IRS provides guidance for April 15 filing delay

By Alistair M. Nevius, J.D.

Late on Friday, the IRS officially announced that, because of the ongoing coronavirus pandemic, tax returns due April 15 will not have to be filed until July 15 this year. Notice 2020-18 was released hours after Treasury Secretary Steven Mnuchin had broken the news in a tweet (see prior coverage here). The AICPA expressed its thanks to Treasury and the IRS for the filing extension and to its members and the state CPA societies for their outreach to federal legislators and administrators on the issue (see statement here).

The postponement applies to any “individual, a trust, estate, partnership, association, company or corporation” with a federal income tax return or income tax payment due on April 15 (affected taxpayer). Any affected taxpayer receives an automatic postponement of that deadline until July 15. They do not have to file Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, or Form 7004, Application for Automatic Extension of Time to File Certain Business Income Tax, Information, and Other Returns.

Earlier in the week, the IRS had announced a postponement of federal tax payments due April 15. Under that guidance (Notice 2020-17), C corporations and consolidated groups could postpone up to $10 million in tax payments under this relief. All other taxpayers could postpone up to $1 million in tax payments. Notice 2020-18 removes the limitation on the amount of tax that can be postponed and entirely supersedes Notice 2020-17.

Under Friday’s notice, no interest, penalty, or addition to tax for failure to file a federal income tax return or to pay federal income taxes will accrue between April 15, 2020, and July 15, 2020, for any return or payment postponed by the notice.

The IRS is postponing the filing and payment deadlines using its authority under Sec. 7508A, which was triggered on March 13 when President Donald Trump declared the ongoing coronavirus pandemic a national emergency under the Robert T. Stafford Disaster Relief and Emergency Assistance Act, P.L. 100-707.

Friday’s notice applies only to federal income tax returns and payments (including self-employment tax payments) due April 15, 2020, for 2019 tax years, and to estimated income tax payments due April 15, 2020, for 2020 tax years. The notice explicitly does not apply to any other type of federal tax or to any federal information returns. For state tax developments related to the coronavirus outbreak, see the AICPA list here.

Because Notice 2020-17 is superseded, the IRS will not be returning phone calls it received concerning that notice.

For more news and reporting on the coronavirus and how CPAs can handle challenges related to the outbreak, visit the JofA’s coronavirus resources page.

— Alistair M. Nevius, J.D., (Alistair.Nevius@aicpa-cima.com) is the JofA’s editor in chief, tax.

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