What happens with the OZ deadlines now when the tax filing deadlines have been moved to July due to the coronavirus crises?
The OZ deadlines will move in tandem with the Form 1040 deadlines. Keep in mind that Form 8996 is still attached to either IRS Form 1120 or IRS Form 1065, and those due dates were not extended by the government; you would've had to file for those extensions yourself.
The deadline to invest does not change. It is still 180 days from the recognition of the capital gain. If the gain is from a pass-through entity(such as a partnership or S Corp), it is 180 days from the due date of the tax entity generating the capital gain. The 31 month rule for improving tangible property can be extended for delays required by a government entity for any reason including CV 19 mandated construction suspension.
I believe the biannual testing dates of a qualifying property will be unchanged but that the filing dates of entities may take full advantage of the filing and payment extensions.
The required forms 8996 and others, need to be included with the corresponding tax returns (1040, 1120, 1065). Therefore, their filing date is extended. Other due dates and deadlines (investment, 90% test, etc.) remain the same.
The testing dates would presumably be unchanged but the tax filing and payment dates would change based on the coronavirus tax relief extension and become due July 15.
This is a great question. There are a number of areas where deadlines/timelines in the Regs might be softened due to the National Emergency that was declared. Stay tuned!
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