When is an eFiled return considered filed?

[Rich Carreiro]

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?

Thanks!

 

[Alan]

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?

Thanks!

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.

 

[Rich Carreiro]

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.

Thank you for the information!

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.

That's fine, then -- I efile all the returns and handle all
the rejects (if any) and would have no problem getting the
acks and rejects on the 16th.

 

[Arthur Kamlet]

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.

This is true for files tranmitted to the IRS.

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.

 

[Harlan Lunsford]

This is true for files tranmitted to the IRS.

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.

Last I heard IRS will "accept" returns up till the 20th providing they
were transmitted before midnight 4/15 to the intermediary.

ChEAr$,
Harlan Lunsford, EA n LA

 

[MTW]

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?

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.

MTW

 

[Alan]

This is true for files tranmitted to the IRS.

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.

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.

 

[Rich Carreiro]

See Reg 301.7502-1(d)(1) which includes the following:
[snip]

Assuming that your software company issues an "electronic postmark," I
believe that is the date that applies,

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

 

[Alan]

See Reg 301.7502-1(d)(1) which includes the following:
[snip]

Assuming that your software company issues an "electronic postmark," I
believe that is the date that applies,

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.

 

[MTW]

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

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).

MTW