The first electronic transmission of tax return data to the IRS was completed in 1986. One IRS employee manually turned on a single modem for each electronically filed (e-filed) return, an undertaking dubbed “Mission Impossible” — reportedly after the movie of the same name released later that year (true story). That year, tax preparers filed 25,000 returns electronically and over a billion returns have been successfully e-filed since.
Yet not one of them was Form 1120-RIC.
After 40 years of marching through rain, sleet, snow and hail uphill in both directions to the post office, Form 1120-RIC has finally joined the party. The 2025 form instructions, released in January 2026, indicated Form 1120-RIC can be e-filed as of mid-February.
Historically, Forms 1120-RIC, related forms, schedules and attachments were paper filed with the IRS at specific Ohio, Missouri or Utah tax processing centers, depending on total assets at tax year-end. While it may seem surprising, paper filing was more efficient, as e-filing capabilities were not developed until the late 1980s. That efficiency, however, did not keep pace as technology evolved.
For the last few decades tax preparers, administrators and officers of Regulated Investment Companies (RICs) dealt with wet signatures, cost of postage, back pain (some of the packages were heavy!), slow tax return processing, and mismatched timing of electronic federal tax payments and processing of a paper filed return.
Temporary relief arrived for electronic signatures during the COVID-19 pandemic for certain tax returns, including Form 1120-RIC. While this spared signers’ wrists, it did little to eliminate the drive to the post office or the broader costs of paper filing tax returns.
E-filing does more than bring Form 1120-RIC into the 21st century. It offers potential benefits to key stakeholders in the tax operations of a RIC, including but not limited to:
Additionally, signing officers of RICs should expect e-file authorization forms for electronic signature in lieu of paper filing copies, which will make signing returns more efficient and accessible. The days of being tied down to a specific location waiting for a package to arrive may finally be over.
The short answer is no. While e-filing is now an option for Form 1120-RIC, this method is only required for RICs that file 10 or more returns of any type (including income tax, employment tax, excise tax and information returns) during the calendar year. While it may be rare for a RIC to have 10 or more filings to trigger mandatory e-filing, those who fall within this group may request a waiver of the e-filing requirement, if they desire.
With all the excitement surrounding the announcement of e-filing for Form 1120-RIC, like taxpayers in 1986, there are still unknowns on how the IRS e-filing system will respond to a flood of Form 1120-RIC returns itching to be transmitted electronically instead of taking the long hard road via truck, train or plane.
While this analysis is meant to bring some humor to the technologic advance in the industry, reserve some caution for the inevitable growing pains as thousands of taxpayers and returns convert to e-filing. Consult your tax adviser on capabilities of their software to ensure tax returns are properly filed and that there is a timely backup plan to paper file Form 1120-RIC, should it become necessary.
Contact Ryan McKenna or a member of your service team to discuss this topic further.
In this blog Cohen & Co is not rendering legal, accounting, investment, tax or other professional advice. Rather, the information contained in this blog is for general informational purposes only. Any decisions or actions based on the general information contained in this blog should be made or taken only after a detailed review of the specific facts, circumstances and current law with your professional advisers.