In addition to individual tax returns, the IRS announcement (officially known as Notice 2020-23) extends the due date for all “time sensitive actions” with an original or extended due date between April 1, 2020 and July 15, 2020. The covered actions includes far more than income tax returns.

The list of “actions” with a postponed due date is 139 pages long and includes:

• Individual Income Tax Returns;
• Corporate (Form 1120) Tax Returns;
• Estate and Gift Tax Returns;
• Not-for-Profit Information Returns; and
• Trust Information Returns.

The postponement also applies to estimated tax payments, accounting method changes, net operating loss carryback periods, carryback claims, and the deadline to file certain refund claims.

It is important to note, however, that Notice 2020-23 does not cover partnership and small business corporation (s-corporation) returns with an original due date of March 15. Instead, the IRS has announced that they will show leniency to those entities who file late as a result of the COVID-19 pandemic.

It is also important to note that Notice 2020-23 does not cover state returns and tax payments. Each state make its own rules regarding due dates. Though many have postponed their due dates to coincide with the federal postponement, some have made no allowances while others have selected their own postponement date.

For more information, please see Notice 2020-23, IRC Sec. 301.7508A-1(c)(1)(iv) - (vi), and Revenue Procedure 2018-58 or contact your tax accountant.