How far back for late Form TD F 90-22.1?

The IRS has six years to find and penalize you if you don’t file Form TD F 90-22.1. The following are the dates on which your audit risk lapses for failure to file Form TD F 90-22.1:

  • 2003 – due on June 30, 2004, audit risk expires on June 30, 2010
  • 2004 – due on June 30, 2005, audit risk expires on June 30, 2011
  • 2005 – due on June 30, 2006, audit risk expires on June 30, 2012
  • 2006 – due on June 30, 2007, audit risk expires on June 30, 2013
  • 2007 – due on June 30, 2008, audit risk expires on June 30, 2014
  • 2008 – due on June 30, 2009, audit risk expires on June 30, 2015
  • 2009 – due on June 30, 2010, audit risk expires on June 30, 2016

This means that up until June 30, 2010, the earliest year the IRS can reach back to is 2003. (The Form TD F 90-22.1 for 2003 was due on June 30, 2004.)

After June 30, 2010, the earliest year the IRS can reach is 2004 (because the Form TD F 90-22.1 for 2004 was due on June 30, 2005).