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Major Deadline Shift for Tax Returns to July 15, 2020

On Thursday, April 9, 2020, the Internal Revenue Service (IRS) announced expanded Coronavirus related relief, granting taxpayers an automatic extension of time to file a much larger array of tax forms.  IRS Notice 2020-23 grants automatic extensions of time to file virtually all tax returns due between April 1, 2020, and July 15, 2020 (originally or pursuant to a valid extension).  This automatic extension of time also applies to nearly all tax payments that would normally be due between April 1, 2020 and July 15, 2020, including Q1 and Q2 estimated tax payments.  Taxpayers needing additional time to file beyond July 15, 2020, should file an extension request by July 15, 2020, using Form 7004 or Form 4868.

The Details

Relief under IRS Notice 2020-23 applies to “Specified Forms” and to “Specified Time-Sensitive Actions” due (originally or pursuant to a valid extension) between April 1, 2020, and July 15, 2020.  Specified Forms are listed directly in IRS Notice 2020-23, while Specified Time-Sensitive Actions are listed in Revenue Procedure 2018-58.  The relief also covers any schedules, forms, elections, or other attachments that are submitted with affected tax returns.

Tax-Exempt Organizations

The following specified forms, if due between April 1, 2020, and July 15, 2020 (originally or pursuant to a valid extension), will now be due on July 15, 2020:

  • 990-T, Exempt Organization Business Income Tax Return
  • 990-W, Estimated Tax on Unrelated Business Taxable Income for Tax-Exempt Organizations
  • Form 4720, Return of Certain Excise Taxes under Chapters 41 and 42 of the Internal Revenue Code

Below are some examples of specified time-sensitive actions that, if due between April 1, 2020, and July 15, 2020 (originally or pursuant to a valid extension), will now be due July 15, 2020:

  • Filing of Form 990, Return of Organization Exempt from Income Tax
  • Filing of Form 5500, Annual Return/Report of Employee Benefit Plan
  • Filing of Form 8955-SSA, Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits

Corporations & Partnerships

The following specified forms, if due between April 1, 2020, and July 15, 2020 (originally or pursuant to a valid extension), will now be due on July 15, 2020:

  • 1065, U.S. Return of Partnership Income
  • 1120, U.S. Corporation Income Tax Return (including other 1120 series forms such as 1120-POL)
  • 1120-W, Estimated Tax for Corporations

Individuals, Trusts & Estates

Commonly filed specified forms that have been automatically extended to July 15, 2020 include:

  • 1040, U.S. Individual Income Tax Return
  • 1041, U.S. Income Tax Return for Estates and Trusts
  • 706, United States Estate (and Generation-Skipping Transfer) Tax Return
  • 709, United States Gift (and Generation-Skipping Transfer) Tax Return
  • 1040-ES, Estimated Tax for Individuals
  • 1041-ES, Estimated Income Tax for Estates and Trusts

States

IRS granted relief only extends to federal tax payment and filing deadlines and does not affect state or local deadlines.  However, individuals and businesses typically need information from their federal returns in order to complete their state filings, so most states have now extended deadlines to match the federal due date.  Taxpayers should check with their state department of revenue or other state government authority to determine their filing and payment deadlines.

 

Prepared By:
Justin W. Herring, CPA MST | Tax Manager

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