IRS FAQs Answer Filing, Payment Postponement Questions

The IRS has launched a webpage entitled Filing and Payment Deadlines Questions and Answers, which answers Filing, Payment Postponement Questions.

In Notice 2020-18 , the Treasury Department and the Internal Revenue Service (IRS) announced special Federal income tax return filing and payment relief in response to the ongoing Coronavirus Disease 2019 (COVID19) emergency.  This IRS webpage answers frequently asked questions related to the relief provided in the Notice.

These questions and answers will be updated periodically and are designed to be a flexible tool to communicate information to taxpayers and tax professionals in this changing environment. The answers to these questions provide responses to general inquiries and are not citable as legal authority. Accordingly, the Treasury Department and the IRS are continuing to consider additional IRB guidance on these issues addressed in these FAQs.

• No COVID-19 effect required. You do not have to be sick, or quarantined, or have any other impact from COVID-19 to qualify for relief. You only need to have a Federal income tax return or payment due on April 15, 2020. (FAQ 2)
• Forms affected. The Notice postpones the filing and payment of Federal income taxes reported on the following forms:
• Form 1040, 1040-SR, 1040-NR, 1040-NR-EZ, 1040-PR, 1040-SS
• Form 1041, 1041-N, 1041-QFT
• Form 1120, 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-SF
• Form 8960 (Net Investment Income Tax— Individuals, Estates, and Trusts)
• Form 8991 (Tax on Base Erosion Payments of Taxpayers With Substantial Gross Receipts)
• With respect to Form 990-T, if that Form is due to be filed on April 15, then it has been postponed to July 15 under the Notice. For taxpayers whose Form 990-T is due on May 15, that due date has not been postponed under the Notice.
• With respect to returns due on March 16, 2020, which include Form 1065, Form 1065-B, Form 1066, and Form 1120-S for calendar year taxpayers, the filing of those returns has not been postponed. (FAQ 3)

• Non-April 15 due dates. Any taxpayers who have filing or payment due dates other than April 15 have not been granted relief at this time. (FAQ 5)
• Payroll and excise taxes. Under the Notice, normal filing, payment, and deposit due dates continue to apply to both payroll and excise taxes. (FAQ 6)
• Estate and gift taxes. Normal filing and payment due dates continue to apply to estate and gift taxes. (FAQ 7)
• Sec. 965(h) installment payments. The relief applies to Code Sec. 965 installment payments due on April 15, 2020. Although the Code Sec. 965(h) installment payment is generally made in respect of a taxpayer's 2017 or 2018 tax year, under Code Sec. 965(h)(2), the due date of the installment payment associated with a 2019 tax return is the due date of the taxpayer's 2019 Federal income tax return. For any taxpayer whose Federal income tax return filing due date has been postponed from April 15 to July 15, 2020, the due date of that taxpayer's Code Sec. 965 installment payment has also been postponed to July 15, 2020. (FAQ 8)

Estimated payments under BEAT.  For any taxpayer whose Federal income tax return filing deadline has been postponed from April 15 to July 15, 2020, the due date for Form 8991 and the Code Sec. 59A Base Erosion and Anti-Abuse Tax (BEAT) payment has been postponed to July 15, 2020. (FAQ 9)

Already filed and scheduled an April 15 payment.  A scheduled payment will not be automatically rescheduled to July 15. If you do nothing, the payment will be made on the date you chose. Here is information on how to cancel and reschedule your payment:

• IRAs. The Notice's relief applies to IRA contributions. IRA contributions for 2019 are due by the tax filing deadline. Thus, 2019 IRA contributions can be made by July 15. (FAQ 17)
• In addition, if a taxpayer owes a 10% additional tax on a 2019 IRA distribution, the reporting and payment of the 10% additional tax has been extended to July 15. (FAQ 18)
• Excess elective deferrals. Under Code Sec. 402(g), an employee can elect to defer a portion of compensation into an employer-sponsored plan. The maximum that can be deferred in 2019 was $19,000. Any excess elective deferrals (and income) have to be removed by April 15, 2020. The Notice does not extend this time. (FAQ 19)
• Employer contributions to qualified plans. In general, an employer contribution made to a qualified plan after the end of a tax year, but no later than the due date of the return for that tax year is considered to have been made on the last day of that year. (Code Sec. 404(a)(6)) This is sometimes referred to as the grace period.
• If an employer has a federal income tax return due date of April 15, then the Notice extends the grace period to July 15. (FAQ 20)