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So You Think the IRS Extended All April 2020 Deadlines? Think Again. **And Again.**

By Anthony P. Daddino on March 24, 2020

This blog post has been updated to reflect updated FAQs released by the IRS and IRS Notice 2020-20. You can view the FAQs by following this link:  https://www.irs.gov/newsroom/filing-and-payment-deadlines-questions-and-answers.

In IRS Notice 2020-18, the IRS automatically extended the April 15, 2020 due date for federal income tax returns and federal income tax payments to July 15, 2020. The IRS made clear, however, that “no extension” is provided for the payment or deposit of any other Federal tax or the filing of any other Federal return.   So what stays on the April 2020 to-do list?  

Although not an exhaustive list, below is a checklist of some of the major returns and payments that have not been extended:

  • *CHANGE* In IRS Notice 2020-20, the IRS automatically extended until July 15, 2020 both the due date for filing Form 709 and for the payment of any federal gift or GST tax.
  • Whether the taxpayer is a weekly, monthly or quarter depositor, the due date for the deposit of payroll taxes is unaffected by the IRS’ extension of the deadline for income tax returns and payments.
  • Business taxpayers must still file Form 941 for the first quarter of 2020, and pay any payroll taxes due, by April 30, 2020.
  • *CHANGE* New FAQs make clear that the deadline to make a contribution to a traditional IRA, Roth IRA, and Health Savings Account for the 2019 tax year is extended until July 15, 2020.
  • Although not an annual filing with an April due date, the IRS has not extended the filing or payment due date of any Form 706 estate tax return.   
  • Finally, the IRS did not extend the due date to file an annual return to report transactions with foreign trusts and the receipt of foreign gifts.  These are reportable on Form 3520, which has a due date of April 15, 2020.  Taxpayers may apply for a six-month extension.

For those of you worried about FBAR filings, there is no need for concern.   Even before this COVID-19 crisis, the IRS made available an automatic extension of the April 15 due date until October 15 and no request for extension is required.   With respect to other international returns such as Form 5471 (Foreign Corporations), Form 5472 (Foreign-owned US Corporations), and Form 8865 (foreign partnerships), the IRS has not expressly addressed the due date of these forms.  Because such forms are filed with the taxpayer’s income tax return, however, the due date is presumptively extended until July 15, 2020. 

*CHANGE* The IRS has recently addressed fiscal year taxpayers, but in a rather arbitrary and limited way.  If the original or extended due date for a fiscal year taxpayer is April 15, the due date is extended until July 15, 2020.  For all other fiscal year taxpayers, the IRS has expressly denied them relief, stating unequivocally:   “Any taxpayers who have filing or payment due dates other than April 15 have not been granted relief at this time.”  Also, the IRS has now provided relief with respect to the IRC Sec. 965 transition tax, stating:  “For any taxpayer whose Federal income tax return filing due date has been postponed from April 15 to July 15, 2020, the due date of that taxpayer’s section 965 installment payment has also been postponed to July 15, 2020.”

What about any refund due dates landing on April 15, 2020?   The IRS says tough luck.  Any deadline that falls on April 15th relating to a refund is not extended.

We will continue to update this blog post as new information becomes available.

If you have any questions about this blog post or any other tax-related matter, please do not hesitate to contact me at (214) 749-2464 or adaddino@meadowscollier.com.