Legal Alert

IRS Provides Additional Guidance Regarding Changing Tax Day to July 15

March 23, 2020

Following Treasury Secretary Steve Mnuchin’s Twitter announcement that Tax Day would be moved from April 15 to July 15, 2020, in response to the ongoing coronavirus crisis, the IRS released Notice 2020-18 (available here) providing additional details.

As we noted in our alert last week (available here), Treasury initially announced that the payment deadline date for federal income taxes and quarterly estimated income taxes due April 15, 2020, would be extended to July 15, 2020, but did not originally extend the filing date, a decision that drew criticism from practitioners. Notice 2020-18 confirms that July 15, 2020, now is the deadline for both federal income tax payments and returns originally due on April 15, 2020. A taxpayer is not required to file anything to take advantage of either extension.

The Notice also removes the caps on the amount of federal income tax payments that can be delayed until July 15, 2020. The original Notice established that the maximum amount eligible for the extension was a $1 million cap for individuals and a $10 million for corporate taxpayers.

Importantly, because the IRS announced that it is administratively changing the return due dates to July 15, 2020, the Notice gives individuals additional times to make contributions to retirement plans, including IRAs, for which the tax return due date is the due date for annual contributions.

While the additional relief was welcomed by taxpayers and practitioners alike, questions remain. First, the Notice is silent as to estimated tax payments due on June 15, 2020; if not addressed, those payments could be due before payments originally due on April 15, 2020. Additionally, practitioners continue to hope for guidance on other issues, including relaxing signature rules and deadlines and allowing for electronic correspondence.

We will continue to monitor developments in this area. If you have questions, please contact a member of the Ballard Spahr Tax Practice Group.

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This alert is a periodic publication of Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances. The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.

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