[co-author: Mark Goldsmith]*

In Notice 2020-18, released on March 25, the Department of the Treasury announced that any person with a federal income tax payment or federal income tax return due on April 15, 2020 has until July 15, 2020 to make the payment or file the return. There is no need to file for an extension, and no penalties or interest will be imposed on the delayed payment, without regard to the amount. Notice 2020-18 supersedes the earlier guidance.

The Notice applies only to federal income tax returns – it does not apply to information returns. Presumably, extensions need to be filed for FinCEN 114 (FBAR) filings, and the filing of Forms 3520 that relate to transactions with foreign trusts, and similar forms.

Individuals

Do I have to file my individual federal income tax return for 2019 by April 15, 2020?

No, you have until July 15, 2020 and do not have to file for an extension. There is no penalty for the deferral of the filing.

I think I will owe taxes with my individual federal income tax return for 2019. Do I have to pay them by April 15, 2020?

No, the due date is now July 15, 2020. There is no limit on the amount that can be deferred without penalties or interest.

What if I don’t pay the taxes due until September 15, 2020?

Interest and penalties for late payment will start to accrue from July 16, 2020.

I should have estimated tax payments due on April 15, 2020. How are they impacted?

No penalties will be charged if the payments are made by July 15, 2020.

Will similar rules apply for state and local taxes?

It is completely dependent on the states in which you are required to file income tax returns. For more information on state guidance, see our state-by-state tax summary.

“C” Corporations

Do the same rules for filing the tax returns apply to taxable “C” corporations that have a December 31, 2019 tax year end?

Yes.

Do corporations have a similar extension of time to pay?

Yes.

Will similar rules apply for state and local taxes?

It is completely dependent on the states in which the corporation is required to file income tax returns. For more information on state guidance, see our state-by-state tax summary.

* Partner, Troutman Sanders