C Corp Contribution deadline

The IRS modified tax return deadines for 2016.  What we are questioning is whether the deadline for making a contribution for a calendar year plan is still September 15th, or (as the form 7004 instructions suggest) has the deadline now changed to October 15th. 

We've taken the position that it is October 15th (to be deductible for the preceding year).  Our research indicates that the reference to the destructibility of a contributions is "6 months" after the tax return due date.  Nothing we have found hard codes the date to September 15th.  The "CPA's" we've talked to agree.  The same is true for entities that are taxed as partnership - which now have a September 15th deadline....

Where does it say 6 months? I guess I missed that. Under both 404(a)(6) and 1.401(a)-1(c), it refers to the extended filing date. For a calendar year C-corp, the extended filing date is, I believe, September 15th until tax years beginning in 2026.

Can you elaborate on the "6 month" piece?

6 months is the length of a valid tax return extension. Regardless, if you're dealing with a calendar year DB plan, remember that your ERISA minimum required contribution is due 9/15, irrespective of tax return due dates, extensions, or which day of the week 9/15 falls upon.

Pardon my being obtuse, but that still doesn't answer the question. Under the (changed) law, the tax return due date for a calendar year C-corp is April 15th.  And unless I'm incorrect, from 2016 through 2025, the extended tax filing date for a CALENDAR year C-corp is September 15th. It doesn't become October 15th until 2026. Do you have a citation that says otherwise? In other words, I don't think a 6 month extension is valid in the specific situation in the OP.

My understanding is that for C-corps with fiscal years ending OTHER THAN 12/31 or 6/30, then they are due on the 15th day of the 4th month, and a 6-month extension is indeed available from that date.

P.S. - yes, I do agree about minimum funding deadlines.

Ah, my apologies - I do see it now. based upon the IRS 7004 instructions, which are contrary to the law, but the IRS exercised its authority to do otherwise. Good to know - glad this post came up!

https://www.aicpa.org/InterestAreas/Tax/Resources/Compliance/DownloadableDocuments/Due-Dates-Summary-Chart.pdf

here's a great summary chart from AICPA

Very nice chart. Thanks!