreign assets (cash, mutual funds, etc.) that exceed over $10,000 in the aggregate at any point during the year are required to file FinCEN Report 114. The FinCEN 114 has sensibly been moved up from June 30th to April 15th, now due consistent with the timing of the taxpayer’s individual income tax returns. Additionally, taxpayers may now request a six-month extension of time to file their FinCEN 114 (previously there was no extension available).
Finally, as a reminder, the due dates for filing certain information returns, i.e. Forms W-2, 1099, etc., have changed for the 2017 filing season. These forms are now required to be filed with the Social Security Administration by January 31st, with no extension for electronically submitted forms. Please see the link to a previous article for more information https://www.schneiderdowns.com/our-thoughts-on/tax/new-filing-dates-for-certain-information-returns