On April 9, 2020, the IRS released Notice 2020-23, which is an update to Notice 2020-18, Additional Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic. This notice provides additional relief to any relief previously granted.
Notice 2020-23 outlines that any person with a Federal tax payment or filing obligation between April 1, 2020 and July 15, 2020 is deemed affected by the COVID-19 emergency and qualifies for relief of the following:
- Individual tax payments and return filings
- Calendar year or fiscal year corporate income tax payments and return filings
- Calendar year or fiscal year partnership return filings
- Estate and trust income tax payments and return filings
- Estate and generation-skipping transfer tax payments and return filings
- Form 706, United States Estate Tax Return
- Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent
- Gift and generation-skipping transfer tax payments and return filings on Form 709, United States Gift Tax Return due on the date an estate is required to file Form 706
- Estate tax payments of principal or interest due as a result of an election made under sections 6166, 6161, or 6163 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
- Quarterly estimated income tax payments for exempt organizations, individuals, and corporations
Automatic relief is provided for all payments and filings listed above until July 15, 2020. For many of these payments and filings, relief had already been granted, but there are a few additions to the list, which are bolded.
All exempt organization filings (Form 990, 990-EZ, 990-N, 990T), as well as private foundation filings (Form 990-PF) have been granted an automatic extension to July 15, 2020.
Additionally, quarterly estimated tax payments have been extended to July 15, 2020. For individuals and calendar year corporations, first quarter estimates were extended with initial relief of April 15 extensions; however, it remained unclear if June 15 extensions would also be extended. Notice 2020-23 provided clarification that no estimated payments are due until July 15, 2020.
If an extension is required past July 15, 2020, the appropriate extension must be filed. However, an additional extension only extends the filing due date. Interest, penalties and additions to tax will not be calculated until July 16, 2020 for all affected payments and filings.
We will continue to keep you updated as additional governmental response to the COVID-19 pandemic is provided.
Contact the professionals at Gilliam Bell Moser if you have any questions.