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IRS Q&A About Extended Filing and Payment Deadlines

By: John V. Aksak Jason Carter |

Yesterday the IRS issued a set of answers to frequently asked questions (“Q&A’s”) to further clarify the relief granted to taxpayers due to the ongoing COVID-19 pandemic.  On March 20, 2020, the IRS issued Notice 2020-18 which provides for an automatic 90-day extension (to July 15, 2020) of the filing and payment deadline for all Federal income tax returns and payments previously due on April 15, 2020.  Notice 2020-18 supersedes and expands upon the relief granted in Notice 2020-17.

Here are the key takeaways from the IRS Q&A:

  • This relief applies to all persons with Federal income tax returns or payments with an original or extended due of April 15, 2020, regardless of the amount owed or whether the taxpayer has been impacted by COVID-19.
  • Relief applies solely to Federal income tax returns and payments previously due on April 15, 2020, including 2020 estimated payments and §965(h) installment payments. No relief has been provided for non-income tax payments (e.g. payroll or excise taxes), for the filing of information returns, or for payments or returns due on any date other than April 15, 2020.
  • For those who have already filed their 2019 returns, you may still delay payments until July 15, 2020. Any payments previously scheduled for April 15, 2020 will not be automatically rescheduled for July 15, 2020, but taxpayers may modify or cancel their payments in order to take advantage of the deferral.
  • Taxpayers may file for an automatic extension of the time for filing their 2019 Federal income tax returns, now due July 15, 2020, to October 15, 2020 by filing Form 7004 (for businesses) or Form 4868 (for individuals) by July 15, 2020.
  • Second quarter estimated income tax payments are still due on June 15, 2020 while first quarter estimated payments are due July 15, 2020.
  • The deadline for making contributions to an IRA and HSA for 2019 has also been extended to July 15, 2020.
  • The relief does not extend the April 15, 2020 deadline to make a claim for a refund for 2016 Federal income taxes.

TPC will continue to monitor for further developments, and will provide additional information as it becomes available. Please contact a member of your TPC engagement team if you have any questions about this topic or to learn more about how TPC can help.