On April 9, 2020, the Treasury released Notice 2020-23, further expanding the tax filing and payment relief previously provided to taxpayers in Notices 2020-18 and Notice 2020-20.
The most discussed portion of Notice 2020-23 may be the postponement of estimated tax payments due on or after April 1, 2020, and before July 15, 2020. However, the Notice also expands the definition of an “affected taxpayer” and postpones certain time-sensitive actions required of taxpayers, giving them the opportunity to minimize short-term cash outflow.
The new filing and/or payment deadline of July 15, 2020, applies to the specified payments and forms provided in the Notice, other forms and schedules filed as attachments, and certain elections required to be made on timely filed forms.
Taxpayers that still require an extension beyond the new deadline can file for one before July 15. However, it will not result in an extension beyond the normal extended filing deadline. The extended deadline for calendar year partnerships and S Corporations remains September 15, and October 15 for calendar year individuals and corporations.
Taxpayers have until July 15, 2020, to perform certain time-sensitive actions that were due on or after April 1 and before July 15. These include filing a petition with the Tax Court or review of a decision by the Tax Court, filing a claim for refund or bringing suit upon a claim for refund. Additionally, the 264 time-sensitive acts specified in Rev. Proc. 2018-58 otherwise due during this time period qualify for the postponement.
Key examples of time-sensitive acts postponed by the Notice are listed below:
The IRS itself was also granted a 30-day postponement, much more narrowly focused than what taxpayers received, to perform certain time-sensitive actions on their end. It applies only:
While the delay in tax return filings and tax payments often garners the headlines, taxpayers should be aware of the additional time they may now have to perform certain time-sensitive actions. In some cases, these postponements could serve as another opportunity to supplement short-term cash flow needs or allow the taxpayer more time to decide the best course of action moving forward.
Contact Robert Venables at firstname.lastname@example.org or a member of your service team to discuss this topic further.
Cohen & Company is not rendering legal, accounting or other professional advice. Information contained in this post is considered accurate as of the date of publishing. Any action taken based on information in this blog should be taken only after a detailed review of the specific facts, circumstances and current law.
Receive insights from our specialists in a variety of areas and timely information on upcoming events directly to your inbox as they go live in our online Knowledge Center.