Hypothetical : 2022 retroactive CB plan to be set up. Potential sponsor already filed 2022 corp return but will amend for reasons other than this but wants to include if possible. In CA we have an automatic extension for all counties due to weather except 2 (client located in county under extension). We have time to file 5558 still. Rev Rule 66-144; 1966-1 C.B 91 seems to support this:
"Section 404(a)(6) of the Code provides that a contribution for a taxable year made by a taxpayer reporting on the accrual basis shall be deemed to be made within such taxable year if paid within the time prescribed for filing its return plus any extension of time in which to file. Therefore, a contribution paid within an extended filing period is deemed to have been made during the taxable year. Thus, a contribution made during such extended period, as provided for under section 6081(b) of the Code, is deemed to have been made during the taxable year regardless of when the return is filed."
Guess the question is does the filing of the 2022 corp return trump the automatic extension granted for CA thru 10/16/23?
Thanks for any input.