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Rev. Proc. 2019-32: Extension of time for partnerships filing superseding Forms 1065

Partnerships filing superseding Forms 1065

The IRS today released an advance version of Rev. Proc. 2019-32 granting an extension of time to eligible partnerships to file a superseding Form 1065, “U.S. Return of Partnership Income,” and furnish a corresponding Schedule K-1 (Form 1065) to each of its partners.

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The relief provided by Rev Proc. 2019-32 only applies to partnerships satisfying certain requirements as set forth in the revenue procedure—specifically that for the applicable tax year:

  • The partnership has not elected the application of section 6221(b)
  • The partnership has timely filed Form 1065
  • The partnership has timely furnished all Schedules K-1 required to be furnished (without regard to the extensions of time provided by this revenue procedure)

Rev. Proc. 2019-32 [PDF 22 KB] acknowledges challenges for partnerships with tax years beginning in 2018, for which the centralized partnership audit regime was mandatory and the first tax years for which restrictions on amending Schedules K-1 under section 6031(b) were effective. To take advantage of the relief provided by Rev. Proc. 2019-32, partnerships are directed to file a superseding Form 1065 and furnish corresponding Schedules K-1 in the same manner as the original return and Schedules K-1 and write on the top of the superseding Form 1065 “SUPERSEDING FORM 1065 PURSUANT TO REVENUE PROCEDURE 2019-32.”

The filing and furnishing extensions provided in Rev. Proc. 2019-32 apply only to partnership tax years that ended prior to the issuance of this revenue procedure and for which the extended due date for such partnership tax year is after July 25, 2019.

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