IRS Changes Tax-Filing Requirements for Large Corporations and Partnerships

The Internal Revenue Service said Friday that it will be making changes to the filing requirements for corporate and partnership taxpayers with assets of between $10 million and $50 million in an effort to lighten the burden.

The changes pertain to the Schedule M-3 filing requirement for taxpayers with assets between $10 million to $50 million for Forms 1120, 1120-C, 1120-F, 1120S, 1065 and 1065-B.

These business taxpayers will be permitted to file Schedule M-1 in place of the Schedule M-3 Parts II and III. The changes will be effective for tax years ending on Dec. 31, 2014, and later.

However, the IRS added that no changes are currently planned to the Schedule M-3 requirements for Forms 1120-L or 1120-PC, nor for Form 1120 taxpayers filing as a mixed group.

The IRS said the reason for the changes is to reduce filing burden and to simplify reporting for these corporations and partnerships. The changes affect the filing requirements for Schedule M-3, “Net Income (Loss) Reconciliation for Corporations with Total Assets of $10 Million or More.”

Effective for tax years ending Dec. 31, 2014 and later, corporations and partnerships with at least $10 million but less than $50 million in total assets at tax year end will be permitted to file Schedule M-1 instead of Schedule M-3, Parts II and III. Schedule M-3, Part I, lines 1-12 will continue to be required for these taxpayers. Those taxpayers electing to file Schedule M-1 must report book income on Schedule M-1, line 1, equal to the book income amount reported on Schedule M-3, Part I, line 11. Corporations and partnerships with $10 million to $50 million in total assets may voluntarily file Schedule M-3 Parts II and III rather than Schedule M-1. This change applies to corporations and partnerships filing Forms 1120, 1120-C, 1120-F, 1120S, 1065 and 1065B.

Corporations and partnerships filing Forms 1120, 1120-C, 1120-F, 1120S, 1065 and 1065B with $10 million to $50 million in total assets will not be required to file Form 1120 Schedule B, Form 1065 Schedule C or Form 8916-A.

The IRS’s Large Business & International Division is continuing to consider changes to Schedule M-3 and to the requirements for the book-to-tax reconciliation for corporations with $10 million to $50 million in total assets filing Form 1120-L, 1120-PC, or filing as a mixed group including the requirement that mixed groups sub-consolidate and file Form 8916, the IRS noted. In addition, the IRS LB&I Division is considering changes to Schedule M-3 and to the requirements for the book-to-tax reconciliation for corporations and partnerships with $50 million or more in total assets.

Schedule M-1 detail is currently filed electronically as four attachments, one each to Schedule M-1 lines 4, 5, 7, and 8.  This will not change, according to the IRS.

Partnerships with less than $10 million in total assets that are currently required to file Schedule M-3 (adjusted total assets of $10 million or more, total receipts for $35 million or more, or a reportable entity partner also required to file Schedule M-3) will continue to file Schedule M-3, Part I and may elect to file Schedule M-1 in place of Schedule M-3, Parts II and III.  Partnerships with less than $10 million in assets will not be required to file Form 1065 Schedule C or Form 8916-A.

Corporations and partnerships with less than $10 million in total assets that are not otherwise required to file Schedule M-3 are currently allowed to voluntarily file Schedule M-3. These taxpayers can continue to voluntarily file Schedule M-3, according to the IRS, and they may elect to file Schedule M-3 Parts I, II, and III or to file Schedule M-3 Part I and to file Schedule M-1 in place of Schedule M-3 Parts II and III. Such corporations and partnerships will not be required to file Form 1120 Schedule B, Form 1065 Schedule C, or Form 8916-A.

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