IRS may extend Form 1099-R filing time but not change deadline

Plain-English summary

Chief Counsel advised that the IRS may grant extensions for filing Form 1099-R but cannot change the filing deadline itself under the current rules. A filer may obtain an initial 30-day extension without stating a reason. A second 30-day extension may be available when the filer provides a reason on Form 8809.

Ruling snapshot

• Question: May the IRS change the Form 1099-R filing deadline?
• Outcome: Advice given, extensions are allowed but the deadline itself cannot be changed
• Key authorities: IRC §§ 6047 and 6071; Form 8809 procedures

Full text (IRS public release)

 ID:        CCA_2022051713365550                     [Third Party Communication:

 UILC:      6071.02-00, 6047.00-00                   Date of Communication: Month DD, YYYY]

Number: 202346012
Release Date: 11/17/2023
From: ---------------------
Sent: Tuesday, May 17, 2022 1:36:56 PM
To: ---------------
Cc: ----------------------
Bcc:
Subject: RE: Your help is appreciated - Form owner of the 1099-R for discussion related to possible
changes to the filing deadlines


That’s correct. Of course, the Service can grant an extension. Under the current rules,
for example, one could obtain a 30-day extension for filing the 1099-R without providing
a reason, and another 30 day extension with reason provided via Form 8809. But the
deadline itself could not be changed.

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