Pullman & Comley - Labor, Employment and Employee Benefits Law

The simple and safe answer to the question posed is “April 15, 2020.”  Contributions to traditional and Roth Individual Retirement Accounts (“IRAs”) and Health Savings Accounts (“HSAs”) must be made no later than “the time prescribed by law for filing the return for such taxable year (not including extensions thereof)”. See Code Section 219(f)(3).  For most taxpayers eligible to make these contributions, this usually means April 15th whether or not an extension to file the Federal income tax return has been requested.

COVID-19 has impacted many aspects of our lives including the timing for filing and paying Federal and Connecticut income tax returns for 2019.  The IRS issued Notice 2020-18 on March 20, 2020, announcing “the due date for filing Federal income tax returns and making Federal income tax payments due April 15, 2020, is automatically postponed to July 15, 2020.”  The postponement of the due date would seem to indicate that the last date for making IRA or HSA contributions is July 15, 2020. But this may not be the case. The April 15th filing date for Federal Income tax returns is a statutory requirement.  Generally, the IRS does not have authority to change statutory provisions.  In the absence of further guidance, it is not clear whether Notice 2020-18 merely granted taxpayers an automatic extension of the statutory due date rather than a true postponement of the statutory due date. In fact, informal emails from individuals with close contacts at the IRS indicate that the IRS interprets Notice 2020-18 as granting everyone an extension.  These same individuals indicate that IRS has been made aware of the issue concerning the IRA contribution deadline date and is likely to issue guidance explicitly granting an automatic extension of the deadline for making 2019 IRA contributions to July 15, 2020.  Until this guidance is issued, making contributions to IRAs and HSAs by April 15, 2020 is the safe bet.

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