The IRS released FAQs addressing the Treasury’s decision to move Tax Day (for both filing and payment) from April 15 to July 15, 2020 (available here). The FAQ addresses questions relating to (i) general eligibility for relief, (ii) filing and paying 2019 Federal income taxes and first quarter 2020 Federal estimated income taxes, (iii) Individual Retirement Accounts (IRAs) and workplace-based retirement plans, (iv) Health Savings Accounts (HSAs) and Archer Medical Savings Accounts (MSAs), and (v) other miscellaneous questions and answers. The IRS stated that it will update the FAQs periodically.

Some key takeaways from these FAQs include:

  • Only payments due on April 15, 2020 are extended; no extensions are available for federal income tax returns or payments due on any other date (e.g., absent further guidance, June 15, 2020 estimated tax payments are still due on June 15, 2020, Form 990-Ts due on May 15, 2020 are not extended, and the filing date for returns that were due before the announcement on March 16, 2020, including Form 1065 and Form 1120S for calendar year taxpayers, have not been extended).
  • Similarly, there is no relief for underpayments of estimated tax payments for the 2019 tax year.
  • Relief is not contingent on the impact from COVID-19 on any particular individual (i.e., a person does not have to be sick or quarantined and no affirmative request is required to receive relief). If a taxpayer is unable to file by July 15, 2020, the taxpayer may file for an automatic extension by July 15, 2020 extending the filing deadline to October 15, 2020 (although payment must be made by July 15, 2020 to avoid interest and late payment penalties).
  • Relief does not apply to the filing of returns for or payments of payroll taxes, excise taxes, estate and gift taxes, or to the filing of information returns.
  • Taxpayers now have until July 15, 2020 to make contributions to an IRA, HSA, or MSA, and any penalties related to early withdrawals also are deferred until July 15, 2020.

The Notice does not extend the time for filing refund claims for prior tax years (e.g., a claim for refund of 2016 income tax reported on a return filed on April 15, 2016).

We will continue to update for further developments. If you have questions, please contact a member of the Ballard Spahr LLP Tax Group.

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