IRS provides details on April 15 postponement

By Alistair M. Nevius, J.D.

On Monday, the IRS issued guidance with details on its postponement of the April 15 tax deadline for individuals (Notice 2021-21). The IRS had announced in a news release on March 17 that it was delaying the April 15 deadline for individuals until May 17, 2021. Monday’s notice clarifies and adds details about the postponement. Like the news release before it, the notice does not extend the April 15 due date for estimated tax payments.

Under the notice, the postponement applies to any individual who files a federal individual income tax return on Form 1040, 1040-SR, 1040-NR, 1040-PR, 1040-SS, or 1040(SP) (the Form 1040 series) or has a federal tax payment reported on one of these forms that would otherwise be due April 15, 2021. The IRS says the postponement also applies to the filing of all schedules, returns, and other forms that are filed as attachments to forms in the Form 1040 series or are required to be filed by the due date of the Form 1040 series. The IRS lists as examples Schedules H and SE, as well as Forms 965-A, 3520, 5329, 5471, 8621, 8858, 8865, 8915-E, and 8938. Also, elections that are made or required to be made on a timely filed form in the Form 1040 series (or attachment to the form) will be considered timely if filed on such form or attachment, as appropriate, on or before May 17, 2021.

The notice also extends the postponement to claims for credit or refund of federal income tax that absent the notice would expire on or after April 15, 2021, and before May 17, 2021 (this generally affects 2017 tax years).

The notice also automatically postpones to May 17 the time for affected taxpayers to make 2020 contributions to their individual retirement arrangements (IRAs and Roth IRAs), health savings accounts (HSAs), Archer Medical Savings Accounts (Archer MSAs), and Coverdell education savings accounts (Coverdell ESAs). The postponement also applies to the time for reporting payment of the 10% additional tax on amounts includible in gross income from 2020 distributions from IRAs or workplace-based retirement plans.

The postponement also applies to individuals who are required to file and furnish Form 5498, IRA Contribution Information; Form 5498-ESA, Coverdell ESA Contribution Information; or Form 5498-SA, HSA, Archer MSA, or Medicare Advantage MSA Information, (the Form 5498 series) that would generally be due June 1, 2021. That deadline is postponed to June 30, 2021.

Taxpayers do not have to file a form, such as Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, to obtain relief under Notice 2021-21. The IRS will disregard the period beginning April 15, 2021, and ending on May 17, 2021, in calculating any interest, penalty, or addition to tax for failure to file the federal income tax returns or to pay the federal income taxes postponed by the notice.

The IRS cautions that the postponement does not apply to any other type of taxpayer or federal tax return.

The IRS also reiterated that it has not extended the April 15, 2021, due date for estimated income tax payments.

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

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