On Friday, March 20, 2020, the Treasury issued Notice 2020-18 which supersedes and expands upon the guidance in Notice 2020-17 that we previously wrote about. Important changes to note are:
1. Notice 2020-18 removes the cap on the amount of tax payments that may be deferred. Individual, trust, estate and corporate taxpayers may now defer an unlimited amount of federal income tax.
2. Notice 2020-18 also changes the due date for filing returns originally due on April 15, 2020 to July 15, 2020. Taxpayers are not required to file an extension on or before April 15, 2020 to take advantage of this new due date. Any extension filed on or before July 15, 2020 will extend the due date for filing to the original extended due dates (September 30 or October 15). The extended due dates have not been pushed back.
It should also be noted that Notice 2020-18 continues to limit the relief to federal income tax payments (including payments of tax on self-employment income) only. No other federally-imposed tax or filing deadline has been deferred. As an example, gift tax returns originally due on April 15, 2020 remain due, along with any tax payments due with those returns. Taxpayers who need an extension of time to file their gift tax returns would have to separately extend the time for filing those returns using Form 8892.
