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IRS Updates Deadlines, Expands List

Ben Westbrook

4.13.20 | Client Alert – COVID-19 Update

The IRS released notice 2020-23 on April 9 and it contains many updates to deadlines. The initial notices (2020-18 and 2020-20) only applied to returns and payments due April 15, extending them to July 15. This new notice includes anything due between April 1 and July 15 for affected taxpayers and features additional forms, extending them all to July 15.

The list of forms extended to July 15 includes the following. New additions are in bold:

  • 1040, 1040-NR
  • 1120, 1120-C, 1120-F, 1120-H, 1120-REIT, 1120-S
  • 1065
  • 1041
  • 706, 706-GS(T), 706-GS(D)
  • 709
  • 990, 990-EZ, 990-PF, 990-T
  • Quarterly estimated tax payments on forms 1040-ES, 1041-ES, 1120-W and 990-W (including payments due June 15)

The IRS also went on to say that the relief doesn’t just apply to those listed forms, but also all schedules, returns, and other forms that are filed as attachments to the listed forms, such as:

  • Schedules H and SE
  • 3520
  • 5471
  • 5472
  • 8621
  • 8858
  • 8865
  • 8938
  • 965(h) installment payments

It also states that elections that are made or required to be made on a timely filed specified form (or attachment to a specified form) shall be timely if filed on or before July 15.

Additional Items

  • Extensions can be filed by July 15 if you need more time, but extensions will be granted to the original extension date.  For example, you can extend Form 1040 by July 15, but it will be a 3-month extension, to October 15.
  • The period of April 1, 2020 through July 15, 2020 will be disregarded in calculating interest, penalty or addition to tax for failure to file any of the specified forms or payments.  These will begin to accrue on July 16, 2020.
  • Affected Taxpayers (those filing the forms listed above) also have until July 15, 2020 to perform Specified Time-Sensitive actions, including filing all petitions with the Tax Court, filing a claim for credit of refund of any tax, and bringing suit upon a claim for credit or refund.  If you have a specific situation, you must review the notice.
  • The notice also provides the IRS with a 30-day postponement to perform time-sensitive actions for taxpayers under examination, with cases with the Independent Office of Appeals, and 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.

More to Come

In addition, the notice referred to Rev Proc 2018-58 and its long list of time-sensitive acts as being included for relief. We are still reviewing some of these, including items related to 1031 exchanges, and will send out further information as we receive it.

For more information on this topic or any other matter related to the COVID-19 pandemic, please contact your Berdon Advisor.

Berdon LLP New York Accountants