Multistate Tax Alert: District of Columbia Office of Tax and Revenue Extends Combined Report Due Date
On September 14, 2011, the Fiscal Year 2012 Budget Support Act of 2011 required combined reporting in the District of Columbia (“District”) for tax years beginning after December 31, 2010. Under this new combined filing regime, a taxpayer corporation that is a member of a combined group and that must report income derived from the activities of that group in a combined report ("combined reporting filer") was originally required to file that report on September 17, 2012.
On September 7, 2012, the District’s Office of Tax and Revenue (“OTR”) issued Notice 2012-07, stating that combined reporting filers “may receive an automatic extension [to file the combined report] until October 15, 2012, in lieu of the six-month extension allowed … under DC Official Code § 47-1805.03(b).” Taxpayers should note that the Notice appears to apply only to combined reporting filers. Therefore, taxpayers not filing as part of a combined report (e.g., corporations filing a separate return) would presumably still be required to file by September 17, 2012.