Overview
For additional guidance, please refer to Steptoe's COVID-19 Resource Center.
On March 24, the Internal Revenue Service (IRS) issued answers to frequently asked questions (FAQs) related to the special federal income tax return filing and payment extension until July 15, 2020 provided in Notice 2020-18 for the COVID-19 emergency. The FAQs clarify that the extension has limited benefits for tax-exempt organizations. The relief in Notice 2020-18 is available for any individual or entity with a federal income tax return or payment due April 15, 2020. The extended deadline does not apply to information returns, such as the Form 990, or returns due on May 15, including Form 990 or Form 990-T. The extension also does not apply to excise or payroll taxes. Therefore, the only benefit for tax-exempt organizations is for those that have a Form 990-T filing deadline of April 15, 2020. For those taxpayers, the deadline for filing federal tax returns and payment of tax is automatically extended to July 15, 2020. Taxpayers seeking to use this extension do not need to file a request for an extension and do not need to be sick, quarantined, or have other impacts from COVID-19 to qualify for the relief.
The FAQs also address some important questions related to retirement plans. The FAQs provide that the extended deadline of July 15 applies as an extension for both the deadline to contribute to an IRA and for an employer to make contributions to qualified retirement plans for 2019.
We understand that organizations, such as the AICPA and the ABA, are seeking an expansion of the return extension relief. As a result, exempt organizations may yet receive an extension for returns due on May 15.
