On March 13, 2020, the President of the United States issued an emergency declaration under the Stafford Disaster Relief and Emergency Assistance Act in response to the ongoing Coronavirus Disease pandemic. The Emergency Declaration instructed the US Treasury to provide relief from tax deadlines to Americans.
With Notice 2020-18, the Treasury has automatically postponed the due date for filing Federal income tax returns and making Federal income tax payments from April 15, 2020, to July 15, 2020. Taxpayers do not have to file Forms 4868 or 7004 to receive this automatic extension.
The relief is available solely with respect to Federal income tax payments and income tax returns due on April 15, 2020, for the 2019 taxable year and estimated income tax payments due on April 15, 2020, for the 2020 taxable year.
No extension is provided in this notice for the payment or deposit of any other type of Federal tax, or for the filing of any Federal information return.
As a result of the automatic postponement of the due date for filing Federal income tax returns, the IRS will disregard the calculation of any interest, penalty, or addition of tax for failure to file the Federal income tax returns or to pay the Federal income taxes postponed by Notice 2020-18. Interest, penalties, and additional tax will begin to accrue after July 15, 2020.
Exempt organizations will see little benefit from Notice 2020-18, which is exclusive to income tax returns and payments due on April 15, 2020. Forms 990, 990EZ, and 990PF are information returns and the original due date for the 2019 calendar year filers is May 15, 2020. Furthermore, exempt organizations with unrelated business taxable income that file Form 990T will generally not have relief either because the due date for most returns is also May 15, 2020. Therefore, the automatic postponement by the Treasury does not apply to these exempt organization returns.
However, 990T filers first quarter estimated tax payments for 2020, which would normally be due April 15, 2020, will benefit as that estimate is now postponed until July 15, 2020. Keep in mind that the second-quarter estimated tax payment for the 2020 taxable year is still due June 15, 2020, for all taxpayers. Notice 2020-18 did not change that due date. This will cause the second quarter estimated tax payments to come due, June 15, 2020, before the first quarter estimated tax payment, now July 15, 2020.
Pension Trusts under section 401(a) that file Form 990T have a due date of April 15, 2020. Political organizations and certain exempt organizations with political activity that file Form 1120-POL also have a due date of April 15, 2020. Both of these exempt organizations will benefit from Notice 2020-18 as their returns will be automatically postponed until July 15, 2020.
For exempt organizations with fiscal years ending June 30, 2019, that may have filed extensions to file their 2018 Form 990 returns, the extended due date of May 15, 2020, has not been changed by Notice 2020-18. Those returns on final extension must be completed by May 15, 2020.
