New Notice of Extended Deadlines
In a further response to the COVID-19 pandemic and its effects on taxpayers, on April 9, 2020, the IRS released Notice 2020-23, 2020-18 IRB, 04/09/2020, extending more tax deadlines to cover individuals, estates, corporations, and other taxpayers.
The notice covers numerous tax form filings and payment obligations due between April 1, 2020 and July 15, 2020, including estimated tax payments due June 15. The notice also extends the statute of limitations to claim tax refunds. Finally, the accrual of interest, other additions to tax, and penalties for late filing or late payment are suspended until July 15, 2020.
The IRS previously issued notices extending certain filing and payment deadlines. On March 18, 2020, the IRS issued a notice postponing the due date for some federal income tax payments from April 15, 2020 until July 15, 2020.
On March 20, 2020, the IRS issued another notice postponing until July 15, 2020, the filing date for 2019 federal income tax returns and 2020 federal estimated income tax payments that would otherwise be due on April 15, 2020.
On March 27, 2020, the IRS issued a third notice extending tax filing and payment relief to taxpayers with gift tax or GST tax obligations due by April 15 to July 15, 2020
More tax deadlines extended
By issuing Notice 2020-23, the IRS is amplifying the relief provided in the prior notices with new relief that includes extending the following filing and payment deadlines:
- Individual income tax payments and return filings on 1040-NR, U.S. Nonresident Alien Income Tax Return, 1040-NR-EZ, U.S. Income Tax Return for Certain Nonresident Aliens With No Dependents, 1040-PR, Self-Employment Tax Return – Puerto Rico, and 1040-SS, U.S. Self-Employment Tax Return (Including the Additional Child Tax Credit for Bona Fide Residents of Puerto Rico);
- Calendar year or fiscal year corporate income tax payments and return filings on Form 1120, U.S. Corporation Income Tax Return, 1120-C, U.S. Income Tax Return for Cooperative Associations, 1120-F, U.S. Income Tax Return of a Foreign Corporation, 1120-FSC, U.S. Income Tax Return of a Foreign Sales Corporation, 1120-H, U.S. Income Tax Return for Homeowners Associations, 1120-L, U.S. Life Insurance Company Income Tax Return, 1120-ND, Return for Nuclear Decommissioning Funds and Certain Related Persons, 1120-PC, U.S. Property and Casualty Insurance Company Income Tax Return, 1120-POL, U.S. Income Tax Return for Certain Political Organizations, 1120-REIT, U.S. Income Tax Return for Real Estate Investment Trusts, 1120-RIC, U.S. Income Tax Return for Regulated Investment Companies, 1120-S, U.S. Income Tax Return for an S Corporation, and 1120-SF, U.S. Income Tax Return for Settlement Funds;
- Calendar year or fiscal year partnership return filings on Form 1065, U.S. Return of Partnership Income, and Form 1066, U.S. Real Estate Mortgage Investment Conduit (REMIC) Income Tax Return;
- Estate and trust income tax payments and return filings on Form 1041, U.S. Income Tax Return for Estates and Trusts, 1041-N, U.S. Income Tax Return for Electing Alaska Native Settlement Trusts, and 1041-QFT, U.S. Income Tax Return for Qualified Funeral Trusts;
- Estate and generation-skipping transfer tax payments and return filings on Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, 706-NA, United States Estate (and Generation-Skipping Transfer) Tax Return, 706-A, United States Additional Estate Tax Return, 706-QDT, U.S. Estate Tax Return for Qualified Domestic Trusts, 706-GS(T), Generation-Skipping Transfer Tax Return for Terminations, 706-GS(D), Generation-Skipping Transfer Tax Return for Distributions, and 706-GS(D-1), Notification of Distribution from a Generation-Skipping Trust (including the due date for providing such form to a beneficiary);
- Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return filed pursuant to Revenue Procedure 2017-34;
- Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent and any supplemental Form 8971, including all requirements contained in Code Sec. 6035(a);
- Gift and generation-skipping transfer tax payments and return filings on Form 709, United States Gift (and Generation-Skipping Transfer) Tax Returns that are due on the date an estate is required to file Form 706 or Form 706-NA;
- Estate tax installment payments of principal or interest due as a result of an election made under Section 6166 of the Internal Revenue Code;
- Exempt organization business income tax and other payments and return filings on Form 990-T, Exempt Organization Business Income Tax Return;
- Excise tax payments on investment income and return filings on Form 990-PF, Return of Private Foundation or Trust Treated as Private Foundation, and excise tax payments and return filings on Form 4720, Return of Certain Excise Taxes under Chapters 41 and 42 of the Internal Revenue Code; and
- Quarterly estimated income tax payments calculated on or submitted with Form 990-W, Estimated Tax on Unrelated Business Taxable Income for Tax-Exempt Organizations, 1040-ES, Estimated Tax for Individuals, 1040-ES (NR), U.S. Estimated Tax for Nonresident Alien Individuals, 1040-ES (PR), Estimated Federal Tax on Self Employment Income and on Household Employees (Residents of Puerto Rico), 1041-ES, Estimated Income Tax for Estates and Trusts, and 1120-W, Estimated Tax for Corporations.
The relief granted by Notice 2020-23 is automatic. Taxpayers are not required to call the IRS or file any extension forms or other documents to receive this relief.
Refund claims, Court Filings, and Statutes of Limitations
In addition to providing return filing and tax payment relief, the notice includes extending the time for filing petitions with the Tax Court, for review of a decision by the Tax Court, filing a claim for credit or refund of any tax, and bringing an action in court on a claim for credit or refund of any tax.
However, the notice does not revive lapsed statutes of limitations. Therefore, no relief is provided for the time period for filing a petition with the Tax Court or for filing a claim or bringing a suit for credit or refund if that period expired before April 1, 2020.