The 2025-36 Internal Revenue Bulletin (IRB) provided critical deadline extensions for taxpayers affected by major federally declared disasters occurring in mid-to-late 2025. Specifically, it codified relief that postponed various filing and payment deadlines—originally falling between August and December 2025—to early 2026, including individual income tax returns, certain corporate filings, and quarterly estimated tax payments.
The Role of Internal Revenue Bulletin 2025-36
The Internal Revenue Bulletin (IRB) is the authoritative vehicle of the Commissioner of Internal Revenue for announcing official rulings and procedures of the IRS and for publishing Treasury Decisions, Executive Orders, Tax Conventions, legislation, Court Decisions, and other items of general interest. Published on September 2, 2025, Bulletin 2025-36 serves as a permanent record of administrative relief measures.
For tax professionals and taxpayers, IRB 2025-36 is significant because it consolidated several "Notices" and "Announcements" regarding tax relief that were issued sporadically in the preceding weeks. In the context of 2026, this bulletin remains the primary legal reference for verifying why certain 2025 tax obligations were permitted to be fulfilled in the current calendar year without incurring late-filing or late-payment penalties.
The bulletin primarily addresses the application of Internal Revenue Code Section 7508A, which grants the IRS the authority to postpone deadlines for taxpayers affected by federally declared disasters. By the time this bulletin was published, several regions had experienced significant climate-related disruptions, necessitating a broad-based administrative response to ensure that taxpayers were not unfairly penalized for circumstances beyond their control.
Key Deadline Extensions and Affected Taxpayers
The extensions outlined in IRB 2025-36 were not universal; they applied specifically to "affected taxpayers" as defined by the IRS. This definition generally includes individuals whose primary residence is located in a disaster area, businesses whose principal place of business is in a disaster area, and relief workers assisting in those regions.
Individual and Corporate Income Tax Returns
One of the most impactful provisions of the 2025-36 bulletin was the postponement of filing deadlines for taxpayers who had previously requested a valid six-month extension for their 2024 returns. While the standard extension would have expired in October 2025, IRB 2025-36 pushed these deadlines into February 2026 for those in qualified zones. This allowed individuals and businesses to focus on recovery rather than complex tax accounting during the immediate aftermath of the disasters.
Quarterly Estimated Tax Payments
Taxpayers who were required to make quarterly estimated tax payments also received significant relief. Payments originally due in September 2025 and January 2026 were consolidated and postponed. Under the guidance of IRB 2025-36, these payments could be made concurrently with the final 2025 return in early 2026 without the accrual of underpayment penalties, provided the taxpayer met the geographic eligibility requirements.
Payroll and Excise Tax Deposits
While the bulletin provided extensive relief for filing returns, it offered more nuanced rules for payroll and excise tax deposits. Typically, the IRS provides a shorter window of relief for these deposits to ensure that trust fund taxes are still collected. IRB 2025-36 generally abated penalties for failure to make timely deposits for a specific 15-day window following the disaster onset, provided the deposits were made by a specific late-2025 date.
Disaster Relief Provisions Under Section 7508A
The technical backbone of the 2025-36 extension is Section 7508A of the Internal Revenue Code. This section allows the Secretary of the Treasury to specify a period of up to one year that may be disregarded in determining whether tax-related acts were performed within the time prescribed by law.
When a disaster occurs, the Federal Emergency Management Agency (FEMA) issues a declaration. Once a "Major Disaster" or "Emergency" declaration is made, the IRS evaluates the severity and typically mirrors the FEMA disaster area for tax relief purposes. IRB 2025-36 codified these areas as of September 2025.
Automatic vs. Manual Relief
In most cases, the relief provided in IRB 2025-36 was automatic. The IRS identifies taxpayers located in the covered disaster area based on the address of record on their last filed return. Consequently, affected taxpayers did not need to contact the IRS to apply for the extension. However, if an affected taxpayer received a late-filing or late-payment penalty notice from the IRS, they were instructed to call the number on the notice to have the penalty abated in accordance with the bulletin’s guidelines.
Relief for Taxpayers Outside the Disaster Area
A critical but often overlooked detail in IRB 2025-36 is the relief for taxpayers who live outside the disaster area but whose records necessary to meet a deadline are located within the disaster area. This also applied to taxpayers whose tax practitioner was located in the affected region. These individuals were required to contact the IRS specifically to identify themselves as "affected" to receive the extension benefits.
Administrative and Information Return Postponements
Beyond standard income tax returns, IRB 2025-36 addressed a variety of administrative and information returns. These filings are often as critical as tax returns because they trigger significant penalties for non-compliance.
- Form 5500 Series: Employee benefit plan returns that were due during the postponement period were granted extensions. This was vital for plan administrators who may have lost access to payroll data or physical offices.
- Tax-Exempt Organizations: Organizations filing Form 990-series returns received identical postponements. This ensured that charities operating on the front lines of disaster relief were not bogged down by administrative filing requirements during their peak operational demand.
- Like-Kind Exchanges (Section 1031): The bulletin provided specific guidance for taxpayers involved in Section 1031 like-kind exchanges. If a taxpayer had started an exchange and the 45-day identification period or the 180-day exchange period fell within the disaster window, IRB 2025-36 allowed for a postponement of those deadlines, preventing the accidental triggering of capital gains taxes due to disaster-related delays.
