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Thursday, February 9, 2017

Extended due date for calendar year corp - what?

In 2015, Congress changed the due date for several types of entities as well as for the FBAR (for foreign financial accounts). The AICPA has a wonderful chart with all of the new dates noted.

When Congress made the changes for C corporations, they apparently had a concern with a change that would move a due date from one government fiscal year into the next fiscal year. The federal government's fiscal year ends September 30.  Prior to the due date changes, we had these due dates:

Calendar year corporation - due March 15, extend to September 15
June 30 corporation - due September 15, extend to March 15

You can see that the extended due date for calendar year and original due date for June 30 corporations crosses the government's fiscal year end if one more month is added to these due dates.

So, Congress said that for the next ten years (2016 through 2025), the extended due date for calendar year corporations would remain at September 15 and the original due date for June 30 corporations would remain the same.  But, the other due dates would have one month added (so calendar year returns due April 15 and June 30 extended return due April 15). After 2025, the due dates would be 3 1/2 months after year end + 6 months extension.

This makes sense (I'm being generous) for the June 30 corporation because its taxes are due on September 15. If that got changed to October 15, it pushes revenue into the next fiscal year. But this isn't the case for the extended due date for calendar year corporations because tax is always due by the normal (unextended) due date.

Well, the IRS recently told us via instructions to Form 7004 and a statement on their website (dated 2/7/17), that it will give calendar year corporations a 6 month extension to October 15 now, even though Congress said September 15 through 2015 and only October 15 after 2025. This is a logical answer, but many practitioners already learned that it was September 15.  Not the end of the world, but one more example of little items that can add up to some confusion.

What do you think? Did IRS make it simpler or more complicated?

1 comment:

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