About
Foundational Principles In the Community Diversity, Equity & Inclusion Technical Excellence Alumni TIAG Membership
Careers
Why Cohen & Company Our Culture Total Rewards & Benefits Intern & Entry Level Opportunities Experienced Opportunities
Contact
Akron, OH Baltimore, MD Chicago, IL Cleveland, OH Detroit, MI Milwaukee, WI New York, NY Philadelphia, PA Pittsburgh, PA St. Clair Shores, MI Youngstown, OH
Client Portal
Services Industries Knowledge Center People

About Our Services

We offer tailored solutions — whether private company or owner; public or private fund, adviser or fund service provider; or Fortune 1000 enterprise. Learn how we can help you.

Learn More

Assurance Services

Employee Benefit Plan Audits Internal Controls Investment Company Audits Private Company Audits SOC Readiness & Compliance

Tax Services

Federal Tax Planning & Compliance High Net Worth & Wealth Transfer International Filings & Structuring Investment Company Tax State & Local Tax Tax Credits & Incentives Transaction Tax Planning

Advisory Services

Business Valuations Data & Insights Digital Finance Solutions IT Strategy & Implementation M&A Advisory Outsourced Accounting Solutions Risk Assurance & Advisory Transaction Services Turnaround & Restructuring

Our Industry Expertise

Our industry experience means you can find professionals who speak your language and bring earned insights to the table. Learn how we can help you.

Learn More

Key Industries

Digital Assets Investment Companies Manufacturing Private Companies Private Equity Real Estate & Construction Technology & Life Science
VIEW THE COMPLETE LIST

Knowledge Center

Our team wants to help your team stay up to date. Browse our thought leadership, events and news for insights and a point of view on business-critical topics.

Learn More

Insights

Browse valuable articles and publications our experts have written to help you and your organization answer key questions — and consider new ones.

Read Our Insights

Events

Join us in person and online for events that address timely topics and key business considerations.

Explore Our Events

News

Find out what is happening at Cohen & Company, from industry recognitions and growth updates, to where we are contributing to important media stories.

Read Our News
People
Foundational Principles In the Community Diversity, Equity & Inclusion Technical Excellence Alumni TIAG Membership
Why Cohen & Company Our Culture Total Rewards & Benefits Intern & Entry Level Opportunities Experienced Opportunities
Akron, OH Baltimore, MD Chicago, IL Cleveland, OH Detroit, MI Milwaukee, WI New York, NY Philadelphia, PA Pittsburgh, PA St. Clair Shores, MI Youngstown, OH
Client Portal
Back to Insights

Treasury Postpones Estimated Tax Payments and Other Time Sensitive Actions in Further Response to COVID-19

by Robert Venables

April 14, 2020 Federal Tax Planning & Compliance, Investment Company Tax

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.

Which Forms and Payments Are Postponed?

  • Quarterly estimated tax payments (Forms 990-W, 1040-ES, 1041-ES and 1120-W)
  • Individual income tax return and payment (Forms 1040, 1040-NR and various other 1040 series returns)
  • Corporate income tax return and payment (Forms 1120, 1120-F, 1120-REIT, 1120-RIC, 1120-S and various other 1120 series returns)
  • Partnership tax return (Forms 1065 and 1066)
  • Estate and trust income tax return and payment (Forms 1041, 1041-N and 1041-QFT)
  • Estate and GST tax return and payment (Forms 706 and various other 706 series returns, Form 8971)
  • Gift and GST tax return and payment (Form 709)
  • Estate tax payments of principal or interest due as a result of an election under Sections 6166, 6161 or 6163 and annual recertification requirements under Section 6166
  • Exempt organization business income tax and payment (Form 990-T)
  • Excise tax return and payment (Forms 990-PF and 4720)

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.

Which Time Sensitive Actions Are Postponed?

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:

  • 180-day period to invest in a Qualified Opportunity Zone
  • 45-day identification and 180-day exchange periods under Section 1031
  • Form 3115 for non-automatic accounting method changes for fiscal years ending April, May or June
  • Contributions to a qualified retirement plan, a simplified employee pension or a SIMPLE IRA
  • Elections under Sections 1361 and 1362 related to ESBT, QSST, QSUB and S Corporations

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:

  • If the IRS’ last day for performance of the action is on or after April 6, 2020, and before July 15, 2020, and
  • To taxpayers who are under examination, have cases in the appeals process or are filing amended returns.

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 rvenables@cohencpa.com 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.

About the Author

Robert Venables, CPA, JD, LLM

Director, Tax
rvenables@cohencpa.com
330.255.2135

Sign Up for Our Emails & Events

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.

Subscribe Today
Subscribe to our newsletter
About Contact Submit RFP Privacy Policy
LinkedIn Twitter Facebook
© 2023 Cohen & Company