Due Dates Changed for FBARs and Some IRS Tax Returns

Although your IRS tax return is still due April 15^th and the six-month automatic extension remains intact, Congress has recently moved a number of other deadlines for filing returns. Due dates have been changed for corporate tax returns, partnership returns, and FBAR forms (FinCEN Form 114) by way of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (H.R. 3236). The law, though not directly tax-related, also increases a number of IRS audit periods from three years to six under particular circumstances.

The following changes are applicable as of January 1^st, 2016:

• C corporation tax returns, which were due March 15^th, will be due April 15^th. For non-calendar years: “the 15^th day of the fourth month following the close of the tax year.”
• Partnership tax returns, which were due April 15^th, will be due March 15^th. For non-calendar years: “the 15^th day of the third month following the close of the tax year.”
• The due dates for FBAR forms will change from June 30^th to April 15^th and allow for six-month extensions.
• C corporations whose tax years end on June 30^th currently have a due date of September 15^th; after the year 2025, these returns will be due one month later, on October 15^th.
• S corporation tax returns are unchanged and remain due on March 15^th, or “the third month following the close of the taxable year.”

If the balances of any of your foreign accounts exceed $10,000 within a taxable year, you must file an FBAR (Form 114) and penalties for not doing so may include both civil and criminal sanctions. Although most tax evasion charges carry a potential three-year prison term, FBAR charges are punishable by up to ten years.

FBAR forms are now required by FinCEN to be submitted electronically, as well.

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