I'm the ERO of our AARP TaxAide site and we e-file most returns. This year, our last session of the season is on April 15 itself.
So I'd really love to know when an e-filed return is considered filed.
Is it when (in this case) I send it to UTS? Is it when UTS sends it to the IRS? Is it when the IRS accepts it? What happens if there are rejects? Should I efile extensions for all our April 15 clients so that if the ultimately filed return is rejected it won't be late filed?
A return is considered filed when it is accepted. Returns transmitted on April 15 will be considered timely filed unless it is rejected. A re-transmitted rejected return is considered timely filed as long as it is accepted no later than April 20.
If you are going to e-file on 4/15, you need to have a plan in place for someone to obtain the acks & rejects on 4/16/09; get the rejects fixed and retransmitted; and once again obtain the acks and hopefully no further rejects. If you can't put this plan in place, you should not e-file any returns on 4/15.
For 4/15 clients with a balance due, we give them the option to go with e-file; go with paper or go with an extension and pay with the extension. Either way, they are informed that they have to pay by midnight 4/15 to avoid a late payment penalty. Clients with a refund typically opt for e-filing.
We have at least two EROs who come in on 4/16 to close out all outstanding transmitted returns.
When I was in CA, we had a small site and had no capability on
4/16 to follow up. We only prepared paper returns on 4/15.
If your software sends the files to an aggregator who batches and resends them to the IRS a few hours later, even an hour later, you might miss the April 15th deadline.
Either last year or the year before (or three years ago??) one of the big software providers got into a logjam on April 15th and missed getting them filed on April 15th. I think they pleaded with the IRS to accept late-filed returns, and here I'm hazy, but I think the IRS agreed for the public good.
In any event, if your software transmits via an agregator, or wants to anticipate a logjam which will prevent them from sending them all to the IRS on time, they will set an early-in-the-day deadline for sending efiles, if they are to be guaranteed.
For example, the software company sending directly to the IRS might set a 3pm deadline, while one sending via an aggregator might set a noontime deadline.
That doesn't mean a file sent at 8pm won't make it into the IRS and be accepted before midnight, but the software company can say We told you so if it doesn't get there on time.
See Reg 301.7502-1(d)(1) which includes the following:
"(1) In general. A document filed electronically with an electronic return transmitter (as defined in paragraph (d)(3)(i) of this section and authorized pursuant to paragraph (d)(2) of this section) in the manner and time prescribed by the Commissioner is deemed to be filed on the date of the electronic postmark (as defined in paragraph (d)(3) (ii) of this section) given by the authorized electronic return transmitter. Thus, if the electronic postmark is timely, the document is considered filed timely although it is received by the agency, officer, or office after the last date, or the last day of the period, prescribed for filing such document."
Assuming that your software company issues an "electronic postmark," I believe that is the date that applies, corrected for your local time zone, even though the IRS doesn't actually received or accept the file until a later time.
AARP Taxaide sites use Taxwise and transmit to the electronic filing center at UTS. As long as the transmission is sent successfully on 4/15/09, it is timely e-filed.
So, does UTS/TaxWise issue such a "postmark"? Given what the MSRP of their software is I'd like to think so, but I know better than to assume anything when it comes to taxes :)
See my reply to ARt Kamlet's comment. After you transmit to UTS, it will tell you the transmission is successful and the e-files have been erased. At that point you have a timely filed e-file. At this point, all you need to be concerned about are rejects.
I would assume so, but I don't know for sure. With the program I'm most familiar with (TaxACT), their status system tracks TWO significant items. One is the date/time RECEIVED (this is the time they received the file from you, and it is presumably the "postmark"). The other is the STATUS (listed as either "accepted," "rejected" or "pending").
The acknowledgment that they send after your return has been accepted lists the date/time RECEIVED as the time of acceptance. So, in other words, the acceptance appears to be effective as of the time they first receive the file from you, even though the IRS may process it at a later time. This is essentially the same as the "mailbox rule" for a paper-filed return (it is deemed filed when mailed).
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