IRS Updates Guidance on Filing and Payment Deadlines and Provides New Guidance Relating to Other Taxpayer Actions

Client Alert
April 10, 2020

For additional information on the effects of the latest Notice on Opportunity Zones and Like-Kind Exchanges, please also see our April 15 Client Alert.

Yesterday, the Internal Revenue Service issued Notice 2020‑23, which updates and amplifies its earlier guidance under Notice 2020‑18 and Notice 2020-20, discussed in our earlier Client Alert.

Compared to previous grants of relief, the Notice is much more comprehensive, and while we anticipate more detailed alerts on how the guidance may affect specific industries or practices in the days ahead, we wanted to provide you with some critical high points.

The new guidance generally moves all IRS filing and payment due dates to July 15, 2020 for due dates that fall within the period beginning April 1, 2020 and ending July 14, 2020. The relief applies both to original due dates and extended due dates that fall within that period. It covers individual income tax, fiduciary income tax, corporate income tax, gift tax, estate tax, generation-skipping transfer tax, and partnership and REMIC tax filings, and payments of balances due and estimated taxes (including second quarter 2020 estimated taxes for individuals due on June 15). The Notice also provides relief with respect to forms and election that would otherwise be required to be attached to a return covered by the relief provision.

In addition, the IRS has added deadline relief for a broad range of acts that would otherwise be required to be completed by a taxpayer in the April 1 to July 14 period.  These include, as just a few examples, filing a petition with the Tax Court, reinvesting gain from sales of property into a Qualified Opportunity Fund to defer tax, and identifying and acquiring replacement property in a like-kind exchange.

Please let us know if you have a particular question with respect to how the extension relief might apply to your unique situation.

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