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Taxes & deadlines

Prepare the business history for a Form 1128 tax-year change

Gather filing history, ownership facts and monthly operating evidence before an adviser assesses a US business's proposed change of tax year.

By Institution3 minute readPublished View sources
In this guide

Establish the filing year the business actually uses

Before a US business asks to change its tax year, retrieve the last filed returns and identify their exact beginning and ending dates. Compare those periods with the ledger calendar and any prior approvals. A management report ending in September does not establish that September is the business's federal tax year.

Form 1128 has separate routes for automatic approval and a ruling request, with exceptions where the form is unnecessary. Give the adviser the entity's tax classification, formation history and requested year so the correct route can be assessed. This preparation concerns an existing business's filing period; it does not decide its eligibility to use a preferred calendar.

References: IRS: Instructions for Form 1128, tax-year changes

Build the history needed to assess the available procedure

Collect earlier year changes, classification elections, ownership changes and group membership dates. Include related entities and their tax years, plus any examination or dispute concerning the accounting period. Record missing documents explicitly. A predecessor's history can matter even when the current business uses a different name or accounting system.

Revenue Procedures 2006-45 and 2006-46 set different automatic-change conditions for corporate and specified pass-through applicants. Prior changes, related interests and other restrictions require review against the applicable procedure and subsequent modifications. Have the adviser document which conditions were tested, rather than inferring automatic eligibility from the form's availability.

Explain the operating reason for the proposed year in concrete terms: when sales peak, when inventory falls, or how the business cycle ends. Keep management's preference separate from the evidence used to establish any permitted tax year.

References: IRS: Instructions for Form 1128, tax-year changes; IRS: Revenue Procedures 2006-45 and 2006-46, annual accounting periods

Prepare monthly evidence without reshaping the numbers

For a natural-business-year review under the specified gross-receipts test, the Form 1128 instructions call for the most recent 47 months of receipts, including relevant predecessor data. Obtain the underlying monthly figures using the tax accounting method required by the test. Preserve the source reports and reconciliation to filed returns.

Consider a hypothetical retailer seeking a January year-end because holiday sales continue through returns season. A narrative about busy December trading does not establish the test. Supply the complete month sequence, identify returns and adjustments consistently, and let the adviser evaluate the requested year against alternatives.

If an acquisition, shutdown or system migration interrupts the series, explain the gap and provide available records. Do not replace absent months with forecasts and present them as actual receipts. Label any reconstructed figures and retain the method and supporting documents.

References: IRS: Instructions for Form 1128, tax-year changes

Plan the transition around the reviewed tax periods

A change in accounting period can require a short-period return. Draw the current year, proposed transition period and first full new year on a dated schedule. For illustration, a proposed change from December to June could involve a January-through-June short period, subject to the adviser's confirmation of the permissible change.

Assign responsibility for closing the transition books, preparing the application, meeting the applicable deadline and retaining filing evidence. Automatic and ruling procedures have different timing rules. Preserve the reviewed route and any IRS response with the final return periods, then update the filing calendar and accounting settings from that documented conclusion.

References: IRS: Instructions for Form 1128, tax-year changes; IRS: Tax years and short tax periods

Sources

Requirements and product details can change. Check the linked guidance for the facts that apply to your situation.

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General information, not personalized accounting, tax, legal, or investment advice. Have the appropriate qualified professional review decisions that depend on your circumstances.