Not All Tax Returns Have Been Extended

Friday night, the IRS made it official regarding income tax returns due on April 15th; they are now due on July 15th. However, not all returns have been extended.

First, while I expect most states to conform to this deadline it may take a week or two for this to occur. The AICPA is maintaining a list. Local property taxes are also still due as normal (in most areas).

But when we look at federal returns, not everything was extended. Let’s look at this form by form:

  • Forms 1040, 1040-NR, 1040-SR, 1041, and 1120: These are now due on July 15th.
  • Forms 1040-ES: This is where it gets confusing. First quarter payments due on April 15th have been extended to July 15th. However, second quarter payments due on June 15th are still due on June 15th. There is legislation pending in Congress that would extend the deadline for paying the first three quarters of estimated tax payments to October 15th. Some states (e.g. California) have extended second quarter payments to July 15th.
  • Forms 1065 and 1120-S: These were due on March 16th and were not extended.
  • Forms 706 (Estate Tax) & 709 (Gift Tax): These are now due on July 15th per IRS Notice 2020-20.
  • Form 720 (Excise Tax): These are still due on the original due dates.
  • Form 941 and Other Payroll Tax Forms: These are still due on the normal dates.
  • Form 990 (Non-Profits and Charities) Series: These are due on May 15th. As of today, they have not been extended.
  • Form 3520A: This was due on March 16th and was not extended.
  • Form 3520: This is still due on April 15th. However, an extension of time for Form 1040 extends the time for Form 3520. It’s unclear whether anyone not filing an extension has until July 15th to file Form 3520. The simple solution for anyone filing Form 3520 is to extend your return by filing Form 4868 or Form 7004.
  • Forms 4868/7004 (Tax Extensions): These are now due (assuming the underlying return has been extended) on July 15th. It is unclear how long an extension will be for (will extended returns be due on October 15th or January 15, 2021?).
  • Forms 8804/8805: The due dates of these have not changed from April 15th.
  • Form BE-10 Series: These are still due on May 29th. This is the required every five-year survey of US ownership of foreign entities.
  • Backup Withholding Payments: These are still due as normal.
  • FBAR (FINCEN Form 114): This was not extended. However, while the FBAR is due on April 15th, there is an automatic extension until October 15th.

I’m sure I missed a tax or two (and I’ll expand this as needed), but there are traps for the unwary.


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