Tax filing deadline extended due to COVID-19

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Late on March 20, 2020, the U.S. Treasury Department issued Notice 2020-18, which replaced Notice 2020-17 and implemented announcements by Steve Mnuchin of the U.S. Treasury Department that the tax filing deadline for U.S. federal income tax returns due on April 15, 2020 would be extended to July 15, 2020. Unlike Notice 2020-17, which only applied to certain taxpayers, Notice 2020-18 applies to all persons, including individuals, trusts, estates, partnerships, association, companies or corporations.

Notice 2020-18 grants a 90-day extension to the April 15 due date with respect to filing U.S. federal income tax returns and paying U.S federal income taxes and self-employment taxes (i.e., the filing of U.S. federal income tax returns and the payment of U.S. federal income taxes and self-employment taxes that would otherwise have been due on April 15 are now due on July 15). Notice 2020-18 also provides a 90-day extension to the April 15 due date with respect to the U.S. federal first quarter estimated income tax payment (including the payment of U.S federal income tax on self-employment income) due on April 15 (i.e., U.S. federal estimated income tax payments that would otherwise have been due on April 15 are now due on July 15).

While Notice 2020-18 provides useful guidance, it remains unclear (i) how the tax filing and payment extensions apply to fiscal year taxpayers (rather than calendar year taxpayers) and (ii) whether a similar extension will be provided for the U.S. federal second quarter estimated income tax payment (including the payment of U.S federal income tax on self-employment income) due on June 15.

State income tax deadlines

Since our previous post, a number of additional states have provided guidance regarding their income tax filing and income tax payment deadlines. For example, California, Maryland, and Virginia have provided some form of income tax filing and income tax payment extension.  However, neither Illinois nor Missouri have provided any guidance as of this moment.

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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