IRS Extends More Tax Deadlines Due to COVID-19

Update: This article has been updated with the latest guidance as of April 14.

On April 9, the IRS announced via Notice 2020-23 that it is expanding tax relief to include additional types of returns, tax payments, and other actions. All taxpayers who are covered by this notice and have a filing or payment due on or after April 1 and before July 15 will automatically receive an extension to July 15. This broadened COVID-19 tax relief applies to individuals, most trusts, estates, corporations, and certain noncorporate tax filers, allowing an expanded group of taxpayers to wait until July 15 to file their 2019 federal income tax return and pay any tax due, without penalty. Notice 2020-23 builds upon the IRS’s previous COVID-19 relief, which extended only the filings and payments due on the April 15 date.

For any form or payment covered by this notice that is due on or after April 1 and before July 15, the due date has been postponed to July 15. This applies to both original due dates and extended due dates falling into the April 1 to July 15 timeframe. This relief is automatic, and there is no extension filing required. This means that some of the most common forms, including the below, are now extended automatically to July 15:

• Form 1040, U.S. Individual Income Tax Return
• Form 1065, U.S. Return of Partnership Income
• Form 1120, U.S. Corporation Income Tax Return
• Form 990 series of annual information returns, including Form 990 and Form 990-PF
• Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return
• Form 5227, Split-Interest Trust Information Return
• Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code

For a full list of impacted forms and payment types, see Notice 2020-23 and Rev. Proc. 2018-58.

Second Quarter Estimated Tax Payments

When the IRS previously extended April 15 payments due, it extended the first quarter estimated tax payments for individuals but left second quarter estimated payments with a due date of June 15. Notice 2020-23 now makes first quarter and second quarter individual estimated tax payments due on July 15.  Furthermore, any covered payment type that is due within the April 1 to July 15 timeframe is now due July 15.

Filing Extensions

Those who need additional time to file beyond the July 15 date can request an extension. The extension request must be filed by July 15, and the extended due date will be determined based on the original due date. The extended date is for filing only; all tax payments will be due by July 15.

Schedules and Other Forms

The due date for all schedules, returns, and other forms that are filed as attachments to a form covered by this relief are extended to July 15. In other words, there are no separate extensions required for any form that is filed as an attachment to a covered form.

Specified Time-Sensitive Actions

The due date for any “specified time-sensitive action,” as defined within the notice, that is due to be performed within the April 1 to July 15 timeframe has been postponed to July 15. This includes the actions specified in Rev. Proc. 2018-58 and the 180-day period for investing eligible gains into a qualified opportunity zone or qualified opportunity fund.

Petitions and Claims

The notice provides taxpayers with additional time to file petitions with the U.S. Tax Court and to file refund claims (i.e., extends the statute of limitations). However, the notice also provides the IRS with additional time to pursue certain actions against taxpayers, including taxpayers that are under examination or have appeal cases pending.

Gift Tax Returns

Form 709, a regular gift tax return, is not included on the list of forms covered by this notice. However, Notice 2020-23 extends the gift tax return due date to July 15.

However, additional guidance can be expected, and the IRS has stated it will update its filing and payment deadlines FAQ.

VISIT THE KSM COVID-19 RESOURCE CENTER