IRS Notice Greatly Expands Actions Whose Deadlines Are Extended to July 15

The IRS has issued Notice 2020-23, guidance that expands the number of time-sensitive tax-related actions whose completion can be delayed to July 15, 2020. The extension is being provided as a result of disruptions caused by the coronavirus (COVID-19) pandemic. (The IRS had previously extended from April 15 to July 15 the deadline for filing individual and business tax returns, and for making IRA, HSA, and certain employer-sponsored retirement plan contributions.)

Notably, under this new guidance it is not necessary that an individual or entity wishing to avail itself of the extension be directly affected by the COVID-19 pandemic (e.g., a diagnosis of COVID-19, or experiencing adverse financial consequences).

Notice 2020-23 identifies actions eligible for the extended deadline as any that are described in IRS Revenue Procedure 2018-58. Some are actions to be completed by individuals, others are the responsibility of entities such as financial organizations and employers maintaining retirement plans. For any of the identified actions, a deadline that falls on, or after, April 1, 2020, and before July 15, 2020, is extended to July 15, 2020.

Among the tax-related actions eligible for the extension are the following.

  • Filing certain information returns and retirement plan forms, including the 5498 and 5500 series, and Form 8955-SSA
  • Completion of rollovers (including rollovers from 529 plans to ABLE accounts), IRA recharacterizations, and certain delayed contributions
  • Correcting certain excess contributions to employer-sponsored retirement plans, IRAs, HSAs, and other tax-advantaged savings arrangements
  • Making retirement plan loan payments
  • Making certain ESOP elections and distributions

Notice 2020-23 is being examined for all provisions of significance to Ascensus clients, and additional details will be forthcoming.