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Yes, there are certain corporations that file Forms 1120, 1120-S, or 1120-F that cannot file their tax returns electronically. Specifically, the Corporate e-file Program does not accept and process the following corporate returns:
Additionally, the following forms cannot be filed electronically as a return at the parent level but must be filed in XML format if they are part of a consolidated return. If these forms are stand-alone filings (not part of a consolidated return), they must be filed in paper format:
The following forms must be filed in paper if they are stand-alone filings but can be attached in PDF format to a consolidated return:
Furthermore, Form 1120-X (Amended Return) cannot be e-filed as a stand-alone return and can only be submitted as an attachment to an 1120 return.
Sources:
Publication 4163 (12/2023)
Publication 4164 (10/2023)
Instructions for Form 1120 (2023)
Instructions for Form 1120-S (2023)
Publication 4452
IRM Part 3. Submission Processing. Chapter 42. Electronic Tax Administration. Section 4. IRS e-file for Business Tax Returns