In Notice 2020-23 issued on April 9th, the IRS has extended more tax deadlines for individuals, trusts, estates, corporations, nonprofit organizations, and other non-corporate tax filers. This broad relief includes a variety of tax filings and payment obligations that are due between April 1, 2020 and July 15, 2020, and the relief is automatic, so taxpayers do not have to file extensions or submit other documentation to the IRS to obtain relief. The notice also suspends interest, additions to tax, and penalties for late filing or late payment until July 15th.
Taxpayers who need additional time beyond July 15, 2020, have until July 15th to request an extension, but the extension date may not go beyond the original extension date (for calendar-year filers, this would be September 15th for partnerships and S corporations; October 15th for individuals and C corporations; and November 15th for Form 990 series filers).
The relief includes not only the filing of the specified forms, but also all schedules, returns, and other forms that are filed as attachments to these forms or are required to be filed by the due date of the specified forms (for example, Schedule H and Schedule SE, as well as Forms 3520, 5471, 5472, 8621, 8858, 8865, and 8938). Elections that are made or required to be made on a timely filed specified form will be timely made if filed on the specified form or attachment on or before July 15, 2020 (unless an extension is filed).
The relief also applies to time-sensitive acts listed in Regs. Secs. 301.7508A-1(c)(1)(iv) through (vi) and Rev. Proc. 2018-58.
Some common filings and payment obligations now added to the list of filings granted relief by this notice include:
- Estimated tax payments due June 15, 2020 (including Forms 1040-ES, 1041-ES; 1120-W; and 990-W)
- Form 706, United States Estate (and Generation Skipping Transfer) Tax Return
- Form 990, Return of Organization Exempt from Income Tax
- Form 990-T, Exempt Organization Business Income Tax Return
- Form 990-PF, Return of Private Foundation
- Form 5500, Annual Return/Report of Employee Benefit Plan
- Form 1120 (and other filings) for certain fiscal year taxpayers
- Deadline for filing a 2016 return to claim a refund
- Installment payments under IRC Section 965(h)
You can find additional information through our links below:
- Click here for a more complete list of tax forms granted relief under this and prior notices.
- Click here to read the full text of IRS Notice 2020-23.
- Click here for more information on relief previously granted.
Please contact your tax advisor with any specific questions regarding the timing of your return and the payment of any related taxes. You can visit ML&R’s dedicated COVID-19 page for additional information and resources for any important updates on this or other COVID-19 related legislation as it arises.
