On March 20, 2020, the IRS issued Notice 2020-18 (the “Notice”) which provides that the due date for making tax payments and for filing federal income tax returns is automatically extended from April 15, 2020 to July 15, 2020.
Under the Notice, any person with a Federal income tax payment or an income tax return due on April 15, 2020 is deemed “affected” by the COVID-19 virus and therefore treated as an “Affected Taxpayer” eligible for relief. All Affected Taxpayers, can defer payments due April 15, 2020 until July 15, 2020, without penalties and interest, and regardless of the amount owed or the number of filings to be postponed. This relief applies to all taxpayers including those who pay self-employment tax.
The relief provided under Notice 2020-18 also applies all federal income tax payments (including self-employment income) and tax returns due for the 2019 taxable year, as well as estimated tax payments (and self-employment income tax) due on April 15, 2020 for the taxpayer’s 2020 tax year. No extension is provided for the payment or deposit of any other type of federal tax or the filing of any federal information return.
The period of April 15, 2020 until July 15, 2020 will be disregarded in the calculation of any interest, penalty or addition to tax for the failure to file federal tax returns or the failure to pay federal income taxes postponed by this notice. All deferred interest, penalties and additions to tax will begin to accrue on July 16, 2020.
The extension is automatically granted by the government, therefore, taxpayers do not need to file any additional forms or call the IRS in order to qualify for relief. Individual and business taxpayers who may need additional time beyond the July 15, 2020 deadline may request a filing extension as they would in the ordinary course of business by filing Form 4868 (individuals) or Form 7004 (businesses). Individuals who are due a refund are urged to file as soon as possible and to file electronically.
After the publication of Notice 2020-18, taxpayers and tax practitioners alike had a number of open questions regarding the application and implementation of the relief. On Wednesday, March 25, 2020, the Internal Revenue Service published a Filing and Payment Deadlines Q&A to provide answers to help clarify open questions regarding the extension. The following clarifications were provided:
Filing and Paying 2019 Taxes and Q1 2020 Estimated Taxes
Individual Retirement Accounts (IRAs) and Workplace-based Retirement Plans
Health Savings Accounts (HSAs) and Archer Medical Savings Accounts (MSAs)
In response to the national emergency and to protect employees, taxpayers, communities and others, the IRS has temporarily closed all Taxpayer Assistance Centers and discontinued face-to-face service throughout the country until further notice. The IRS is continuing to process tax returns, issue refunds and help taxpayers to the greatest extent possible.
 The term person includes an individual, trust, estate, partnership, association, company or corporation as such term is defined in section 7701(a)(1) of the Internal Revenue Code of 1986, as amended.