Recent legislation has made changes to due dates for some tax and information returns that will be filed for the 2016 and following tax years. These changes will require modifying the timing of the preparation work in many cases.
Payroll and information reporting returns (Forms W-2 and 1099)
These forms historically were sent to the recipients by January 31st of each year, and government reporting copies of these forms were transmitted by either February 28th or March 31st , depending on whether they were mailed or electronically filed. For 2016 returns filed in 2017, all copies of the forms must be sent to recipients and filed by January 31st. This change was made to combat identity theft by allowing the IRS to match withholding information when tax returns are filed and reject fraudulent refund claims. The due dates for filing all other information reporting returns remain unchanged. See the table below for specific details:
Income tax returns
Partnerships and C Corporations also have new due dates for the 2016 tax year. Starting in 2017, partnership returns will be due 2½ months after year-end (March 15th for calendar year filers) and C Corporations will be due 3½ months after year-end (April 15th for calendar year filers). This switch is intended to put the due dates in a more logical order. Pass-through entities such as S Corporations and partnerships will now be due one month prior to individual and C corporation returns.
- S Corporations – Return due dates will remain the same at 2 ½ months after the close of the year (a six-month extension is available).
- Partnerships – Returns are now due 30 days earlier (2½ months after the close of the year). The automatic extension has been increased from five months to six months which retains the same extended due date (September 15th for calendar year filers).
- C Corporations – Returns are now due 30 days later (3½ months after the close of the year). The extension remains at six months resulting in a later extended due date except for calendar year filers who will have only a five-month extension (until 2026).
- Calendar-year C corporations – The extension remains five months instead of six months (until 2026). This means that the original due date is 30 days later, but the extended deadline remains the same at September 15th (until 2026).
- Fiscal-year C Corporations with a June 30th year-end – Until 2026, returns will still be due 2½ months after year-end (September 15th), but a seven-month extension is available. In 2026, the original due date will be 3½ months and the extension will be six months.
- Trusts – The due date will stay at 3½ months after the close of the year, but the 5 month extension will change to 5½ months for trusts filing Form 1041 and six months for trusts filing Forms 5227, 3520 or 3520-A.
See the table below for filing dates for 2016 returns:
Foreign Bank Account Reporting
The foreign bank account reporting deadlines will now mirror the individual tax return deadlines more closely. Currently, the reporting deadline for reporting foreign bank accounts on Form FIN Cen 114 is June 30th with no extension available. Under the new regulations, the initial due date will move to April 15th (the individual tax return deadline) with a new extension available until October 15th (the extended individual deadline).