IRS Extends More Deadlines

The IRS released Notice 2020-23 this afternoon, formally extending lots more tax deadlines. I’m going to copy the language as it matters:

The Secretary of the Treasury has determined that any person (as defined in section 7701(a)(1) of the Code) with a Federal tax payment obligation specified in this section III.A (Specified Payment), or a Federal tax return or other form filing obligation specified in this section III.A (Specified Form), which is due to be performed (originally or pursuant to a valid extension) on or after April 1, 2020, and before July 15, 2020,is affected by the COVID-19 emergency for purposes of the relief described in this section III (Affected Taxpayer).

The IRS extends various deadlines/payment dates to July 15th:

  • Form 1040 Series
  • Forms 1040-ES (and other estimated taxes) [1]
  • Forms 1120 Series (including Form 1120-S) [2]
  • Form 1065 [2]
  • Form 1041 Series
  • Form 706
  • Form 709
  • Form 990-T
  • Form 990-PF
  • Form 3520

However, some tax forms were not included: Form 990, Form 990N, and Form 990-EZ. I’m not sure what the reason was for excluding the forms that most nonprofits have to file.

A couple of notes:

  1. The language in this notice appears to extend all estimated payments due between April 1st and July 15th to July 15th. That means that second quarter estimated payments that were due on June 15th are now due on July 15th.
  2. The notice states that relief is granted to: “Calendar year or fiscal year corporate income tax payments and return filings on…[Form] 1120-S…[and] Calendar year or fiscal year partnership return filings on Form 1065, U.S. Return of Partnership Income….” This means that the March 15th deadline for S-Corporations and Partnership returns has been retroactively extended to July 15th–at least, that’s how I read the notice. That’s big news as I have some new clients who just submitted their partnership information, so they’ll be considered timely filed.
  3. The IRS specifically granted relief for anyone who has to file items such as Forms 3520, 5471, 5472, 8921, 8858, 8865, and 8938 with their tax returns. They can either file by July 15th or with a timely (by July 15th) extension.

Kudos to the IRS for this relief–especially the July 15th second quarter estimated tax deadline. Clients were already very confused regarding the idea that the second quarter estimated payment was due before the first quarter payment.


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