< Back to Our Insights

Share

The American Institute for Certified Public Accountants (AICPA) has long advocated for the due dates of tax returns to be changed in order to facilitate the flow of information between taxpayers in a more sensible order. Their efforts, along with others advocating for this change, have come to fruition with the enactment of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015. On July 31, 2015, President Obama signed the short-term highway funding extension into law and with it altered several common tax return deadlines. These deadline changes are effective beginning with the filing of the 2016 tax returns. Taxpayers should be aware of how the new deadlines may affect them for the upcoming filing season.

*It should be noted that the individual return (Form 1040) deadline of April 15 did not change. The chart below depicts the federal due dates for the 2016 tax returns. The changed deadlines are in bold.

January 31

Information Returns (i.e. W-2 and 1099s)

Prior Due Dates: To IRS/SSA – February 28 and March 31 if filed electronically
New Initial and Extended Deadlines: Forms W-2 and certain 1099-MISC due to IRS/SSA January 31. All other Form 1099s due February 28; March 31 if filled electronically. (The accelerated deadline for information returns was caused by the enactment of the PATH Act.)

March 15

Extension until September 15

Foreign Trusts with a U.S. owner; Form 3250-A

Prior Due Dates: March 15; September 15
New Initial and Extended Deadlines: March 15; September 15 (No change)

Partnership (calendar year) Form 1065

Prior Due Dates: April 15; September 15
New Initial and Extended Deadlines: March 15; September 15 (Under new law, the return will be due on the 15th day of the 3rd month after year-end. A six-month extension is allowed.)

 S Corporation (calendar year) Form 1120S

Prior Due Dates: March 15; September 15
New Initial and Extended Deadlines: March 15; September 15 (No change) This is the due date for the tax return and also for the Schedule K-1 that the entity must provide to its owners.

April 15

Extension until October 15, unless noted below

Individual Form 1040

Prior Due Dates: April 15; October 15
New Initial and Extended Deadlines: April 15; October 15 (No change)

Trust and Estate Form 1041

Prior Due Dates: April 15; September 15
New Initial and Extended Deadlines: April 15; September 30 (Under the new law, there is a 51/2 month extension.)

C Corporation (calendar year) Form 1120

Prior Due Dates: March 15; September 15
New Initial and Extended Deadlines: April 15; September 15 (Beginning with the 2026 tax returns, the extension deadline will be moved to October 15.)

C Corp Fiscal Year End (other than December 31 or June 30) Form 1120

Prior Due Dates: 15th day of 3rd month after year-end; 15th day of 9th month after year-end
New Initial and Extended Deadlines: 15th day of 4th month after year-end; 15th day of 10th month after-year end

C Corporation June 30 Fiscal Year Form 1120

Prior Due Dates: September 15; March 15
New Initial and Extended Deadlines: September 15; April 15 (Beginning with the 2026 tax returns, the deadline will be October 15 with an extension deadline of April 15.)

FinCen Report 114

Prior Due Dates: June 30
New Initial and Extended Deadlines: April 15; October 15; Foreign Bank and Financial Account Report (FBAR)

May 15

Extension until November 15

Exempt Organization Forms 990

Prior Due Dates: May 15; August 15; November 15
New Initial and Extended Deadlines: May 15; November 15 (Removed need to file the first 90-day extension, and the extension will now be an automatic 6-month extension.)

July 31

Extension until October 15

Employee Benefit Plans Form 5500

Prior Due Dates: July 31; October 15
New Initial and Extended Deadlines: July 31; October 15 (No change)

Why the new due dates are helpful

One of the AICPA’s biggest goals was to improve the tax filing process. It would seem they made strides in achieving this goal by changing the partnership Form 1065 due date to having the earliest deadline. This is both logical and helpful because all other entities and individuals can be partners in a partnership and thus may need information from Schedules K-1 from partnership investments to timely and accurately complete their tax returns.

Once partnership and S corporation returns have been filed by March 15, and owners have received their Schedules K-1, individuals, trusts, and C corporations will have the information they need from their passthrough entity investments to file accurate and timely returns. Under the new law, trusts will have two more weeks after receiving their extended partnership and S corporation Schedules K-1 to complete their extended return. Trusts will then issue their extended Form 1041 Schedules K-1 to beneficiaries, who will have an additional two weeks to complete their extended personal returns. In addition, taxpayers with foreign accounts will have all the information needed to complete FinCEN Form 114 at the same time as the individual tax return due date and extension.

C corporations will largely benefit from the new due date of April 15. Many C corporations previously needed to extend their returns because they were waiting on audited financial statements, which typically arrive by the end of March. The AICPA hopes that the new return deadlines will benefit corporations from needing to extend the income tax return. Although the new legislation created a later extension deadline, it will not be applicable until 2027 when the 2026 tax returns are being filed.

*It should be noted that the due dates for estimated tax payments have not changed.

Kathryn Merkle

Kathryn Merkle is a staff assistant in the Tax Department. She earned her B.S. in financial accounting and her M.S. in accountancy from Illinois State University.