Comparison of Original vs. Extended Deadlines
The following table summarizes the typical shifts in deadlines as codified in IRB 2025-36 for the most common tax obligations.
| Tax Obligation Type | Original 2025 Due Date | Extended 2026 Due Date |
|---|---|---|
| Individual Income Tax (with 2024 Extension) | October 15, 2025 | February 3, 2026 |
| Quarterly Estimated Tax (Q3) | September 15, 2025 | February 3, 2026 |
| Quarterly Estimated Tax (Q4) | January 15, 2026 | February 3, 2026 |
| Calendar-Year Corporate Returns (with Extension) | October 15, 2025 | February 3, 2026 |
| Quarterly Payroll/Excise Tax Returns | October 31, 2025 | February 3, 2026 |
| Form 5500 (Employee Benefit Plan) | Varies (Aug–Dec 2025) | February 3, 2026 |
Note: Dates may vary slightly based on the specific disaster declaration; taxpayers should verify their specific county on the IRS Around the Nation page.
Eligibility and Verification Procedures
As we navigate the 2026 filing season, verifying eligibility for the 2025-36 extensions is paramount for accurate record-keeping and audit protection. Taxpayers who utilized these extensions should ensure their 2025 tax records contain documentation justifying the delay.
Proving "Affected" Status
The IRS uses the ZIP code of the taxpayer’s address of record. If you moved into a disaster area after filing your 2024 return but before the 2025 deadlines, the IRS might not have automatically flagged your account for relief. In 2026, if you are reconciling these payments, you may need to provide a utility bill or lease agreement from the disaster period to demonstrate residency in the affected zone.
Impact on Interest and Penalties
Under the 2025-36 extension, both penalties and interest were waived for the duration of the postponement period. However, it is important to understand that interest resumes as soon as the extended deadline (e.g., February 3, 2026) passes. Taxpayers who failed to meet the new February deadline will find that interest is backdated, often to the original October or September 2025 due dates, creating a significant financial burden.
Common Pitfalls and Compliance Strategies
Despite the relief offered by IRB 2025-36, many taxpayers encountered difficulties. One common mistake was assuming that the extension applied to all types of taxes. For example, information returns like Form 1099 or Form W-2 generally have different relief structures than Form 1040.
Another pitfall involves "Notice of Deficiency" timelines. While IRB 2025-36 postponed the deadline to file a petition with the Tax Court, it did not always extend the time for other types of legal responses unless specifically stated. Taxpayers should consult with a qualified tax professional to ensure that "statutes of limitations" for claiming refunds were not inadvertently missed, as the rules for extending the time to file a return are different from the rules for extending the time to claim a credit or refund.
Strategy for 2026 Filing
For those currently preparing their final 2025 returns in 2026:
- Mark the Return: Ensure the disaster designation is clearly noted if filing via paper, though most e-file software will handle this based on the ZIP code.
- Reconcile Payments: Carefully track the "postponed" estimated payments made in early 2026 to ensure they are credited to the 2025 tax year rather than the 2026 tax year.
- Documentation: Maintain a digital copy of IRB 2025-36 and the specific FEMA declaration for your county in your permanent tax file.
Frequently Asked Questions
Does IRB 2025-36 apply to state tax deadlines?
Not necessarily. While many states align their disaster relief deadlines with the IRS, they are not required to do so. Taxpayers must check with their specific state department of revenue (e.g., California Franchise Tax Board or New York Department of Taxation and Finance) to confirm if state-level extensions mirror the federal ones provided in IRB 2025-36.
What should I do if I lived in a disaster area but received a penalty notice?
If you lived in an area covered by the 2025-36 bulletin and received a notice for the period covered by the extension, do not ignore it. Call the number on the top right corner of the notice. Explain that you are an affected taxpayer in a federally declared disaster area. The IRS agent should be able to see the disaster indicator on your account and abate the penalty immediately.
Are there any extensions for retirement account contributions?
Yes, IRB 2025-36 typically extends the deadline for making 2024 or 2025 contributions to IRAs and other retirement accounts if the deadline for filing the return was postponed. If your filing deadline was moved to February 2026, you generally had until that date to fund your IRA for the preceding tax year.
How do I find out if my specific county is covered?
The IRS maintains a dedicated Disaster Relief page that lists every state and county eligible for relief. You should look for the specific disaster name (e.g., "Hurricane X" or "Wildfire Y") that occurred in late 2025 and check if your county is listed as a "Designated Area."
Does the extension apply to the "Foreign Bank Account Report" (FBAR)?
Generally, the Financial Crimes Enforcement Network (FinCEN) aligns its FBAR (Report of Foreign Bank and Financial Accounts) deadlines with the IRS disaster relief, but this is published separately from the IRB. Taxpayers should verify through FinCEN’s official announcements to ensure their FBAR filing was also postponed.
Final Recommendation
If you were impacted by a disaster in 2025 and utilized the extensions provided in Internal Revenue Bulletin 2025-36, your primary objective in 2026 should be verification and reconciliation. Ensure that every payment made under the postponed deadline is accurately reflected in your IRS transcript. You can request a "Tax Account Transcript" for free from the IRS Get Transcript tool to confirm that no penalties have been erroneously assessed. If discrepancies exist, address them immediately through a practitioner or the IRS disaster hotline to maintain your compliance standing.
