On March 27, 2020, the IRS published Notice 2020-20, which expands relief provided previously in Notice 2020-18. The notice extends the due date for Form 709, (Gift and Generation Transfer Skipping Tax Return), as well as the date for making payments of Federal gift and generation-skipping transfer tax from April 15, 2020 until July 15, 2020.
This relief is automatic; there is no requirement to file Form 8892 (Application for Automatic Extension of Time to File Form 709 and/or Payment of Gift/Generation Skipping Transfer Tax) to obtain the benefit of the filing and payment postponement until July 15, 2020. However, a taxpayer may choose to file Form 8892 by July 15, 2020, to obtain an extension to file Form 709 by October 15, 2020 (any Federal gift and generation-skipping transfer tax payments will still be due on July 15, 2020).
After the publishing of Notice 2020-20, the following tax returns that were originally due on April 15 are now due on July 15, 2020:
- Form 1040, 1040-SR, 1040-NR, 1040-NR-EZ, 1040-PR, 1040-SS (individuals)
- Form 1041, 1041-N, 1041-QFT (trusts and estates)
- Form 1120, 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-SF (corporations, REITs, RICs, etc…)
- Fiscal year corporate returns with an original or extended due date of April 15, 2020
- Form 8960 (net investment income tax)
- Form 8991 (tax on base erosion payments)
- A Form 990-T due on April 15th. A Form 990-T due on May 15 is NOT postponed.
- Form 709 (United States Gift and Generation-Skipping Transfer Tax Return)
The following returns remain due on April 15:
- Estate (Form 706) returns
- Any return with filing due dates between April 15 and July 15th, (for example, Form 990s originally due May 15, 2020)
- Payroll and excise tax returns
By: Tony Nitti, CPA, MST
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