IRS Extends Tax Return Filing Date

New due date is July 15

Just days after issuing guidance deferring the payment of certain tax obligations but maintaining the April 15 tax filing deadline, the IRS has changed course and announced in Notice 2020-18 that it is indeed extending the April 15 tax filing deadline.

Specifically, for any “person” with a federal income tax payment or a federal income tax return due April 15, 2020, the due date for filing and making such payments is automatically postponed to July 15, 2020.  (“Person” includes an individual, trust, estate, partnership, association, company or corporation.)  Affected taxpayers do not have to file extensions (Forms 4868 or 7004).  Unlike the initial advice from the IRS, there is no limitation on the amount of the payment that may be postponed. 

This relief 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 a taxpayer’s 2019 taxable year and Federal estimated income tax payments (including payments of tax on self-employment income) due on April 15, 2020 for the taxpayer’s 2020 taxable year.  No extension is provided for the payment or deposit of any other type of federal tax or for the filing of any federal information return. 

As relates to interest and penalties -- 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 the Notice.  Interest, penalties and additions to tax with respect to the postponed federal income tax filings and payments will begin to accrue on July 16, 2020.

A few observations –

• This Notice does not cover estimated income tax payments due on June 15, 2020. The status of June 15 estimated income tax payments could change through future IRS action or federal legislation.
• The impact of this Notice on the filing of 2019 federal gift tax returns is unclear. Clarification is required. 
• It is unclear to what extent the various states will conform their tax filing and payment schedules to those of the IRS. This will likely evolve quickly over the upcoming days.

We will keep you informed of new tax developments as government addresses this evolving coronavirus pandemic.