On July 25, the IRS issued a Revenue Procedure 2019-32, which generally grants partnerships an automatic six-month extension to file amended 2018 tax returns (and furnish partners with corresponding Schedules K-1) if the partnerships have timely filed their original 2018 tax returns, even if they did not timely request an extension.
Partnerships generally are required to file their tax returns by the fifteenth day of the third month after the end of their taxable year (i.e., March 15, in the case of a calendar year partnership), but are entitled to an automatic six-month extension if they request the extension before the original deadline. However, partnerships that are subject to the new centralized partnership audit regime (which applies to most partnerships as of the 2018 tax year) generally are prohibited from amending their original tax returns if they do not request an extension before the original deadline. (We discussed the centralized partnership audit regime in a previous BrassTax article.)
Under Revenue Procedure 2019-32, the IRS will treat a timely filed partnership tax return by a partnership that is subject to the centralized partnership audit regime as a timely filed request for a six-month extension. As a result, the partnership may file a superseding tax return (and furnish partners with corresponding Schedules K-1) until the extended deadline.
This relief applies only to partnerships whose tax years ended before July 25 and whose extended due date for filing is after July 25.
Linda Z. Swartz
Partner
T. +1 212 504 6062
linda.swartz@cwt.com
Adam Blakemore
Partner
T. +44 (0) 20 7170 8697
adam.blakemore@cwt.com
Jon Brose
Partner
T. +1 212 504 6376
jon.brose@cwt.com
Andrew Carlon
Partner
T. +1 212 504 6378
andrew.carlon@cwt.com
Mark P. Howe
Partner
T. +1 202 862 2236
mark.howe@cwt.com
Catherine Richardson
Partner
T. +44 (0) 20 7170 8677
catherine.richardson@cwt.com
Gary T. Silverstein
Partner
T. +1 212 504 6858
gary.silverstein@cwt.com