In addition to previously granted automatic extensions of time to file and pay, the IRS yesterday granted additional, broad relief in response to coronavirus. Notice 2020-23, applies to all taxpayers that have a filing or payment deadline on or after April 1, 2020, and before July 15, 2020. This includes individuals, trusts, estates, corporations, and other non-corporate tax filers. The period will be disregarded by the IRS in calculating any interest, penalty, or addition to tax for failure to file the forms specified in the notice.
The following is a running list of extended deadlines for federal taxes. This list will be updated as changes occur.
Estimated taxes: The June 15 deadline for estimated tax payments has been pushed to July 15.
Unclaimed 2016 refunds: The deadline for filing a 2016 tax return to claim a refund, normally April 15, is extended to July 15. The return must be postmarked by July 15.
Installment payments under Sec. 965(h): Installment payments of the Sec. 965 transition tax due on or after April 1, 2020, and before July 15, 2020, are postponed to July 15, 2020.
American citizens living abroad: Americans who live and work abroad can now wait until July 15, 2020, to file their 2019 federal income tax return and pay any tax due.
Specified forms: Federal tax forms and payments covered by the relief include:
- Individual income tax payments and return filings on Form 1040 and other forms in the 1040 series;
- Calendar year or fiscal year corporate income tax payments and return filings on Form 1120 and other forms in the 1120 series;
- Calendar year or fiscal year partnership return filings on Form 1065;
- Estate and trust income tax payments and return filings on Form 1041 and other forms in the 1041 series;
- Estate and generation-skipping transfer tax payments and return filings on Form 706 and other forms in the 706 series;
- Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent, and any supplemental Form 8971;
- Gift and generation-skipping transfer tax payments and return filings on Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return, that are due on the date an estate is required to file Form 706 or Form 706-NA;
- Estate tax payments of principal or interest due as a result of an election made under Secs. 6166, 6161, or 6163 and annual recertification requirements under Sec. 6166;
- Exempt organization business income tax and other payments and return filings on Form 990-T; and
- Excise tax payments on investment income and return filings on Form 990-PF and excise tax payments and return filings on Form 4720.
In addition, and because the current pandemic has made it difficult for IRS employees, taxpayers, and others to work due to office closures and/or restricted activities, the notice also gives the IRS additional time to perform certain time-sensitive acts, like audits. The IRS is giving itself an extra 30 days to perform these time-sensitive acts if the last date for performance is on or after April 6, 2020, and before July 15, 2020. Affected taxpayers include those under examination, those with cases with the Independent Office of Appeals, and those who submit amended returns or submit payments with respect to a tax for which the assessment period would expire on or after April 6, 2020, and before July 15, 2020.
The IRS earlier provided filing and payment relief in Notice 2020-18, but that relief had applied only to federal income tax returns and payments (including self-employment tax payments) due April 15, 2020, for 2019 tax years, and to estimated income tax payments due April 15, 2020, for 2020 tax years.
Please continue to reference this list for updates, and reach out to us with questions, as always.