3/23/20

Federal Tax Bulletin: Treasury Issues New Notice on Tax Filing and Payment Deadlines, Eliminating Prior Caps

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On the morning of Friday, March 20, Treasury Secretary Mnuchin announced via Twitter that Treasury was “moving Tax Day from April 15 to July 15.”  Vorys prepared a Federal Tax Bulletin on March 20 (the Vorys Bulletin) describing then-existing guidance on federal income tax payment and filing deadline extensions (link here).  Late on March 20, Treasury released Notice 2020-18 (the Notice).  This Notice supersedes Treasury’s earlier Notice 2020-17, which was addressed in the Vorys Bulletin.  The new Notice describes the extended filing deadline announced by Secretary Mnuchin earlier in the day, and also eliminates the caps that Notice 2020-17 had placed on the amount of federal income tax payments that could be deferred.  Other aspects of Notice 2020-17 remain unchanged.  Below is a complete summary of Treasury’s current guidance on the extension of federal income tax payment and filing deadlines:

Treasury Extends April 15 Deadline For Making Tax Payments and Filing Tax Returns 

On Friday, March 20, Treasury released the Notice.  The Notice extends the due date for making federal income tax payments that are due on April 15, 2020.  The extended due date for these payments is now July 15, 2020.  There is no limit on the amount of the federal tax payments that may be deferred under the Notice.  This extension applies to both federal income tax payments due on April 15 with respect to the 2019 taxable year, and estimated tax payments due on April 15 for the first quarter of 2020 (in each case including, seemingly, self-employment tax).  The Notice DOES NOT EXTEND the deadline for any tax payments that are due on a date other than April 15.  Therefore, for example, under the Notice self-employed individuals are still required to make second quarter 2020 estimated income tax payments by June 15.  In addition, the Notice DOES NOT EXTEND the deadline for payment of any other taxes, such as payroll taxes. 

The Notice also extends the due date for filing federal income tax returns that are due on April 15, 2020.  The extended due date for these filings is now July 15, 2020.   This Notice DOES NOT EXTEND the deadline for filing an income tax return with a due date that occurs after April 15, 2020.  Therefore, for example, under the Notice a taxpayer with a federal income tax return with a due date of May 15, 2020 is still required to file such tax return, or a request for extension, by the May 15 due date.  In addition, the Notice DOES NOT EXTEND the deadline for any federal tax filing other than federal income tax returns.  Please contact your Vorys tax advisor with questions.