IRS Issues Notice 2020-23 Providing More Relief for Taxpayers Due to Coronavirus Pandemic

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The Treasury Department has issued Notice 2020-23, an update to Notice 2020-18 (and Notice 2020-20) which provided additional relief for taxpayers affected by the ongoing Coronavirus Pandemic. The Notice provides an explicit list of Federal tax payment obligations and Federal Tax or other Form filing obligations due dates that will be given automatic extension.

Under the Notice, any taxpayer with a Federal tax payment obligation or a Federal tax return or other filing obligation, which is due to be performed (originally or pursuant to a valid extension) on or after April 1, 2020, and before July 15, 2020, will receive an automatic extension. Notice 2020-23 expands the relief provided in both Notice 2020-18 and Notice 2020-20.

The following Federal tax payments and filing obligations with due dates on or before April 1, 2020, and before July 15, 2020, will be automatically postponed to July 15, 2020. (Please see the official IRS issued Notice 2020-23 for an exhaustive list of tax payments and filing requirements to which the extension applies.)

  • Estate and Trust Income Tax Payments and Returns on:
    • Form 1041, U.S. Income Tax Return for Estates and Trusts;
    • Form 1041-N, U.S. Income Tax Return for Electing Alaska Native Settlement Trusts; and
    • Form 1041-QFT, U.S. Income Tax Return for Qualified Funeral Trusts.
  • Estate and Generation-Skipping Transfer Tax Payments and Return Filings on:
    • Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return;
    • Form 706-NA, United States Estate (and Generation-Skipping Transfer) Tax Return;
    • Form 706-A, United States Additional Estate Tax Return;
    • Form 706-QDT, U.S. Estate Tax Return for Qualified Domestic Trusts;
    • Form 706-GS(T), Generation-Skipping Transfer Tax Return for Terminations;
    • Form 706-GS(D), Generation-Skipping Transfer Tax Return for Distributions; and
    • Form 706-GS(D-1), Notification of Distribution from a Generation-Skipping Trust (including the due date for providing such form to a beneficiary).
  • Form 706, United States Estate (and Generation-Skipping Transfer) Tax Return, filed pursuant to Revenue Procedure 2017-34.
  • Form 8971, Information Regarding Beneficiaries Acquiring Property from a Decedent and any supplemental Form 8971, including all requirements contained in section 6035(a) of the Code.
  • Gift and Generation-Skipping transfer tax payments and return filings on Form 709, United States Gift (and Generation-Skipping Transfer) Tax Return that are due on the date an estate is required to file Form 706 or Form 706-NA.
  • Estate tax payments of principal or interest due as a result of:
    • an election made under sections 6166, 6161, or 6163 of the Code; and
    • annual recertification requirements under section 6166 of the Code.
  • Exempt organization business income tax and other payments and return filings on:
    • Form 990-T, Exempt Organization Business Income Tax Return (and proxy tax under section 6603(e) of the Code).
  • Excise tax payments on investment income and return filings on:
    • Form 990-PF, Return of Private Foundation or Section 4979(a)(1) Trust Treated as Private Foundation.
  • Quarterly estimated income tax payments calculated on or submitted with:
    • Form 990-W, Estimated Tax on Unrelated Business Taxable Income for Tax-Exempt Organizations;
    • Form 1040-ES, Estimated Tax for Individuals;
    • Form 1040-ES (NR), U.S. Estimated Tax for Nonresident Alien Individuals;
    • Form 1040-ES (PR) Estimated Federal Tax on Self Employment Income and on Household Employees (Residents of Puerto Rico);
    • Form 1041-ES, Estimated Income Tax for Estates and Trusts; and
    • Form 1120-W, Estimated Tax for Corporations.

Postponement of Due Dates with Respect to Certain Federal Tax Returns and Federal Tax Payments.

The due date for filing forms and making payments with respect to the list in Notice 2020-23 (“Specified Forms” and “Specified Payments”) is automatically postponed to July 15, 2020. This means that the relief is granted automatically and Taxpayers do NOT have to call the IRS or file any Forms to receive this relief.

Taxpayers needing additional time to file may choose to file the appropriate extension form by the postponed due date of July 15, 2020. However, the extension date may not go beyond the original statutory or regulatory extension date.

Interest and Penalties. As a result of the automatic postponement of the due date for Filing Specified Forms and making Specified Payments, the period beginning April 1, 2020, and ending July 15, 2020, will be disregarded in the calculation of any interest, penalty, or addition to tax for failure to file Specified Forms or make Specified Payments postponed by this Notice. Interest, penalties and any additions to tax with respect to the filing of Specified Forms and payment obligations will start to accrue on July 16, 2020.


About the Authors

Taylie Riddle

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

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