As we previously alerted our clients and friends, the Internal Revenue Service has postponed the tax payment deadlines for calendar year taxpayers until July 15, 2020 provided that the amounts owed did not exceed certain levels (prior alert); however, the tax filing deadline itself was not automatically extended under this prior guidance

Recent guidance just issued significantly expands upon the prior guidance in two materials ways.  Under the guidance:

1. The dollar limitation on the amount of the payment that may be postponed until July 15 was removed.  Under the new guidance, all payments for 2019 income taxes and first quarter 2020 estimated income taxes may be postponed until July 15, 2020 without penalty or interest.  This deferment applies to all taxpayers, including individuals, trusts and estates, corporations and other non-corporate tax filers as well as those who pay self-employment tax. 
2. The federal income tax filing due date was automatically extended from April 15, 2020, to July 15, 2020.

The IRS noted that taxpayers who need additional time to file beyond the July 15 deadline, can request a filing extension by filing Form 4868 at that time.  Additional IRS guidance will be necessary to flesh out the details and on the mechanics of this extension.   Moreover, the IRS stated that the above extensions do not apply to any other type of tax or payment otherwise due (e.g.  FICA taxes) or to federal information returns (e.g. payroll returns).

There are a number of states that are matching the IRS’s July 15 filing and payment deadline.  New York, California, Indiana and a growing list of others have provided similar relief.   However, Illinois has not yet modified its normal filing and payment deadlines.

This continues to be a very fluid situation and we expect additional guidance from the IRS as well as the states shortly.   Future DB alerts will be issued when significant new developments occur. 

Taxpayers with balances otherwise due on April 15th will still need to make these payments on July 15th, as well as any second quarter estimated payment, which continues to be due June 15th as these payments have not been included in the tax payment deferral program.  Proper cash flow planning will be essential in these times in order to meet these obligations as well as others. DUGGAN BERTSCH can assist you with your tax and legal planning surround these obligations. As always, please feel free to reach out to us for assistance or any questions concerning the IRS’ guidance on taxes or on any matter.