Armanino Blog

Filing Deadlines Are Upon Us … or Are They?

April 14, 2020

Here, you'll find a quick reminder and recap of recent events to assist you in your tax extension and payments requirements.

The IRS and Treasury Department significantly expanded relief measures for tax return filings and payments in response to the coronavirus pandemic. Notice 2020-23 stipulates all taxpayers with a filing or payment deadline falling on or after April 1, 2020 have until the revised due date of July 15, 2020 to file returns and make payments without penalties or interest. Included in the relief measure were corporations (including pass-through), individuals, trusts and estates, whether calendar- or fiscal-year filers.

While Notices 2020-18 and 2020-20 established the relief measures in payment due dates and filing due dates, in Notice 2020-23, the IRS identified specific forms and payments subject to relief. The Notice listed "time-sensitive actions" and specific forms listed in Revenue Procedure 2018-58, which effectively postponed the deadline for most actions required to be taken by taxpayers from April 1 through July 14, until July 15. Expanding relief measures to forms identified in Revenue Procedure 2018-58 but not highlighted in the first two Notices issued in 2020 (-18 and -20), included forms 990, 1041-A, 4466 and 5227.

Notice 2020-23 specifically extends the payment and filing deadlines for the following forms:

  • Form 1120 and related filings (1120, 1120-C, 1120-F, 1120-FSC, 1120-PC, 1120-REIT, 1120-S, 1120-SF and other 1120 forms)
  • Forms 1065 and 1066
  • Form 1040 and related filings (1040, 1040-NR, 1040-NR-EZ, 1040-PR and other 1040 forms)
  • Form 1041 and related filings (1041, 1041-N and 1041-QFT)
  • Forms 1065 and 1066
  • Form 706 and related filings (706, 706-NA, 706-A, 706-QDT, 706-GS(T), (D), D-1)
  • Form 709
  • Form 8971
  • Forms 990-T and 990-PF

Notice 2020-23 also extends filing and payment deadline relief to the following tax forms and matters:

  • All schedules, returns and other forms that are filed as attachments to the specified forms
  • Elections that are made or required to be made on a timely filed specified form
  • Estimated quarterly tax payments due from April 1 through July 14
  • Filing a petition with the Tax Court
  • Appealing a decision by the Tax Court
  • Filing a claim for credit or refund of any tax
  • Bringing suit upon a claim for credit or refund of any tax

We're here to help

We're closely monitoring the many changes related to COVID-19, and we will send out updates as they become available. Reach out to our Rapid Response Team experts if you need further information on this topic.

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