Tax Day

In the United States, Tax Day is the day on which individual income tax returns are due to be submitted to the federal government.[1] Since 1955, Tax Day has typically fallen on or just after April 15. Tax Day was first introduced in 1913, when the Sixteenth Amendment was ratified.

Tax Day
Observed byUnited States
TypeNational
SignificanceDue date for federal individual income tax returns
Date
  • April 15 (Monday through Thursday)
  • April 17 (Tuesday; April 15 is Sunday)
  • April 18 (Monday or Tuesday; April 15 is Friday or Saturday)
2023 dateApril 18 (Tuesday)
2024 dateApril 15 (Monday)
2025 dateApril 15 (Tuesday)

The date is delayed if it conflicts with a weekend or public holiday such as Emancipation Day. Natural disasters or public health emergencies, most recently the COVID-19 pandemic, also delay Tax Day when they prevent filing taxes on time, and state income agencies often delay their own submission deadlines to remain in common with that of the federal government. The federal government may set a different deadline for certain states, as it did when Patriots' Day conflicted.

History

Federal income tax was briefly introduced with the Revenue Act of 1861 to help fund the Civil War, and subsequently repealed, re-adopted, and held unconstitutional. The early taxes were based on assessments, not voluntary tax returns. Tax payment dates varied by act.[2]

The case of Pollock v. Farmers' Loan & Trust Co. challenged the constitutionality of the Wilson–Gorman Tariff Act of 1894, which taxed incomes over $4,000 at the rate of two percent. The case was decided by the United States Supreme Court in 1895. The Supreme Court decided that the Act's unapportioned income taxes on interest, dividends, and rents were effectively direct taxes. The Act was therefore unconstitutional because it violated the Constitution's rule that direct taxes be apportioned among the states.[3] In 1913, eighteen years later, the Sixteenth Amendment to the United States Constitution was ratified. This Amendment gave the United States Congress the legal authority to tax all incomes without regard to the apportionment requirement.[4]

The filing deadline for individuals was March 1 in 1913 (the first year of a federal income tax), and was changed to March 15 in 1918 and again to April 15 in 1955.[5] Today, the deadline remains April 15, unless it conflicts with a weekend or holiday.

Alignment with state and District of Columbia holidays and changes in date

Tax Day occasionally falls on Patriots' Day, a civic holiday in the Commonwealth of Massachusetts and state of Maine, or the preceding weekend. When this occurred for some time, the federal tax deadline was extended by a day for the residents of Maine, Maryland, Massachusetts, New Hampshire, New York, Vermont, and the District of Columbia, because the IRS processing center for these areas was located in Andover, Massachusetts, and the unionized IRS employees got the day off.[6] In 2011 and 2015, Tax Day fell on Patriots' Day. However, federal filings were directed to Hartford, Connecticut, Charlotte, North Carolina, and Kansas City, Missouri,[7] and there was no further extension for Maine, Massachusetts or other surrounding states' residents.[8][9][10] In 2019 and 2021, when Patriots Day was again observed on the tax filing deadline, residents of Maine and Massachusetts were given extra time to file as post offices in those states would be closed on normal deadline.[11][12][13]

Emancipation Day is celebrated in Washington, D.C., on April 16 or the nearest weekday. Under the federal Tax Code holidays observed in the District of Columbia have an impact nationwide.[14] If April 15 falls on a Friday then Emancipation Day is observed in Washington, D.C., on April 15 (the nearest weekday to Saturday the 16th) and Tax Day becomes the following Monday, April 18.[15][16] When April 15 falls on a Saturday or Sunday then Emancipation Day is observed on the following Monday and tax returns are instead due on Tuesday.[17]

For both Emancipation Day and Patriots' Day, when April 15 falls on a Saturday or Sunday, tax returns are due the following Tuesday, April 18 or April 17 respectively.[18][19] This means that when the tax filing deadline is not moved for other political reasons, tax day for any particular year is always on April 15 (years when this day is a Monday through Thursday), Tuesday April 17 (years when April 15 is a Sunday) or Monday or Tuesday April 18 (years when April 15 is either a Friday or Saturday). For residents of Maine and Massachusetts, tax day may fall on April 19 if the 15th was Emancipation Day and the 18th is Patriots Day.[13]

In 2007 a powerful storm and flooding affected the East Coast, and certain states were granted additional time to file. In some cases, the deadline was extended to as late as June 25.[20][21]

In 2020, due to the economic effects of the coronavirus pandemic filing for returns was extended to July 15.[22][23] The tax deadline was again moved in 2021 due to tax code changes from the COVID-19 relief package from April 15 to May 17, 2021.[24]

