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March 24, 2020 TO: ICI MembersPension Committee
Pension Operations Advisory Committee SUBJECTS: Pension
Tax RE: IRS/Treasury Provide Informal Guidance on COVID-19 Tax Relief
Late last week, in connection with the COVID-19 emergency, the IRS and Treasury announced in Notice 2020-18 that, for taxpayers with a Federal income tax payment or a Federal income tax return due April 15, 2020, the due date for filing Federal income tax returns and making Federal income tax payments is automatically postponed to July 15, 2020.[1] The IRS and Treasury have now posted answers to frequently asked questions related to that relief.[2]
Notably, Q&A 17 indicates that the deadline for making contributions to an IRA for 2019 is similarly extended to July 15, 2020, with the following explanation:
“Contributions can be made to your IRA, for a particular year, at any time during the year or by the due date for filing your return for that year. Because the due date for filing Federal income tax returns has been postponed to July 15, the deadline for making contributions to your IRA for 2019 is also extended to July 15, 2020.”
Also of note are Q&A 18, 19, and 20, relating to the deadlines for payment of the early distribution penalty tax, removing excess deferrals from a retirement plan, and an employer making contributions to a qualified retirement plan, for 2019.
Q&A 3 provides a list of the form numbers for the specific returns whose filing deadlines have been postponed. Q&A 10 indicates that the relief in the Notice does not apply to filing information returns.
The introduction to the FAQs explains that “[t]hese questions and answers will be updated periodically and are designed to be a flexible tool to communicate information to taxpayers and tax professionals in this changing environment. The answers to these questions provide responses to general inquiries and are not citable as legal authority. Accordingly, the Treasury Department and the IRS are continuing to consider additional IRB guidance on these issues addressed in these FAQs.”
Please note that at the time of this writing, the web page indicated that it was “Last Reviewed or Updated: 24-Mar-2020.”
Elena Barone Chism
Associate General Counsel - Retirement Policy
endnotes
[1] Notice 2020-18 is available here: https://www.irs.gov/pub/irs-drop/n-20-18.pdf.
[2] The FAQs are available here: https://www.irs.gov/newsroom/filing-and-payment-deadlines-questions-and-answers