Taxpreparer filing deadlines: managing disaster relief

What to take away

How an IRS disaster postponement actually reaches your client

The President signs a major disaster declaration. The IRS then postpones filing and payment deadlines for taxpayers inside the covered area. The relief is automatic, and it applies to the taxpayer, not to the preparer.

The legal authority is IRC § 7508A, which permits the IRS to postpone certain deadlines for taxpayers affected by a federally declared disaster. Rev. Proc. 2018-58 describes the acts covered by disaster postponements; the event-specific IRS notice identifies the locations, acts and dates that apply.

Each postponement gets its own news release. That release lists the covered counties or parishes, the returns and payments it covers, and the new due date. The Tax Relief in Disaster Situations page collects the current notices, and the IRS updates it as declarations arrive.

Geography decides who qualifies. A client whose home, business or tax records sit in a covered county qualifies. A client two counties away does not, even if the storm knocked out their power.

Many postponements provide about 60 days of relief, but there is no single end date for every disaster or every covered act. IRC § 7508A authorizes the postponement, and the event-specific IRS notice states the dates and acts covered; use that notice rather than treating 60 days as a guaranteed extension.

If the postponement reaches past the original due date, the return is not late and no failure to file or failure to pay penalty accrues for the covered period. Interest still runs on an unpaid balance from the original due date.

Subscribe to the IRS newsroom hub for disaster relief releases instead of waiting for a client to call. That one habit catches most postponements before they matter.

Hurricane season: what moves, and when

Hurricane postponements arrive in clusters. A storm makes landfall, a declaration follows within days, and the IRS postpones deadlines for the covered counties. Florida, Texas, Georgia and the Carolinas carry most of the volume.

The Atlantic season runs June 1 to November 30. That window overlaps the October 15 extended return deadline and the September and January estimated payment dates, so one early-October storm can move a whole batch of extended returns at once.

The NOAA Atlantic hurricane season prediction gives you a planning baseline, not a forecast for any single storm. NOAA maintained its outlook for a below-normal season, which means prepare for the usual burst without assuming a quiet year.

Inland flooding reaches counties far from the coast, and the declaration follows the damage rather than the storm track. Check the covered area in the notice, not the map on the evening news.

Your own office is in scope too. A firm inside the covered area gets the same postponement for its own filings, and displaced staff may be gone for weeks. Build the plan around people first, then documents.

Keep a standing list of clients in coastal counties. When a declaration lands, match it against that list. The list is the fastest way to keep tax preparation jobs on time when a storm hits mid-season.

Wildfire postponements come county by county

Wildfire relief is more scattered than hurricane relief. Fires burn in California, Arizona, Washington, Oregon and Colorado, and each declaration covers a specific set of counties. Two fires in one state can produce two different notices with two different dates.

California carries the largest volume. The California Franchise Tax Board often conforms to the federal postponement for state returns, so one declaration can move both dates for the same client. Confirm the state action separately, because conformity is common but not universal.

Arizona and Washington follow the same pattern at smaller scale. A single county declaration can cover three or four clients, and those are the ones a practice misses when it tracks only the big fires.

Smoke and evacuation disrupt records, not just buildings. A client who evacuated without last year's return or the closing documents needs the extra time for a reason the notice already covers.

Wildfire season now stretches into the fall in several states, close to the October 15 extended deadline. A fire in early October can move a group of extended returns days before they were due.

State authorities publish their own relief pages. The California Franchise Tax Board and the New York State Department of Taxation and Finance both issue postponements tied to federal declarations, and each sets its own covered returns. Track the state notice beside the federal one.

Running the declaration through the office

A moved deadline is a scheduling event. The return still gets prepared, reviewed and filed; only the date changes. The job is to absorb that change without pushing the rest of the season out of shape.

Start with the client list. Match the covered counties against your book and flag every affected file. Then decide, client by client, whether to file on the original schedule or use the postponement. A client waiting on a refund usually wants to file anyway.

Rebuild the calendar around the new date. Move affected returns to the back of the queue and fill the freed slots with clients who are not covered. For one client the postponement is breathing room; for the practice it is a scheduling problem.

