IRS issues universal extension to July 15, 2020 for 2019 1040, 1041 and 1120 returns

March 20, 2020

The IRS late this afternoon issued the official details of the news Treasury Secretary Mnuchin tweeted this afternoon: July 15 is the new filing deadline for calendar-year 2019 returns normally due April 15.

Notice 2020-18 is much simpler than the prior tax payment deferral guidance it replaces:

For an Affected Taxpayer, the due date for filing Federal income tax returns and making Federal income tax payments due April 15, 2020, is automatically postponed to July 15, 2020. Affected Taxpayers do not have to file Forms 4868 or 7004. There is no limitation on the amount of the payment that may be postponed.

Who is an "affected person?"

The Secretary of the Treasury has determined that any person with a Federal income tax payment or a Federal income tax return due April 15, 2020, is affected by the COVID-19 emergency... The term “person” includes an individual, a trust, estate, partnership, association, company or corporation, as provided in section 7701(a)(1) of the Code.

That probably means you.

This replaces the prior guidance, which didn't extended payment dates without extending filing deadlines, creating potential traps for unwary taxpayers. The prior guidance was also limited to individual payments of up to $1 million, or corporate payments up to $10 million.

In addition to postponing balances due with 2019 returns, it also delays the first 2020 estimated tax payment deadline to July 15, 2020. It appears, inexplicably, that the second quarter payment for 2020 is still due before the first quarter payment.

A few questions remain; for example, while it appears that extensions can still be filed for the new date, the Notice doesn't say whether such extensions run to the usual October 15 deadline, or to a new January 2021 deadline. We expect such details to be flushed out next week. Follow Eide Bailly Tax News & Views and Eide Bailly Insights for updates.

 Correction: the first version of the post stated that the second quarter 2020 was also postponed to July 15. That does not appear to be correct.


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