Form 15 Filing Deadline 15 How To Leave Form 15 Filing Deadline 15 Without Being Noticed

To acquiesce partnerships that may accept fabricated errors on their 2018 tax allotment a adventitious to actual those errors, the IRS is acceding assertive partnerships a adventitious to book superseding 2018 tax allotment (Rev. Proc. 2019-32). The abatement applies to partnerships that had appropriate filed their Forms 1065, U.S. Acknowledgment of Affiliation Income, and Schedules K-1 (Form 1065), Partner’s Share of Income, Deductions, Credits, etc., for the 2018 tax year (March 15 for calendar-year taxpayers) and did not accept out of the new centralized affiliation analysis regime. Such partnerships will now be accustomed an addendum of time to book superseding 2018 Forms 1065 and Schedules K-1 by Sept. 15, 2019.



The Bipartisan Budget Act of 2015 (BBA), P.L. 114-74, replaced the TEFRA affiliation procedures with a centralized affiliation analysis administration that, in general, determines, assesses, and collects tax at the affiliation level. Tax years of partnerships alpha in 2018 were the aboriginal tax years for which the centralized affiliation analysis administration was binding and the aboriginal tax years for which partnerships are banned from alteration Schedules K-1 beneath Sec. 6031(b). A cardinal of partnerships accept filed for extensions of time to book their 2018 allotment and may book an aboriginal or superseding acknowledgment by the continued due date of Sept. 15.

Many added partnerships accept filed their allotment on time for the 2018 tax year but may accept fabricated errors, including not appropriately advertisement all of the appropriate advice on Schedules K-1. These BBA partnerships, accepting appropriate filed, did not appeal an addendum of the borderline to book and, due to the restrictions on alteration Schedules K-1 beneath Sec. 6031(b), may not alter the Schedules K-1, including for the 2018 tax year. The adeptness of the ally of such BBA partnerships to alter their own allotment for the 2018 tax year is not afflicted by the restrictions beneath Sec. 6031(b); however, if the accomplice is a BBA partnership, the restrictions beneath Sec. 6031(b) may apply.



To be acceptable for abatement beneath this procedure, the affiliation charge (1) not accept adopted the appliance of Sec. 6221(b) (the acclamation out of the BBA); (2) accept appropriate filed Form 1065; and (3) accept appropriate furnished all Schedules K-1 appropriate to be furnished (without attention to the extensions of time provided in the relief).

Under the relief, the IRS will amusement the appropriate filing of Form 1065 by an acceptable affiliation as a appropriate and appropriately filed appeal for a six-month addendum of the borderline to book the Form 1065. Thus, an acceptable affiliation may book a superseding Form 1065 and accouter agnate Schedules K-1 afore the cessation of the continued deadline.



To booty advantage of this relief, acceptable partnerships should book their superseding allotment on or afore six months afterwards the due date and accommodate the afterward account at the top of the superseding Form 1065: “SUPERSEDING FORM 1065 PURSUANT TO REVENUE PROCEDURE 2019-32.”

The abatement applies alone to affiliation tax years that concluded above-mentioned to the arising of the acquirement action and for which the continued due date for that affiliation tax year is afterwards July 25, 2019.

— Sally Schreiber, J.D., (Sally.Schre[email protected]) is a JofA chief editor.

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