Two questions. Does the IRC S 6081 automatic extension apply to where a domestic USA corporation transacts 100% of its business in the USA but keeps 100% of its records and books of account outside the United States (in Canada, where all mgmt and ownesr are also located)? The essence of this question is how to interpret the word “and†in the citation further below.
Second question is whether the 6081 automatic extension also extends the payment due date (I understand that extensions requiring filing on forms do not exetend the payment due date but I have seen different conclusions put forth for the 6081 extensions).
“An extension of time for filing returns of income and for paying any tax shown on the return is hereby granted to and including the fifteenth day of the sixth month following the close of the taxable year in the case of Domestic corporations which transact their business and keep their records and books of account outside the United States and Puerto Ricoâ€. Reg. § 1.6081-5(a)(2).
6081 automatic extension
Moderator: Mark T Serbinski CA CPA