U.S. IRS Extends All Tax Deadlines Until 15 July 2020

The Internal Revenue Service acted on 10 April 2020 to greatly expand its earlier filing and payment relief
Notice 2020-23, and Announcement IR-2020-66, extend all income tax deadlines, and many other actions associated with federal taxes, until 15 July 2020.

Previous guidance had extended only the filing and payment deadlines for income tax returns due 15 April. The new guidance extends to 15 July the filing and payment deadlines for any federal income tax return due on or after 1 April, 2020. It also extends the deadlines for a host of other time-sensitive actions taxpayers might be required to take, such as filing claims for refund.

What is Covered

As a result, the following major actions that were not included in the earlier relief are now covered:

  •  Fiscal year income tax returns (that is, returns with a required filing date on or after 1 April, but not due precisely on 15 April)
  •  Estimated tax payments, such as the one due 15 June
  •  Non-profit returns such as Form 990
  •  Filings and payments for Americans who live and work abroad

Essentially, relief is now provided for any income tax-related action required on or after 1 April and before 15 July.

IRS also provided that taxpayers unable to file by 15 July may still request and receive automatic extensions to file until 15 October 2020, but payments will still be due 15 July.

What is Not Covered

Employment tax returns, which remain due 30 April for the first quarter of 2020, and related tax deposits. Note, however, that the CARES Act allows employers to delay payment of the employer portion of employment taxes until 2021 and 2022, and some otherwise required deposits can be recovered as advance Employee Retention Tax Credits or credits for required payments of sick leave.

The report of Foreign Bank Accounts (the FBAR), due to the Treasury Department of Financial Crimes and Enforcement Network (FinCEN) on electronic Form 114 by 15 April 2020. So far as can be determined, FinCEN has not extended the filing due date for these reports.

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How This Impacts Mobility

This welcome action by IRS responds to numerous requests, and will greatly assist Worldwide ERC® members who may experience difficulties in filing returns or paying income tax due to the COVID-19 emergency.

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