The United States Department of the Treasury and Internal Revenue Service (“IRS”) released Notice 2020-23, further expanding the filing and payment relief provided under Notices 2020-18 and 2020-201 to taxpayers affected by COVID-19 (“Affected Taxpayers”). Any person (including individuals, trusts and estates, partnerships, associations, companies or corporations) with a federal tax payment or federal tax return or other form due on or after April 1, 2020 and before July 15, 2020, has an automatic extension to July 15, 2020 to make such payment or filing.
This relief now extends the following:
- Estate and trust income tax payments and return filings on Form 1041, United States Income Tax Return for Estates and Trusts (including Forms 1041-N and 1041-QFT).
- Estate and generation-skipping transfer tax payments and return filings on Form 706, United States Estate (and Generation-skipping Transfer) Tax Return (including Forms 706-NA, 706-A, 706-QDT, 706-GS(T), 706-GS(D) and 706-GS(D-1)).
- Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent and any supplemental Form 8971.
- Estate tax payments of principal or interest due as a result of an election made under Sections 6166, 6161, or 6163 of the Internal Revenue Code (“IRC”), and annual recertification requirements under Section 6166.
- Exempt organization business income tax and other payments and return filings on Form 990-T, Exempt Organization Business Income Tax Return.
- Excise tax payments on investment income and return filings on Form 990-PF, Return of Private Foundation (including Form 4720).
- Calendar year or fiscal year corporate income tax payments and return filings on Form 1120, United States Corporation Income Tax Return (including Forms 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-S, 1120-SF).
- Calendar year or fiscal year partnership return filings on Form 1065, United States Return of Partnership Income and Form 1066 for U.S. Real Estate Mortgage Investment Conduit Income Tax Return.
estimated income tax payments calculated on or submitted with Form 1040-ES, Estimated Tax for Individuals, Form 1041-ES, Estimated Income Tax for Estates and Trusts, Form 1120-W, Estimated Tax for Corporations (also applies to Forms 1040-ES (NR), 1040-ES (PR), and 990-W).
- Any time-sensitive action listed in Section 301.7508A-1(c)(1)(iv)-(vi) of the Procedure and Administration Regulations or Revenue Procedure 2018-58 (including Form 5227).
If additional time to file beyond the July 15th deadline is needed, Affected Taxpayers may file the appropriate extension form by July 15, 2020 to obtain such extension, however, that extended date may not go beyond the original statutory or regulatory extension date. The extension to file after July 15, 2020 does not extend the payment of tax after July 15, 2020.
This relief also extends the time for filing all petitions with the Tax Court or for review of a decision rendered by the Tax Court, filing a claim for credit or refund of any tax, and bringing suit upon a claim for credit or refund of any tax, that was due on or after April 1, 2020 and before July 15, 2020, to July 15, 2020 to
perform such action.
1Notice 2020-18 was issued on March 20, 2020, superseding Notice 2020-17 and postponing the filing and payment date of April 15, 2020 to July 15, 2020 for Federal income tax returns. Notice 2020-20 was issued on March 27, 2020, amplifying Notice 2020-18 and postponing the filing and payment date of April 15, 2020 to July 15, 2020 for Federal gift (and generation-skipping transfer) tax returns.
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