Thinking Beyond the Numbers

Mark BellowsAuthor:
Mark Bellows
Sacramento Region Partner Group

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On July 31, 2015, President Obama signed into law a short-term extension of the mass transit and highway funding bill. The bill, titled the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015, extends various federal transportation funding through October 29, 2015. In order to pay for this additional three months of funding (since this bill, like all bills, must be “revenue-neutral” meaning it expenses must be paid for in full by additional revenues), the bill changes the due dates (original and extended) of many tax returns and reports. Most of these changes apply to returns for tax years beginning after December 31, 2015, although some do not take effect until after 2025.

A highlight of the existing rules and changes for due dates and extensions are listed below:

• For partnerships, the due date is March 15 for calendar year partnerships, and the 15th day of the third month after the close of the fiscal year for fiscal year partnerships. The law allows for a six-month extension. This is a change in the due date, since presently returns for partnerships are due on the 15th day of the fourth month following year end.
• For S corporations, the due date is March 15 for calendar year S corporations, and the 15th day of the third month after the close of the fiscal year for fiscal year S corporations. The law allows for a six-month extension.
• For C corporations, the due date is April 15 for calendar year C corporations, and the 15th day of the fourth month after the close of the fiscal year for fiscal year C corporations. The law allows for an automatic six-month extension, EXCEPT for calendar-year C corporations, which will only get an automatic five-month extension until 2026, and corporations with a June 30 year end will get an automatic seven-month extension until 2026. This is a change in the due date, since presently returns for C corporations are due on the 15th day of the third month following year end. This is also a change in the automatic extension period, since presently C corporation are provided an automatic three-month extension by the Internal Revenue Code, and an automatic six-month extension by the Internal Revenue Regulations. There is also a specific rule for C corporations with fiscal years ending on June 30: the new due dates will not apply until tax years beginning after December 31, 2025.
• For trust returns, the due date is April 15 for calendar year trusts, and the 15th day of the fourth month after the close of the fiscal year for fiscal year trusts. The law allows for a five and a half-month extension. This is a change in the extension period, since presently the extension period is five months.
• For exempt organizations, the due date is May 15, and the 15th day of the fifth month after the close of the fiscal year for fiscal year exempt organizations. The law allows for an automatic six-month extension. This is a change in the extension period, since presently exempt organizations can get two three-month extensions.
• For employee benefit plans, the due date is July 31, and the law allows for an automatic three and a half-month extension. This is a change in the extension period, since presently plans can get a three month-extension.
• There is a big change with the FinCEN Report. This report, and its predecessor form Report of Foreign Bank Account (FBAR), have historically been due on June 30, with no extension allowed. Under the new law, the Report is due April 15, and the law allows for a six-month extension.

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© 2015