IRS Filing Deadline Extension

Updated March 23, 2020 at 10:00 a.m.

On Friday, the Treasury Department issued Notice 2020-18 announcing that the filing deadline for taxpayers would be postponed from April 15th to July 15th to match the deferral of tax payments that was announced earlier in the week with Notice 2020-17. This will allow taxpayers filing form 1040 and form 1120 to defer filing and paying taxes without incurring penalties and interest until July 15, 2020. Extension forms 4868 and 7004 are not required as a result of this new notice and Notice 2020-18 supersedes previously filed Notice 2020-17.

As a reminder of the guidance issued earlier last week, the deferral of payments applies to "any person with a Federal income tax payment due April 15, 2020" and allows for the postponement of Federal income tax payments until July 15, 2020. Under Notice 2020-18, there is no limitation on the amount of the payments that may be postponed. Previously, payments were limited to $1M for individual taxpayers and $10M for corporate taxpayers. This payment relief applies solely to Federal income tax payments (including payments of tax on self-employment income) due on April 15, 2020 and includes amounts due with respect to 2019 returns as well as first quarter 2020 estimated tax payments. The second quarter estimated tax payments are still due June 15, 2020 at this time. The notice is a postponement and not an extension, so it appears to delay the date to make contributions to retirement plans (IRA, SEP, Simple, etc.) and health savings accounts to July 15th as well. We are closely watching this and will update as additional guidance is available.

The Iowa Department of Revenue executed an order on March 19th extending the filing and payment deadline for several state tax types. The extensions applied to any Iowa tax returns and any associated tax due on those returns if the due date is on or after March 19, 2020 and before July 31, 2020. The due date for these tax returns and taxes is now July 31, 2020. Please visit our guidance from March 19th here for those tax types the relief applies to.

Given the workplace disruption of COVID-19, we plan to prepare significantly less tax returns between today and April 15th. The amount of time available to devote to tax returns over the next few weeks will be greatly diminished, and we anticipate finalizing most returns after the traditional April 15th deadline. Please reach out to your engagement team if you have an urgent need for the completion of your returns. We will be attempting to focus on tax returns that have refunds due first.

We continue to monitor the Senate stimulus bill known as the Phase 3 Coronavirus Response and will be reaching out when the final legislation is passed.