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UPDATE: IRS Income Tax Filings and Payments Delayed Three Months

03.23.2020

On March 13, 2020, the President of the United States issued an emergency declaration in response to the COVID-19 pandemic, which allows the Secretary of the Treasury to provide relief from tax deadlines for those that have been adversely affected by the federally declared disaster. For purposes of the IRS Notice described below, those that have been adversely affected by the COVID-19 pandemic include any person with a federal income tax return or payment due on April 15, 2020. A “person” includes an individual, a trust, estate, partnership, association, company or corporation. 

On March 18, 2020, the Treasury issued Notice 2020-17, which postponed the April 15, 2020 federal tax payment deadline until July 15, 2020.  

On March 20, 2020, the Treasury issued Notice 2020-18, which supersedes, and expands the relief provided under, Notice 2020-17.

Under Notice 2020-18, federal income tax returns and federal income tax payments (including payments of tax on self-employment income) due on April 15, 2020 are automatically postponed until July 15, 2020. There is no limitation on the amount of federal income tax payments that may be postponed until July 15, 2020.

This relief is available only for federal income tax returns due on April 15, 2020 and federal income tax payments (including payments of tax on self-employment income) due on April 15, 2020 with respect to the taxpayer’s 2019 taxable year, and federal estimated income tax payments (including payments of tax on self-employment income) due on April 15, 2020 with respect to the taxpayer’s 2020 tax year. No extension is provided under Notice 2020-18 for the payment or deposit of any other type of federal tax or the filing of any federal information return. 

The period beginning April 15, 2020 and ending on July 15, 2020 will be disregarded in calculating any interest, penalties or additions to tax for failure to file income tax returns or pay income taxes postponed by Notice 2020-18. Interest, penalties and additions to tax with respect to such tax returns and taxes will begin to accrue on July 16, 2020 to the extent such tax returns are not filed or taxes are not paid on or prior to July 15, 2020. 

Click here for the IRS FAQ Webpage regarding this topic. 

If you have any questions about this legal update, please do not hesitate to reach out to any of your contact(s) at Morris, Manning & Martin, LLP.