See also

References
  1. Terrell, Ellen (December 2020) [February 2004]. "Income Tax Day". Library of Congress. Archived from the original on March 25, 2023. Retrieved April 12, 2023.
  2. See, for example, Revenue Act of 1861, section 50, Revenue Act of 1862 section 91.
  3. U.S. Constitution, Article I, Section 9.
  4. "Common Interpretation: The Sixteenth Amendment". National Constitution Center. Retrieved April 17, 2018.
  5. Sung, Jessica (April 15, 2002). "Why Is Tax Day April 15?". Fortune. Retrieved March 11, 2010.
  6. "Patriot's Day 2007 Gives Some Taxpayers Extra Tax Time, IR-2006-170". Internal Revenue Service. November 8, 2006. Retrieved March 27, 2013.
  7. "Massachusetts: Where to File Addresses for Individual Taxpayers". Internal Revenue Service. Retrieved March 27, 2013.
  8. Ohlemacher, Stephen (April 18, 2011). "Who's paying taxes? Half of us". Portland Press Herald. Associated Press. Why is the deadline today? (sidebar). Retrieved April 18, 2011. No reference to Patriots' Day and deadline pegged at "midnight tonight."
  9. "Tax Day 2011: Tax Deadlines for Tax Year 2010". eFile. Internal Revenue Service. n.d. Retrieved April 18, 2011. No reference to Patriots' Day and deadline pegged at April 18.
  10. "2015 Publication 509" (PDF). Internal Revenue Service. Department of the Treasury. November 6, 2014. Retrieved December 12, 2021. A statewide legal holiday delays a due date for filing a return only if the IRS office where you are required to file is located in that state. A statewide legal holiday does not delay a due date for making a federal tax deposit.
  11. Edelson, Harriet (January 8, 2019). "Here's What the Shutdown Means for Filing Your Taxes". aarp.org. AARP. Retrieved March 15, 2019. For most taxpayers, Monday, April 15, 2019, is the filing deadline to submit 2018 tax returns. Because of the Patriots' Day holiday on April 15 in Maine and Massachusetts taxpayers who live in those states have until April 17, 2019, to file their returns, the IRS said.
  12. "Patriots' Day Gives Certain Taxpayers Extra Day to File Return". accountingweb.com. AccountingWeb. February 14, 2002. Retrieved March 15, 2019. April 15 – known to most citizens as the day tax returns are due – is a state holiday in Maine and Massachusetts. The Patriots' Day holiday celebrates the battles that began our nation's fight for independence. The real Patriots' Day is April 19, but the day is officially celebrated in these two states on the nearest Monday, which this year is April 15...Residents of Massachusetts also file in Andover and are granted the tax holiday. Residents of Maine file in Philadelphia this year, but are granted the holiday because the Maine post offices will be closed on the 15th.
  13. "2022 Publication 509" (PDF). Internal Revenue Service. Department of the Treasury. October 21, 2021. Retrieved December 12, 2021. Individuals who live in Maine and Massachusetts have until April 19, 2022, to file their 2021 Form 1040 or Form 1040-SR because April 15, 2022, is Emancipation Day and April 18, 2022, is Patriots' Day.
  14. "26 U.S. Code § 7503 - Time for performance of acts where last day falls on Saturday, Sunday, or legal holiday". LII / Legal Information Institute. Retrieved April 15, 2023.
  15. Ellis, Blake. "Tax day extended to April 18". CNN Money. Retrieved December 29, 2013.
  16. "2016 Tax Season Opens Jan. 19 for Nation's Taxpayers". U.S. Internal Revenue Service. December 21, 2015. Retrieved April 7, 2016. The filing deadline to submit 2015 tax returns is Monday, April 18, 2016, rather than the traditional April 15 date. Washington, D.C., will celebrate Emancipation Day on that Friday, which pushes the deadline to the following Monday for most of the nation.
  17. Iszler, Madison (April 14, 2017). "April 15 is always Tax Day, right? Well, not this year. Here's why". News & Observer. Retrieved April 15, 2017.
  18. "Internal Revenue Bulletin: 2011-10". Internal Revenue Service. Retrieved December 29, 2013.
  19. Roos, Dave. "Why do Americans pay taxes on April 15?". How Stuff Works. Retrieved December 29, 2013.
  20. "IRS Gives Northeast Storms Victims Until April 26 to File Tax Returns". Internal Revenue Service. April 18, 2007. IR-2007-92. Archived from the original on April 16, 2014. Retrieved March 27, 2013.
  21. "IRS Grants Tax Relief for Certain Northeast Storm, Flooding Victims; Taxpayers Have Until June 25 to File Returns". Internal Revenue Service. April 26, 2007. Archived from the original on May 1, 2015. Retrieved March 27, 2013.
  22. Brian Faler (March 20, 2020). "Trump administration moves Tax Day to July 15". Politico. Retrieved March 20, 2020.
  23. "IRS extends more tax deadlines to cover individuals, trusts, estates corporations and others". Internal Revenue Service. April 9, 2020. Archived from the original on April 11, 2020. Retrieved April 19, 2023.
  24. "Tax Day for individuals extended to May 17: Treasury, IRS extend filing and payment deadline". IRS. March 17, 2021. Retrieved March 18, 2021.
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