On April 9, 2020, the IRS released Notice 2020-23, which automatically postpones due dates for payments, returns, and form filings specified in the notice to July 15th, 2020. The Notice supersedes prior Notices 2020-17, 2020-18 and 2020-20 and provides the most expansive relief to date by allowing specified businesses with tax payments or tax returns due (on either the original or extended due date) between April 1 and July 15 to delay payment and filing until July 15, 2020.
The most notable changes from Notice 2020-23 to previous Notices are:
- Tax-exempt organizations required to file a Form 990-T on May 15 are now delayed to July 15, 2020.
- Second quarter estimated payments for individuals and corporations are now due July 15, 2020.
- The Notice extends relief until July 15, 2020, to all schedules, returns and forms that are filed as attachments to forms, including Schedule H and SE, as well as Forms 3520, 5471, 5472, 8621, 8858, 8865 and 8938.
- Any elections that are made or required to be made on a form now due on July 15, 2020 will also be due on July 15, 2020.
What this notice DOES NOT postpone are payroll tax returns and tax deposits. Forms 941s and corresponding payments should be filed and paid as usual.
Notice 2020-23 also provides postponements for specified time-sensitive actions, including the extension of the statute of limitations on claims for refund for the 2016 tax year from April 15, 2020 to July 15, 2020. Also, tax court petitions that are due between April 15, 2020 and July 15, 2020, will be considered to be timely filed if filed by July 15, 2020. This includes bringing a suit upon a claim for credit or refund.
A list of filing and payment obligations delayed until July 15, 2020, are listed in the below table provided by the IRS:
By: Tony Nitti, CPA, MST
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