Form 8809 Checklist for Tax Year 2019
Understanding Form 8809
Form 8809, Application for Extension of Time to File Information Returns, allows filers to request extensions for filing 2019 information returns, including W-2, W-2G, 1042-S, 1094-C, 1095, 1097, 1098, 1099, 3921, 3922, 5498, and 8027. The August 2019 revision established that Forms W-2 and 1099-MISC reporting nonemployee compensation in box 7 require paper submission with justification and cannot be filed through the online FIRE System for extension requests.
Eligibility and Extension Types
Automatic 30-Day Extension
Most information returns qualify for an automatic 30-day extension, without requiring completion of line 7 or a signature. This automatic extension applies to all forms except W-2 and 1099-MISC when reporting nonemployee compensation in box 7.
Non-Automatic Extension
Forms W-2 and 1099-MISC reporting nonemployee compensation in box 7 do not qualify for automatic extensions. These require paper filing, line 7 justification, and the filer's signature. Additionally, second 30-day extension requests for any form type also require these elements.
Filing Method and Deadlines
Paper Filing Deadlines
For W-2 and 1099-MISC reporting nonemployee compensation in box 7, submit Form 8809 on paper by January 31, 2020. For other eligible forms filed on paper, the deadline is February 28, 2020.
Electronic Filing Deadlines
Forms eligible for electronic filing through the FIRE System must be submitted by March 31, 2020. However, W-2 and 1099-MISC reporting nonemployee compensation in box 7 must be filed on paper by January 31, 2020, and cannot use the electronic system for extension requests.
Multiple Form Types
If requesting extensions for multiple form types with different due dates, file Form 8809 by the earliest applicable deadline or complete separate Form 8809 submissions for each form type to avoid confusion.
Step-by-Step Filing Instructions
Step 1: Verify Extension Eligibility
Determine whether your forms qualify for automatic or non-automatic extension. W-2 and 1099-MISC with nonemployee compensation in box 7 require non-automatic extension procedures. All other eligible forms may use automatic extension procedures without explanation.
Step 2: Choose Filing Method
Select either electronic filing through the FIRE System or paper filing. You must use paper filing for W-2 and 1099-MISC reporting nonemployee compensation in box 7. Use a separate Form 8809 for each filing method if requesting extensions for forms filed through different strategies.
Step 3: Complete Filer Information on Line 1
Enter your exact legal name and complete address as provided on your EIN application. The name and TIN must match exactly as originally submitted on Form SS-4, online EIN application, or the telephone EIN service. Do not abbreviate. If you submitted a name change to the IRS, use the current legal name. Include contact name, telephone number, and email address.
Step 4: Enter Your TIN on Line 2
Enter your nine-digit taxpayer identification number without hyphens or spaces. Use your EIN, QI-EIN, WP-EIN, WT-EIN, or SSN if not required to have an EIN. Ensure the number matches your official IRS records exactly.
Step 5: Select Filing Method on Line 3
Mark either “Electronic” for FIRE System filing or “Paper” for mail submission. If requesting an extension for W-2 or 1099-MISC reporting nonemployee compensation in box 7, you must mark “Paper.” Submit a separate Form 8809 for each filing method when requesting extensions for forms filed through different strategies.
Step 6: Enter Multiple Filers on Line 4
If requesting an extension for more than one payer or filer, enter the total number and attach a list containing names and TINs for all additional filers. Follow instructions for proper attachment procedures based on the filing method.
Step 7: Indicate Additional Extension Request on Line 5
Check line 5 only if you already received the automatic 30-day extension and now need a second 30-day extension. Do not check this box for first-time extension requests. If checked, you must complete line 7 and provide a signature.
Step 8: Check Applicable Forms on Line 6
Identify all 2019 information return forms that require an extension by checking the appropriate boxes. Do not enter the number of returns; only check the boxes. Available forms include W-2, 1099, 1098, 1097, 3921, 3922, W-2G, 1042-S, 5498 series, 1094-C, 1095 series, 8027, and 1099-MISC for reporting nonemployee compensation.
Step 9: Complete Line 7 When Required
Line 7 must be completed if requesting an extension for W-2, 1099-MISC reporting nonemployee compensation in box 7, or an additional 30-day extension beyond the initial automatic extension. Select at least one qualifying criterion: catastrophic event in a federally declared disaster area, fire or casualty or natural disaster, death or serious illness, or unavoidable absence of a responsible individual, first year of establishment, or failure to receive timely required payee statement data under section 31.6051-3(a)(1).
Step 10: Sign and Date the Form
Signature is required only for W-2 extensions, 1099-MISC reporting nonemployee compensation in box 7, or additional 30-day extension requests. The filer, transmitter, or person duly authorized to sign a return must sign. For automatic 30-day extensions via the FIRE System, excluding W-2 and 1099-MISC reporting of nonemployee compensation in box 7, no signature is needed.
Step 11: Submit by Appropriate Deadline
Mail paper Form 8809 to the Department of the Treasury, Internal Revenue Service Center, Ogden, UT 84201-0209, or submit electronically through the FIRE System by the applicable deadline. Ensure submission occurs by the original due date of the returns to obtain the extension.
Step 12: Retain Confirmation Records
Keep acknowledgement records from electronic submissions or mailing proof for paper submissions. Electronic filers receive automatic acknowledgement if the request is submitted by the due date. Paper filers should use certified mail or a private delivery service for proof of timely filing.
Form-Specific Requirements for Tax Year 2019
1099-MISC Reporting Nonemployee Compensation
For tax year 2019, nonemployee compensation is reported in box 7 of Form 1099-MISC. Extension requests for these forms must be submitted on paper, including justification on line 7 and the filer's signature, by January 31, 2020. Online FIRE System filing for extension requests is not available for 1099-MISC forms reporting nonemployee compensation in box 7.
Automatic Extension Restrictions
Forms W-2 and 1099-MISC reporting nonemployee compensation in box 7 have no automatic extension available for the tax year 2019. All extension requests require a paper submission with line 7 completion and signature. All other eligible forms may use an automatic 30-day extension through the FIRE System without explanation or signature.
Additional Extension Availability
A second 30-day extension, not exceeding 30 additional days beyond the first extension, is available only for forms other than W-2 and 1099-MISC reporting nonemployee compensation in box 7. Request this through paper submission with line 5 checked, line 7 criteria selected, and filer signature provided.
Recipient Statement Deadline
An approved Form 8809 extension delays only the IRS filing due date, not the deadline for furnishing 2019 statements to payees or recipients. You must still provide recipient copies by the required deadlines, regardless of whether you have obtained approval for a filing extension. The extension of time to file does not extend the time to furnish statements to recipients.
Important Reminders
Filing Timing
File Form 8809 as soon as you know an extension is necessary, but no earlier than January 1 of the year the return is due. Extensions cannot be granted if requests are filed after the original due date of the information returns.
Electronic vs Paper Distinctions
Electronic filing through the FIRE System offers automatic acknowledgement and faster processing for eligible forms. However, certain forms must use paper filing procedures. Follow specific requirements based on the form type and the content of the report.
Penalties for Late Filing
Filers may be subject to penalties if they file late returns without receiving valid extensions. Requesting and receiving proper extension approval protects against late filing penalties when returns are filed within the extended deadline period.
Extension Scope Limitations
Approved extensions apply only to filing information returns with the IRS. They do not extend deadlines for furnishing statements to recipients, making tax deposits, or paying taxes owed. Plan accordingly to meet all separate deadline requirements.
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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.
