U.S. Extends Individual and Business Tax Filing Deadline to July 15

In response to U.S. Treasury Secretary Steven Mnuchin’s March 20, 2020 announcement on Twitter that the U.S. will extend the tax filing deadline for 2019 individual and business tax returns, the Internal Revenue Service issued Notice 2020-18 in support of such measures.

Notice 2020-18 provides that the due date for filing Federal income tax returns and making federal income tax payments due April 15, 2020 (including 2020 first quarter estimated payments) is automatically postponed until July 15, 2020. Notice 2020-18 supersedes Notice 2020-17, issued earlier this week, in which the Internal Revenue Service announced that the payment deadline for any 2019 individual income tax due April 15, 2020 was deferred until July 15, 2020.

Notice 2020-18 expressly provides that the relief applies to any individual, estate, partnership, association, company, or corporation with a federal income tax payment or federal income tax return due April 15, 2020.  Affected taxpayers are not required to file Form 4868 (Application for Automatic Extension of Time to File U.S. Individual Income Tax Return) or Form 7004 (Application for Automatic Extension of Time to File Certain Business Income Tax, Information, and Other Returns) in order to take advantage of the relief. There is no limitation on the amount of the payment that may be postponed.  The relief also expressly applies to payments of tax on self-employment income. 

Although many states follow the federal individual income tax return filing dates, we caution you to check the state filing dates that apply to you. For a summary of current filing and payment relief at the state level, please consult the information compiled by the AICPA here. 

Notice 2020-18 does not expressly provide that the relief applies to filing U.S. Gift Tax Returns (Form 709) that are due on April 15, 2020. Absent further guidance, taxpayers who do not plan to timely file Form 709 by April 15, 2020 should plan to file Form 8892 (Application for Automatic Extension of Time To File Form 709 and/or Payment of Gift/Generation-Skipping Transfer Tax) by April 15, 2020 to request an automatic six-month extension of time to file Form 709.

Notice 2020-18 does not grant, at this time, an extension of time to file Form 990 (Return of Organization Exempt from Income Tax), Form 990-EZ (Short Form Return of Organization Exempt from Income Tax), Form 990-N (Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required to File Form 990 or Form 990-EZ), or Form 990-PF (Return of Private Foundation or Section 4947(a)(1) Nonexempt Charitable Trust Treated as a Private Foundation) for tax-exempt organizations required to file these returns on May 15, 2020. 

Finally, Notice 2020-18 does not address whether taxpayers are entitled to an extension of time to make contributions to their individual retirement accounts (IRAs) for 2019. Ordinarily, such contributions must be made by April 15 of the year following the calendar year in respect of which such contributions are made. For the 2019 calendar year, those contributions must otherwise be made by April 15, 2020 absent additional guidance by the Internal Revenue Service.