Steps to run when a declaration lands:

An operations and workflow guide earns its keep here, because the same six steps repeat every season. Write them once and the next declaration becomes execution rather than a scramble.

Staffing is the hard part. A postponement adds no preparers, and returns still need review to Circular 230 standards. If the practice is already at capacity, the extra time goes to the returns that were going to be late anyway.

Cash flow moves with the date. Postponed clients pay later, so your own receipts shift in the months when a large batch of returns moves.

SBA and FEMA: separate assistance from tax relief

Clients in a disaster area ask about money before they ask about dates. Two programs come up most, and a preparer should know what each one is and where to send the client.

The Small Business Administration makes low-interest relief loans to businesses, homeowners and renters in declared areas. The loans cover physical damage and, for businesses, economic injury. Rates sit below market and terms run long.

FEMA assistance covers individuals and households for needs insurance does not reach. It is a grant, not a loan, and it does not have to be repaid. Applications run through the agency's Get Assistance After a Disaster page.

Neither program changes the return, but both touch it. A client who receives a grant may have a reporting question. A client who takes an SBA loan has a debt, not income, so the loan itself is not taxable. Route the reporting question to a licensed CPA or EA.

Keep the two sets of dates apart in every conversation. The tax deadline is the IRS notice. The assistance deadline belongs to the agency. Write both down when you talk to the client.

For a practice with many affected clients, a one-page handout beats repeating the same explanation. It should name the two programs, the two application routes, and the fact that the tax postponement extends neither one.

What goes in the client file

Documentation protects the client and the practice. If the IRS later questions a late filing, the notice plus the client's location in the covered area is the defense. Without both, the penalty argument is weak.

Five items go in the file: the notice number or a copy of the release, the covered location that applies, the original due date, the postponed due date, and the date the client was told.

The client's address is the key fact. The file should show that the residence, business or records sat in the covered area on the declaration date. A copy of the notice's location list does that.

Record the client's choice. A client who files on the original date despite the postponement has made a decision, and so has a client who uses the full window.

A daily operating checklist keeps this from slipping. Add a disaster postponement line to the checklist you already run, and the documentation happens alongside everything else.

If a return is filed after the original date and before the postponed date, note the authority in the file. One line with the notice reference satisfies most reviews.

Telling clients about a moved date without creating confusion

A deadline change is easy to explain badly. The client hears "extension," stops listening, and assumes the state return and the estimated payment moved too.

Say what moved and what did not. The federal return moved to a specific date. The state return may or may not have moved. The next estimated payment may or may not be covered. Three sentences, one message.

Put the new date in writing. A phone call is forgettable; an email is not. Send it once, and do not send a second version with a different date unless the IRS issues a new notice.

Avoid the word extension on its own. The IRS calls these postponements. An extension is something the taxpayer requests; a postponement is something the IRS grants. Use the agency's term.

Expect the question about filing early. Ask which the client prefers and record the answer. Keep one source of truth for dates, whether that is a shared calendar or a client management field, so two staff members never tell one client two different things.

A complaint handling process covers the rare case where a client believes a deadline was missed. The file note, the notice and the written message are the whole answer.

Review the season after it ends. Which declarations touched the book, how many clients were affected, what you would do differently. Those numbers feed the figures you measure every month, not just at year end.

Common questions

Does the IRS automatically extend the deadline after a federally declared disaster?

Yes. The IRS postpones filing and payment deadlines for taxpayers in the covered area without any request from the taxpayer or the preparer. No Form 4868 is needed for the postponement itself.

How do I know which counties are covered?

Each IRS disaster release lists the covered locations and the new due date. The disaster relief page collects the current notices, and the IRS newsroom carries every release as it is issued.

Does a state deadline move when the federal one does?

Often, but not always. California and New York are among the states that conform to federal disaster postponements, and each sets its own covered returns. Check the state tax authority notice for every affected client.

Do SBA and FEMA deadlines move with the tax deadline?

No. SBA disaster assistance and FEMA assistance run on their own application windows. A client who qualifies applies through each agency separately, and the tax postponement extends neither one.