COVID-19: IRS Postpones Filing and Payment Due Date for Taxpayers with April 15, 2020 Deadlines

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The IRS has issued Notice 2020-18 expanding tax filing and tax payment relief for taxpayers due to the Coronavirus pandemic.

Who qualifies?  Any “person,” which includes an individual, trust, estate, partnership, association, company, or corporation under IRC §7701(a)(1), with a federal income tax payment or a federal income tax return due on April 15, 2020, is considered affected by the COVID-19 pandemic and qualifies for relief.

New Due Date.  The new due date for filing federal income tax returns and making income and self-employment tax payments is automatically postponed to July 15, 2020. You do not need to file for an extension (i.e. there is no need to file Forms 4868 or 7004).  Note, there have been no extensions granted for the filing or payment of any other type of federal tax.

Filings and Payments That Have Been Postponed to July 15, 2020

The following income tax forms, which previously had filing and payment due dates of April 15, 2020, (whether that is the original due date or the due date on extension) are now due July 15, 2020:

  1. Form 1040, 1040-SR, 1040-NR, 1040-NR-EZ, 1040-PR, 1040-SS
  2. Form 1041, 1041-N, 1041-QFT
  3. Form 1120, 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-SF
  4. Form 8960
  5. Form 8991 (Base Erosion and Anti-Abuse Tax payments)
  6. Section 965 installment payments due on April 15, 2020
  7. Form 990-T, provided that Form was due on April 15, 2020.   However, if the Form 990-T is due on May 15, the due date has NOT been postponed.
  8. Form 1040ES for Q1 2020, federal estimated income tax payments for the first quarter of 2020, including payments of tax on self-employment income, which are normally due on April 15, 2020.

2019 IRA, HSA and MSA Contributions: 2019 IRA, HSA, and Archer MSA contributions must be funded by the July 15, 2020, extended due date.

2019 Extensions and Estimated Payments: If you do not anticipate filing a return (that was previously due on April 15) by July 15, 2020, you will need to file an extension (Form 4868 or Form 7004) by July 15, 2020. Any anticipated 2019 tax payments should also be made by July 15, 2020, to avoid interest and penalties after that date.

Filings and Payments That Have NOT Been Postponed.

  • Due Dates Other than April 15, 2020: Any taxpayers that have filing or payment due dates other than April 15, 2020, have not been granted relief at this time.
  • Second Quarter 2020 Estimated Payments: Second quarter 2020 estimated income tax payments are still due on June 15, 2020. Note, unless further relief is granted, this means you may be filing and paying your second quarter 2020 estimated taxes (due in June) before your first quarter estimated taxes (due July 15).
  • Estate and Gift Tax Returns: Normal filing and payment due dates will still apply to gift and estate taxes. No relief or postponement has been granted at this time.
  • Gift Tax Return Extensions. Normally, when you extend your income tax return, you automatically extend the time for filing your gift tax return, if needed.  However, if you have a 2019 gift tax return due on April 15, 2020 and you need to extend this, you must file Form 4868 by April 15, 2020.
  • 2016 Refund Claims: Any 2016 refund claims that are due April 15, 2020, are not extended.

State Filing Guidance for Coronavirus Pandemic. If you have any state income tax filing requirements, do not assume that the state income tax filing and payment date has been extended.  Check with the state to ensure that you remain in compliance. 

Helsell Fetterman LLP remains committed to keeping you informed of legal changes that may affect you during this pandemic.  If you have any questions, please don’t hesitate to contact any of our attorneys.


About the Authors

Taylie Riddle

Taylie Riddle’s practice focuses on wills, trusts, estate planning, business succession and tax planning.

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