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IRS issues New Guidance on April 15, 2020 Filing Requirements

March 21, 2020

As a result of the Coronavirus Pandemic, the IRS has invoked the powers available when there is a Federally-declared disaster to provide relief from April 15 income tax filing and payment obligations.  On March 20, the IRS issued guidance providing relief for taxpayers who have an income tax return due on April 15, owe 2019 taxes due on April 15, 2020, or are required to make 2020 first quarter estimated payments on April 15, 2020. This guidance supersedes the guidance in Notice 2020-17, issued on March 18, 2020.

The IRS guidance (Notice 2020-18) provides:

Extension of income tax filing deadlines:   The due date for income tax returns for taxpayers who have a tax return due on April 15, 2020 is automatically postponed until July 15, 2020. This includes returns for individuals, trusts, estates, partnerships, associations, corporations.

Extension of income tax payment deadlines: Taxpayers who owe 2019 income tax or are responsible for first quarter 2020 estimated income tax payments, all of which are due on April 15, can postpone payments on any amount of income tax due until July 15, 2020. Interest and penalties will be waived on payments due April 15, 2020.

  • All taxpayers taking advantage of this relief should plan to pay their balance in full by July 15.  
  • Second quarter 2020 estimated tax payments due on June 15, 2020 are not affected by this guidance and, at this time, are still due on June 15.
  • There is no relief for late payment of gift or GST tax, estate taxes, or any other tax owed on April 15. 
  • Refunds are currently being processed by the IRS.  Taxpayers due a refund should file as soon as possible.  

A note about state taxes: The IRS guidance does not provide relief for state income taxes owed or delay of state income tax filing deadlines. As of this writing:

  • The Oklahoma Tax Commission has adopted the IRS guidance, delaying the due date for filing and payments of state income taxes until July 15. 
  • Colorado has not issued official guidance, but Governor Polis announced he would defer the deadline for 2019 income tax filing and payment to July 15.
  • As of March 20, Arkansas is still considering whether or not to adopt the IRS guidance and has not changed its filing or payment requirements.
  • State tax filing and payment relief may vary and is subject to change, so check for updates from your state.
  • Check with local authorities for extensions applicable to the filing of any sales or use tax returns, excise tax returns, or any other taxes.  The AICPA has a useful reference guide available here.

The IRS has issued FAQs regarding this notice, which are available HERE.

Update on gift tax return filing deadlines:  On March 27, 2020, the IRS issued Notice 2020-20, providing for an extension of time until July 15, 2020 to file 2019 Form 709, U.S. Gift and Generation-Skipping Transfer Tax Return, and to pay related taxes.  Taxpayers needing additional time beyond July 15 to file Form 709 will need to file an extension on Form 8892 by July 15, 2020.  However, gift and generation-skipping transfer taxes are due on July 15, 2020 and penalties and interest will be incurred for payment of any tax due with Form 709 that is paid after July 15, 2020.  

 

Contact a Hall Estill Tax attorney if you have any questions about how these tax provisions may impact you.