In Notice 2020-23, released April 9, the IRS significantly expanded tax filing and payment relief due to the COVID-19 pandemic. Previously, the IRS had delayed the due date for filing 2019 income tax returns and making payments, including 2020 estimated tax payments, due on April 15, 2020, until July 15, 2020.
This new notice automatically postpones the due date until July 15, 2020, for all taxpayers that have a return filing or tax payment deadline that falls on or after April 1, 2020, and before July 15, 2020.
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What Returns Are Covered?
Tax returns, payments and forms covered by this delay include (Note: This list is not all inclusive):
Are Other Forms, Schedules and Actions Delayed?
- Individual returns – Forms 1040, 1040-SR, 1040-NR, 1040-PR, 1040-SS
- Trust and estate returns – Forms 1041, 1041-N, 1040-QFT
- Corporation returns – Forms 1120, 1120-S, 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-S, 1120-SF
- Partnership returns –Forms 1065, 1066
- Estate and GST returns – Forms 706, 706-NA, 706-QDT, 706-GS(T), 706-GS(D), 706(D-1)
- Gift and GST returns – Forms 709
- Exempt organization returns – Forms 990, 990-T
- Excise tax returns – Forms 990-PF, 4720
- Employee benefit plan returns – Forms 5500
- Quarterly estimated tax payments – Forms 990-W, 1040-ES, 1040-ES(NR), 1040ES(PR), 1041-ES, 1120-W
- Information reporting forms – Forms 8971
As a result, for example, the second quarter estimated tax payments normally due on June 15, 2020, are extended to July 15, 2020. In addition, the notice also extends the time for other time-sensitive actions such as:
- All schedules, returns and other forms filed as attachments to tax returns including, Schedule H, Schedule SE, Forms 3520, 5471, 5472, 8621, 8558, 8865 and 8938
- Installment payments under section 965(h)
- Estate tax payments of principal and interest due as a result of an election under sections 6166, 6161 or 6163
- Elections made or required in a timely filed return
- Filing a petition with the Tax Court
- Filing a claim for credit or refund of any tax
- Bringing suit for credit or refund of any tax
- Meeting the 45-day and 180-day requirements for section 1031 like-kind exchanges and the replacement period for involuntary conversion property
- Meeting the 180-day periods for reinvesting eligible capital gains in a Qualified Opportunity Fund
What Action Do I Need to Take?
Notice 2020-23 automatically applies, so no action is required to obtain the delay in filing or paying tax until July 15, 2020, for those returns that fall within the April 1 – July 15 window. While this is welcome news for taxpayers, each state will need to separately address its own tax filing and payment requirements.
Have questions on how this affects your tax situation?