Tax filing deadlines in the time of coronavirus

The extension also applies to Americans living abroad who would otherwise generally have had a filing deadline of June 15.

The unprecedented fallout from the coronavirus pandemic has meant unprecedented concessions by the U.S. government in a number of respects.

The CARES Act’s $2 trillion stimulus package represents perhaps the largest investment in this regard, but a number of U.S. government agencies have enacted other significant rule changes to help the citizenry get through these challenging times.

CORONAVIRUS IMPACT: ADDITIONAL COVERAGE

Mark Williams is owner and chief executive officer of True Rx Health Strategists cultivating integrity, innovation and healthcare to transcend pharmacy benefit solutions for employers and patients.

Holly Sraeel is Arizent's Senior Vice President of Strategy and Content, Live Media, leading content creation and innovation for the events portfolio and introducing new multimedia and invitation-only experiences for senior executives that drive critical conversations and action around corporate strategy, innovation and financial performance. She is part of the company's operational leadership team and is focused on developing cross-platform programming that creates higher levels of engagement for subscribers, community participants and partners across the company's brands, including American Banker, The Bond Buyer, National Mortgage News, Accounting Today, Digital Insurance, Financial Planning and Employee Benefits News.

Sraeel is an award-winning editorial director, media executive and content strategist with expertise in developing influential content, communities, and events for C-level executives in the banking and financial services, insurance, and technology industries. Prior to joining Arizent, she held several content leadership and strategist roles, including for B2B media consultancy New York Ventures, capital markets management consultancy Opimas, Oxford University-incubated startup Wise Responder, and as cofounder of Genesys Partners' Agility First Forum.

This new role marks a return to the company for Sraeel. In her previous 12-year run, she was a member of the executive team and was pivotal in driving new cross-platform editorial, events and business innovation as SVP of Brand Management; Group Editorial Director of Banking and Technology magazines; and Founder, President and Editorial Director of The Most Powerful Women in Banking,™ the company's first-ever, community-based media platform, now part of Arizent's flagship American Banker.

Sraeel is an early honors graduate of Marist College with a Bachelor of Arts degree in Communications and a concentration in journalism.

Mariah Shields is a senior benefits consultant at Arrow Benefits Group

One such rule change is the extension of this year’s April 15 tax deadline until July 15. Importantly, the extension also applies to Americans living abroad who would otherwise generally have a filing deadline of June 15.

The scope of the July 15 extension

When the July 15 extension was first announced in March, the taxpayer community felt a measure of relief combined with a modicum of uncertainty.

The extra time was welcome, but questions remained: Does the extension apply to the obligation to file, or the obligation to pay tax, or both? Does the extension apply to tax forms due on April 15 other than the basic federal income tax return (Form 1040)? Finally, what about estimated taxes? Are those being extended too?

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Since the original announcement, the IRS has published several updates to clarify the scope of the July 15 extension.

First, the IRS announced that the extension to July 15 applies both to the obligation to file the tax return and to pay any taxes that are due.

The IRS then clarified that the extension applies to other tax forms that would otherwise be due on April 15. This includes corporate tax returns, estate and gift tax returns, exempt organization returns, as well as international information returns and related schedules.

The broad scope of the extension relief is especially relevant for U.S. citizens living abroad who are often required to file additional forms to report assets and activities outside the United States including, for instance, the Form 3520 to report a foreign trust, the Form 5471 to report a foreign corporation, and the Form 8938 to report foreign financial assets under FATCA.

Finally, the IRS did in fact extend the deadlines for quarterly estimated tax payments due on April 15 (the first payment date) and June 15 (the second payment date) to July 15 as well.

One important caveat for citizens living in the United States is the federal extension to July 15 does not necessarily apply to U.S. state and local filing deadlines. Taxpayers should check with their state tax agencies to verify whether an extension has been granted this year for the particular form obligation.

Further extensions still available

With July 15 a few weeks away, taxpayers still have ample opportunity to file this year’s tax return on time.

As with most years, taxpayers who are unable to file by this year’s deadline can file a request for an extension to Oct. 15, 2020. Understandably, the deadline to file the request itself was moved to July 15. It should be noted that the extension to Oct. 15 is only an extension to file and does not extend the time to pay federal income tax beyond July 15, 2020.

For U.S. citizens living abroad, an even further extension may be granted to Dec. 15 under certain circumstances. A tax professional should be consulted to discuss this extension option.

For more information on the July 15 extension as well as other rule changes in response to the pandemic, the IRS has created a webpage dedicated to this topic at https://www.irs.gov/coronavirus.

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