Advisers have been noting that the IRS does not currently allow filing Schedules K-2 and K-3 electronically via MeF/XML, with the expected dates when such filing will be supported coming just after the original unextended due date for partnerships, but not until mid-June for S corporations. However, advisers should note that the IRS does provide an interim solution to attach PDFs of the forms to returns filed before the MeF/XML system is operational.[1]

The official timeframes for Schedules K-2 and K-3 to be available to be filed via the MeF/XML system as announced by the IRS is:

Form Number	Date Available
Form 1065	March 20, 2022
Form 1120-S	Mid-June 2022
Form 8865	January 2023

Because many advisers will find that small partnerships and S corporations will not want to wait until these expected availability dates to file their returns, the IRS does provide an alternative noted on their interim filing website:

Modernized e-File (MeF)/Extensible Markup Language (XML) electronic filing capability for the schedules K-2 and K-3 for TY 2021 will not be available as of the beginning of the 2022 filing season (January 2022). Schedules K-2 and K-3 will be available for MeF/XML filing in the following timeframes. If you electronically file your return before the timeframes (Interim Period), submit the schedules as separate PDF files attached to the return.[2]

At the moment it’s not clear which tax software providers will allow the use of the PDF attachment option under the interim method or which will simply wait for the MeF/XML system to be updated. However, given the long wait to get the S corporation MeF/XML option it seems likely that most vendors will be forced to provide PDF attachment support at least for S corporation filings and some vendors are already supporting the PDF method to file S corporation returns that are required to prepare these schedules.[3]

[1] “Schedules K-2 and K-3: Interim Electronic Filing for Tax Year 2021,” IRS website, December 3, 2021, https://www.irs.gov/e-file-providers/schedules-k-2-and-k-3-interim-electronic-filing-for-tax-year-2021 (retrieved February 5, 2022)

[2] “Schedules K-2 and K-3: Interim Electronic Filing for Tax Year 2021,” IRS website, December 3, 2021

[3] Thomson Reuters’ Ultratax has been reported by some users as supporting electronically filing S corporation returns with these schedules, though partnerships are still to come with a later update.