As owners and operators continue to cope with the disruptions caused by the coronavirus pandemic, the IRS has issued Notice 2020-23, which expands on previous guidance and provides additional deadline relief for certain federal tax returns, forms, schedules, payments, and other required actions.
The notice applies to specified filing obligations or actions that would otherwise be due on or after April 1, 2020 and before July 15, 2020, and extends the deadlines for these to July 15, 2020. This relief is automatic, requiring no extension request to be filed with the IRS, and applies to all taxpayers (including individuals, trusts, estates, and corporate and non-corporate entities) normally required to perform specified obligations or actions within the relief window.
The retirement plan-related deadlines occurring between April 1, 2020 and July 14, 2020 that are extended by the notice to July 15, 2020 include:
- The deadline for distribution of excess deferrals under 402(g), reversing previous IRS guidance
- The deadlines for distribution of deferrals to satisfy ADP testing requirements and contributions to satisfy ACP testing requirements
- The deadline for removal of excess contributions made to an IRA
- The deadline for filing Form 5500 and associated schedules
- The deadline for employers to make retirement plan contributions
- The 60-day deadline for completion of an indirect rollover to an eligible retirement plan or IRA
- The deadline for a participant to elect a withdrawal from an Eligible Automatic Contribution Arrangement
Unlike the relief granted under other federal legislation, taxpayers may take advantage of these extended deadlines even if they have not been directly impacted, either medically or financially, by the coronavirus pandemic. As the situation evolves, further guidance and relief may become available.
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