IRS Provides Details on the Extension of the April 15 Filing Date

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In a series of FAQ’s issued on March 24, the IRS has provided additional information on the extension of the April 15 tax deadline announced in response to the COVID-19 pandemic. As mentioned in a prior tax blog prepared by Dickinson Wright, the IRS has provided an automatic extension to July 15, 2020 of Federal income tax returns and payments that would otherwise be due on April 15. This tax blog highlights a few of the FAQ’s that may be of interest to individuals and sponsors of retirement plans.

  • Individuals or businesses that have a Federal income tax filing that would otherwise be due on April 15 do not need to file an extension form to take advantage of the automatic extension to July 15.
  • Contributions to individual retirement accounts (IRAs) made on or before July 15 may be designated as a contribution for the 2019 tax year.
  • Contributions to health savings accounts (H.S.A.s) made on or before July 15 may be designated as a contribution for the 2019 tax year.
  • An individual’s first quarter 2020 estimated income tax payment has been postponed from April 15 to July 15, 2020. However, the second quarter 2020 estimated tax payment is still due on June 15, 2020.
  • Unrelated business income tax returns (Form 990-T) that are due on April 15 have been granted an automatic extension to July 15. Calendar year retirement plans and IRAs that have $1,000 or more of unrelated trade or business gross income (usually from investments in partnerships) are required to file IRS Form 990-T.
  • Employers with an April 15 Federal income tax due date now have until July 15 to make contributions to their retirement plans for their prior tax year.
  • Payroll and excise tax returns due April 15 have not been extended.
  • Information returns, such as IRS Form 5500, due April 15 have not been extended, although an extension may be requested using IRS Form 5558.
  • ACA information returns, on IRS Form 1095-C and 1094-C due March 31 for electronic filers, have not been extended, although a 30-day automatic extension will be granted by filing Form 8809 before March 31.
  • Gift tax returns (IRS form 709) due April 15 have not been extended, although an extension can be requested using IRS Form 8892.
  • Estate tax returns (IRS form 706) due April 15 have not been extended, although an extension can be requested using IRS Form 4768.
  • The April 15 deadline for removing 2019 excess elective deferrals from an employer’s retirement plan has not been extended.
  • Taxpayers who have filing or payment due dates other than April 15 have not been granted relief at this time.

The IRS relief does not apply to state tax filings and payment deadlines which vary from state to state. Taxpayers should check with their individual state tax agencies for details of any extension.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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