IRS - Guidance from Yeo & Yeo

IRS Extends More Tax Filing Deadlines

CPAs & Advisors

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The IRS issued Notice 2020-23Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic, an update to Notice 2020-18. The notice extends more tax deadlines to cover individuals, trusts, estates, corporations and others. The following is a summary of the key points.   

The following tax returns (including all schedules and forms required to be attached) and payments, with an original due date between April 1, 2020, and July 15, 2020, are automatically extended to July 15. An extension form is not required, nor should taxpayers contact the IRS.
  • Individual tax returns Form 1040 series, including Nonresident Alien returns
  • Corporate returns 1120, 1120S
  • Partnership returns 1065
  • Estate and trust returns 1041
  • Estate tax returns 706
  • Gift tax returns 709
  • Exempt organization business income tax Form 990-T
  • Private Foundation Returns Form 990-PF
  • Quarterly estimated tax payments that are submitted on 990-W, 1040-ES, 1041-ES, 1120-W. Note: This now includes the first and second quarters.
Frequently Asked Questions
Q: Has the FBAR due date been extended? 
A: Not specifically; however, the instructions for the FBAR allow for an automatic extension of time to October 15. 
Q: If I need additional time to file a return after July 15, do I need to file an extension? 
A: Yes, by July 15. For example, a 2019 Form 1040 that will not be prepared until October 15 will need to have an extension filed by July 15, 2020 (originally, it was thought this extension would have to be filed by April 15).
Q: How does this automatic extension apply to tax elections in general? 
A: The IRS has determined that the period of April 1, 2020, to July 15, 2020, is the Specified Time-Sensitive Action period. Any requirements to file elections that would normally be due during this period are now due July 15.
Q: Are due dates for filing for credits, refunds, petitions to the Tax Court, and responses to decisions rendered by the Tax Court extended as well? 
A: Yes, as long as the original due date was not before April 1, 2020.
Q: How will the extended due date affect penalties and interest? 
A: The period from April 1, 2020, to July 15, 2020, will be disregarded in the calculation of any interest penalty, or addition to tax, for failure to file. 
Q: I owe tax for 2019 and have been accruing penalties and interest. Should I pay something by April 15 or can I wait until July 15?
A: You could wait until July 15, as the period from April 1, 2020, to July 15, 2020, will be disregarded for penalty and interest calculations.  Penalties and interest accrued before April 1 will still be applicable and due July 15.
Q: I am being audited and the IRS is requesting documents by a due date that falls within the range of April 6 to July 15, 2020. Is that due date still applicable? 
A: No. There is a 30-day postponement granted for actions with a due date in that range.
Q: Are 990, 990-N, and 990-EZ returns due May 15 extended to July 15 as well?
A: Yes, the IRS extended to July 15 all Form 990-series annual information returns or notices that have filing payment deadlines falling on or after April 1, 2020 and before July 15, 2020.  
For more information, visit Yeo & Yeo’s COVID-19 Resource Center, which is updated continually, or contact your Yeo & Yeo professional.

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