IRS postpones business tax deadlines for Zuni and Guam disaster areas

The two announcements apply Internal Revenue Code section 7508A, under which Treasury can disregard a specified period when determining whether affected taxpayers have met tax deadlines. Treasury Regulation 301.7508A-1 defines affected taxpayers, covered areas and the acts that IRS guidance may postpone. These are specific IRS determinations, not a general extension for every group company.^[1][2][3][4]

Different start dates, one February deadline

NM-2026-03 covers qualifying original or extended deadlines falling on or after 16 July 2026 and before 4 February 2027 for the Pueblo of Zuni in New Mexico. GU-2026-01 starts its corresponding period on 4 July 2026 for Guam. Both postpone covered returns and payments to 4 February. The July incident dates begin the relief periods; the new official tax announcements were issued in October.^[1][2]

Covered obligations include corporate, partnership and S corporation returns, estimated income-tax instalments, and specified employment and excise returns. Both announcements cover relevant quarterly payroll and excise returns normally due on 31 July and 2 November 2026 and 1 February 2027. This brief concerns the federal relief announced by the IRS, not separate local-return arrangements in Guam.^[1][2]

Records can establish eligibility outside the area

Eligibility includes businesses with their principal place of business in the covered area, but also taxpayers elsewhere whose records needed to meet a covered deadline are located there. IRS identification is automatic for locally identified taxpayers; affected taxpayers outside the area must request relief. A multinational group should assess the entity and record location, rather than apply one extension across all subsidiaries.^[1][2][4]

Returns and deposits require different treatment. The announcements exclude employment and excise deposits from the general postponement. Their separate penalty abatements concern deposits already due during July: Zuni deposits due from 16 July until before 31 July must have been made by 31 July; Guam deposits due from 4 July until before 20 July must have been made by 20 July. These are retrospective conditions, not new February deposit deadlines.^[1][2][4]

Listed standalone information returns, including Forms 1042-S and the 1099 series, are generally excluded unless a specifically listed act qualifies. Required return attachments are different: Revenue Procedure 2018-58 section 4.03 explains that postponing a return also postpones its required attachments, expressly illustrating Form 5471. Tax teams should therefore map each return, attachment, payment and deposit separately.^[1][2][5]