In response to the coronavirus disease 2019 (COVID-19) outbreak, on March 20, 2020 the IRS released Notice 2020-18 which postpones the April 15, 2020 income tax filing due date to July 15, 2020. The Notice applies to any “person” with a federal income tax payment (including self-employment tax payments) or federal income tax return due April 15, 2020 (an “Affected Taxpayer”). Person includes individuals, trusts and estates, partnerships, and corporations.
For an Affected Taxpayer, the due date for filing federal income tax returns and making federal income tax payments due April 15, 2020 is automatically postponed to July 15, 2020. In addition to any income tax that might otherwise be due, the postponement includes first quarter 2020 estimated taxes. The June 15, 2020 estimated tax payments are still due on June 15, 2020.
No interest or penalties will be imposed during the postponement period and there is no limit on the amount of the tax payment that is postponed. No extension of time to file (Form 4868 or Form 7004) is required to be filed.
The Notice specifically states that no extension is provided for the payment or deposit of any other type of federal tax, or for the filing of any federal information return. For taxpayers who made gifts in 2019 which require the filing of a gift tax return, we do not believe the Notice automatically postpones the time for filing a gift tax return and the payment of any gift tax. Without further clarification, it would be prudent to pay any gift tax by April 15th and either file the gift tax return or file for an extension of time to file.
If you have any questions regarding the issues raised in this client alert, please contact your Private Wealth counsel at Smith, Gambrell & Russell, LLP.