In Notice 2020-18, IRS has made official the earlier announcement by Treasury Secretary Mnuchin that the filing and payment deadline for 2019 federal income tax returns and 2020 federal income tax estimates that would otherwise be due on April 15, 2020, has been postponed to July 15, 2020. Unlike the payment deadline relief announced last week, there is no cap on the amount of payments that may be postponed under this new relief.
Background
On March 18, 2020, IRS issued Notice 2020-17 which postponed the due date for certain Federal income tax payments from April 15, 2020 until July 15, 2020. On March 20, 2020, Treasury Secretary Steven Mnuchin announced, via a tweet, that he was “moving Tax Day from April 15 to July 15. All taxpayers and businesses will have this additional time to file and make payments without interest or penalties.”
IRS Issues Official Guidance
IRS has now made official the March 20 announcement by the Treasury Secretary that postpones until July 15, 2020, the filing date for 2019 federal income tax returns and 2020 federal income tax estimates that would otherwise be due on April 15, 2020.
Any person with a Federal income tax payment or a Federal income tax return due April 15, 2020 is an “Affected Taxpayer.” The term “person” includes an individual, a trust, estate, partnership, association, company or corporation, as provided in Code Sec. 7701(a)(1).
For an Affected Taxpayer, the due date for filing Federal income tax returns and making Federal income tax payments due April 15, 2020, is automatically postponed to July 15, 2020. Affected Taxpayers do not have to file Forms 4868 or 7004 to obtain this relief.
The relief provided is available solely with respect to Federal income tax payments (including payments of tax on self-employment income) and Federal income tax returns due on April 15, 2020, in respect of an Affected Taxpayer’s 2019 tax year, and Federal estimated income tax payments (including payments of tax on self-employment income) due on April 15, 2020, for an Affected Taxpayer’s 2020 tax year.
No extension is provided in the Notice for the payment or deposit of any other type of Federal tax or for the filing of any Federal information return. As a result of the postponement of the due date for filing Federal income tax returns and making Federal income tax payments from April 15, 2020, to July 15, 2020, the period beginning on April 15, 2020, and ending on July 15, 2020, will be disregarded in the calculation of 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 this notice. Interest, penalties, and additions to tax with respect to such postponed Federal income tax filings and payments will begin to accrue on July 16, 2020.
No limit on amount of payment that can be postponed. Notice 2020-17, issued earlier last week, put limits on the amount of tax payments that could be postponed from April 15 until July 15. The new Notice amends that rule to provide that there is no limitation on the amount of the payment that may be postponed.
Prior guidance superseded. The new Notice supersedes Notice 2020-17. Because of the expansion of relief provided in the new Notice and the fact that Notice 2020-17 is superseded, any phone calls to IRS regarding Notice 2020-17 that have not already been returned will not be returned.
To continue your research on extension of tax-related deadlines for taxpayers affected by disasters, see FTC 2d/FIN ¶ S-8502; United States Tax Reporter ¶ 75,08A4.
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