What Sinlaku Means for Your Taxes

If you have not yet filed your return or requested an extension in advance of the April 15 tax deadline, you are not alone. With Super Typhoon Sinlaku bearing down on the Marianas, there are real questions about what happens to the April 15 deadline. Federal emergency declarations have now been approved for both Guam and the CNMI, but the relief available to you right now is not the same in both places. Both territories have automatic extensions of at least 30 days on the payment of taxes due April 15, but on the filing side, automatic extensions of no less than 30 days are in place in one territory and are anticipated to be no less than 180 days in the other.

President Trump has approved federal emergency declarations for both territories under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, for the CNMI on April 11, 2026, and for Guam on April 12, 2026. With Stafford Act declarations now in place for both territories, the IRS has the authority to postpone filing and payment deadlines for affected taxpayers by up to one year. 

The IRS must publish its own announcement for each territory specifying the disaster area and the new dates. Those announcements have not yet been published as of this writing, but the legal prerequisites have been satisfied for both. We have been here before. After Typhoon Mawar struck in May 2023, the IRS issued guidance within days, extending most filing and payment deadlines to October 2, 2023. After Tropical Storm Bolaven later that year, the IRS issued guidance on October 17, 2023, doing the same. Sinlaku relief for both territories will follow this same path.

When the IRS announcement comes, it will postpone deadlines for individual income tax returns, business returns, estate and trust returns, employment and certain excise tax returns, and tax payments, including the April 15 estimated tax installment, for taxpayers residing or operating a business in the designated disaster area. What it will not cover are returns with deadlines that have already passed (i.e., returns previously due on March 15th, information returns in the W-2, 1094, 1095, 1097, 1098, and 1099 series), nor will it postpone payroll tax deposits themselves, though penalties on those deposits are typically abated for the first two weeks of the disaster period. It is important to note that the IRS announcements will cover your federal obligations, but your territorial authority must issue its own extension separately.

1. CNMI Taxpayers

The CNMI DRT has confirmed that final guidance is expected this week, and that it will announce an automatic extension to file of no less than six months for returns originally due on April 15, including both individual income tax returns and corporate income tax returns. Similar to the IRS, the extension will not cover returns with deadlines that have already passed. That means CNMI taxpayers will have substantial time to get their returns in order after the storm, with the exact end date to be confirmed in the forthcoming announcement. 

The CNMI DRT has also confirmed a minimum 30-day extension to pay any estimated taxes otherwise due on April 15. The failure-to-pay penalty on any unpaid balances from returns originally due April 15 will also not begin to accrue for at least that same 30-day period.

The failure-to-file penalty is effectively waived at least through October 15 by ways of the automatic extension. 

 In the meantime, Form 4868 remains a practical safeguard at the federal level. Filing before April 15, even electronically, gives you an automatic six-month extension to October 15 to file. Keep in mind that Form 4868 extends the time to file, not the time to pay. Interest accrues on any unpaid balance from April 15 forward, but filing eliminates the failure-to-file penalty, which is the sharper of the two. If your tax records are not fully digitized and backed up, keep them in a waterproof bag and focus on staying safe.

2. Guam Taxpayers

Guam territorial filers have some relief already in hand. Governor Leon Guerrero issued Executive Order No. 2026-02 extending the deadline to both file and pay Guam territorial income taxes from April 15 to May 15, 2026, with penalties and interest suspended for the 30-day period. 

Notably, the guidance provided by Guam officials does not address taxpayers who own a business in Guam but reside on Saipan.

Additionally, the guidance does not address Form 4868, which must be filed on or before April 15 to be valid.  If it is filed even one day late, the extension is void. April 15, 2026 falls on a Wednesday, so there is no weekend grace period. That means that if you have not already filed Form 4868, absent additional guidance which includes Form 4868, your window to do so is closing fast on April 15, and if you miss it, the governor's 30-day extension to May 15 is all you have. There is no path to October 15 without a timely Form 4868 for Guam residents like there will be in the CNMI. 

If you still have time to file it today or tomorrow, now is the time to do so. Keep in mind it extends the time to file, not the time to pay. Interest accrues on any unpaid federal balance from April 15 forward, but a timely Form 4868 can prevent the failure-to-file penalty, which accrues at 5% of the unpaid balance per month, up to 25%. 

3. What Applies to Both Territories

Once the storm passes, two items apply regardless of which territory you are in.

The first is the disaster casualty loss deduction. If Sinlaku damages or destroys your property and you are not fully reimbursed by insurance or other assistance, you may be able to deduct that loss on your tax return. The useful feature of the disaster loss rules is timing. You can claim the loss either in the year it occurred, which would be 2026 on next year's return, or on your 2025 return, which is the one due right now. Claiming it on the 2025 return, once extended, may generate a faster refund that helps with your immediate recovery costs. Document everything as soon as it is safe to do so: photographs of damage, lists of lost or destroyed property with approximate values, insurance claim submissions, contractor estimates, and any FEMA assistance received.

The second is a practical reminder about who qualifies for IRS disaster relief at all. The relief is geographically defined. It applies to taxpayers who reside or have a principal place of business in the designated disaster area. If you live on Saipan but your accountant is in California, you still qualify. If you live in California but own rental property on Rota, you may qualify for some purposes but not others, and should call the IRS disaster hotline at 866-562-5227. The IRS generally identifies disaster-area taxpayers automatically based on address, but if your address on file with the IRS is outside the covered area, you may need to affirmatively request the relief.

Navigating disaster relief across two territories, with declarations, executive orders, and IRS announcements all moving at once, is a lot to manage on your own. Do you own a business and need tax representation during and after Sinlaku? Call Azarvand Tax Law. We have boots on the ground not only in the Marianas but on the mainland as well, which means we can provide uninterrupted representation to our clients even when island operations are disrupted. 

Our Saipan team is available from 8 AM to 6 PM CHST, and our mainland team is also on standby from 10 PM to 8 AM CHST, giving us a combined 20 hours of daily availability to answer your questions on typhoon tax relief or anything else on your plate. Call or text us today at 410-698-4005, or send us an email at info@azarvandtaxlaw.com for a free 30-minute consultation.

This column is for general information and does not constitute legal or tax advice. The guidance referenced in this column is current as of the time of publication.