The Department of the Treasury and the Internal Revenue Service issued Notice 2020-17 on March 18, 2020, which postponed the due date for certain Federal income tax payments from April 15, 2020, until July 15, 2020. (see related posts below) Just two days later, this Notice was “superseded” by Notice 2020-18, which was released to “restate and expand upon the relief provided in Notice 2020-17.”
Essentially, the latest Notice cleans up a few matters left unaddressed in the earlier release and expands the information in that release to include the extension of the tax return due dates to match the previously-announced extension of certain tax payment dates.
Under Notice 2020-18, the Secretary of the Treasury has determined that any person with a Federal income tax payment or a Federal income tax return due April 15, 2020, is affected by the COVID-19 emergency for purposes of the relief (Affected Taxpayer). The term “person” includes an individual, a trust, estate, partnership, association, company or corporation.
For an Affected Taxpayer, the due dates for both filing Federal income tax returns and also making Federal income tax payments originally due April 15, 2020, is automatically deferred to July 15, 2020. As the extensions are automatic, affected Taxpayers do not need to file extension Forms 4868 or 7004.
Importantly, the Notice provides that there is no limitation on the amount of the payment that may be postponed. The earlier Notice had capped the amounts that could be deferred to $1 million dollars for individuals and $10 million for corporations.
The relief provided in this Notice is available solely with respect to Federal income tax payments (including payments of tax on self-employment income) and Federal income tax returns due on April 15, 2020, in respect of an Affected Taxpayer’s 2019 taxable year, and Federal estimated income tax payments (including payments of tax on self-employment income) due on April 15, 2020, for an Affected Taxpayer’s 2020 taxable year. Thus, first quarter estimated payments are deferred as well for the 2020 tax year.
Note that the second quarter estimated income tax payment, generally scheduled for June 15, is now due before the 2019 final and first quarter due date of July 15 .
The Notice provides relief for income taxes only, as noted, and no other federal tax. Interest, penalties, and additions to tax with respect to such postponed Federal income tax filings and payments will begin to accrue on July 16, 2020.