IRS Extends Many More Deadlines Until July 15, 2020

In the afternoon of April 9, 2020, the IRS issued Notice 2020-23. In this notice, the IRS extends many more tax deadlines to cover a wide array of tax return filers, forms, payments, and actions. This is the third and most comprehensive “due date” postponement notice that the IRS has issued within the last month, as part of its response to the COVID-19 pandemic. Notice 2020-23 expands on the prior two notices.

Notice 2020-23 applies to all taxpayers that have a filing or payment deadline falling on or after April 1, 2020, and before July 15, 2020, including individuals, trusts, estates, corporations, and other noncorporate tax filers. The same period will be disregarded by the IRS in calculation of any interest, penalty, or addition to tax for failure to file the forms specified in the notice.

We touch on a few items that have generated the most questions at HM&M and that are addressed in Notice 2020-23.

Before Notice 2020-23, there was no relief from paying second quarter estimated payments normally due on June 15 for calendar year taxpayers. For most taxpayers, the first quarterly payment and any tax due for 2019 have been delayed to July 15, 2020. Notice 2020-23 extends the time for paying second quarter estimates until July 15, 2020.

There are a number of “special” forms that must be filed by the due date of the tax return. Foreign disclosure forms are examples of such forms. Most of such forms are filed with the taxpayer’s income tax return. However, the requirement to file such forms is not necessarily bound to filing a tax return; the requirement to file these forms is separately stated. Stout fines can be levied by the IRS, if such forms are not timely filed. Notice 2020-23 extends the time to mirror the filing relief for tax returns due on April 15, 2020, generally an extension to July 15, 2020, not considering a timely filed automatic extension request.

While there might be some few tax returns, forms, schedules, or payments due that “fell through the crack” of this and prior extension notices, it appears that the IRS was trying to include them all.

The relief is automatic for affected taxpayers. They do not have to file extensions or send documents to obtain relief.

COVID-19 has made it difficult for IRS employees to access documents, systems, and other resources due to office closures. The notice gives the IRS additional time (usually an extra 30 days) to perform certain time-sensitive acts.

We have included a link below to the entire and comprehensive Notice 2020-23.

IRS: Notice 2020-23

If you have any questions, please contact your HM&M advisor.

For more information check out HM&M’s COVID-19 Resources page.

HM&M COVID-19 Resources