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Additional IRS Clarification Regarding Filing Deadlines and Payments

The IRS provided additional filing and payment relief to affected taxpayers late last week when they provided Notice 2020-23. The Secretary of the Treasury determined that any person with a Federal tax payment obligation or a Federal tax return obligation which is due (originally or pursuant to a valid extension) on or after April 1, 2020, and before July 15, 2020, is affected by the COVID-19 emergency for purposes of the relief. For an Affected Taxpayer with respect to Specified Filing and Payment Obligations, the due date for filing Specified Forms and making Specified Payments is automatically postponed to July 15, 2020.

To review all of the specified filing and payment obligations, please reference the Notice. However, highlights of Specified Filing and Payment obligations, extending the payment and filing deadlines until July 15, 2020, include:

  • Individual income tax returns: Form 1040 series (1040, 1040-SR, 1040-NR, 1040-NR-EZ, 1040-PR and 1040-SS).
  • Estate and trust income tax returns: Form 1041 series (1041, 1041-N, and 1041-QFT).
  • Calendar-year and fiscal-year partnership returns: Forms 1065 and 1066.
  • Calendar-year and fiscal-year corporate income tax returns: Form 1120 series (1120, 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-S and 1120-SF).
  • Estate and generation-skipping transfer tax returns: Form 706 series (706, 706-NA, 706-A, 706-QDT, 706-GS(T), 706-GS(D) and 706-GS(D-1)).
  • Gift and generation-skipping transfer tax return: Form 709.
  • Information return regarding beneficiaries acquiring property from a decedent: Form 8971.
  • Exempt organization tax returns: Form 990-T (unrelated business income tax); Form 990-PF (excise tax payments on investment income); and Form 4720 (other excise tax payments).

This relief includes not only the filing of Specified Forms, but also all schedules, returns, and other forms that are filed as attachments to Specified Forms or are required to be filed by the due date of Specified Forms, including, for example, Schedule H and Schedule SE, as well as Forms 3520, 5471, 5472, 8621, 8858, 8865, and 8938. This relief also includes any installment payments under section 965(h) due on or after April 1, 2020, and before July 15, 2020. Finally, elections that are made or required to be made on a timely filed Specified Form (or attachment to a Specified Form) shall be timely made if filed on such Specified Form or attachment, as appropriate, on or before July 15, 2020.

Taxpayers interested in extending their filing dates beyond July 15, 2020 (e.g., until October 15, 2020) must file an extension form and pay any taxes due by July 15, 2020.

The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We therefore make no warranties, expressed or implied, on the services provided hereunder.