MORE TAXPAYER RELIEF FROM IRS

The IRS released Notice 2020-23, which grants broader relief to taxpayers for filing and payment obligations due between April 1, 2020 and July 15, 2020. Treasury and the IRS had previously extended the filing and payment deadline for items that were due on April 15, 2020 to July 15, 2020.

With this new announcement, the IRS has automatically extended the filing and payment deadline to July 15, 2020 for most taxpayers that had returns and payments due between April 1, 2020 and July 15, 2020. Effected taxpayers include:

• Individual income tax payments and returns on Form 1040 and other forms in the 1040 series
• Corporate income tax payments and return filings on Form 1120 and other forms in the 1120 series
• Partnership return filings on Form 1065
• Estate and trust income tax payments and return filings on Form 1041 and other forms in the 1041 series
• Estate, gift, and generation skipping tax payments and return filings on Form 706 and 709
• Exempt organization income tax payments and return filings on Forms 990-T and 990-PF
• Quarterly estimated tax payments for individuals, corporations, and tax-exempt entities. For instance, individual 2nd quarter estimated tax payments that would have otherwise be due June 15, 2020 are now due July 15, 2020.

In addition, affected taxpayers have until July 15, 2020 to perform specified time sensitive actions that have been published by the IRS that are due to be performed on or after April 1, 2020 and before July 15, 2020. The list is expansive but includes:

• S corporation filing of Form 8752
• Corporation filing of Form 4466 for a quick refund
• Filing of Form 5500
• Filing of Form 5227, Split-Interest Trust Information
• Filing of Form 990

The Notice also includes the 180 days to invest qualifying capital gains into a Qualified Opportunity Zone as a specified time sensitive action.

An extension will be required for any tax return that is not filed by the new July 15, 2020 deadline. The extension filed at July 15, 2020 will only extend the time for filing to the statutory deadline. For instance, for an individual, the extended due date of the return will be October 15, 2020. The extension only extends the time for filing the return, any amounts due on the return will need to be paid due July 15, 2020 to avoid any late payment interest and penalties.

This announcement only applies to filings with the IRS and does not pertain to state and local jurisdictions.