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
John Starling

John Starling is the senior vice president of Northern Bank’s 1031 Exchange and helps people and business entities preserve profit and build wealth faster through tax-deferred exchange.

Randy Kaston

Randy Kaston is the director of Business Law Group at Ligris + Associates. Her practice concentrates on all aspects of commercial and residential transactions, including representing lenders in closing complex commercial, asset-based, real estate, construction and SBA loans, as well as business lines of credit.

Lamine Zarrad is the founder and CEO of StellarFi, a credit builder that reports unlimited bill payments to the three major credit bureaus. Since 2008, Lamine has worked in various financial services roles, launching his career with Merrill Lynch and later transitioning to the public sector as a National Banker Examiner at the Office of the Comptroller of the Currency. Prior to Stellar, Lamine founded FinTechs Tokken and Joust. The latter was acquired by ZenBusiness where Lamine led the product organization through two fund raises, minting the company as one of the few Austin Unicorns. At StellarFi, Lamine and his team are on a mission to disrupt the U.S. poverty cycle and provide credit access to 132 million Americans with low or no credit. Lamine has been awarded a Bachelors in Business Administration in International Business and Russian Studies from the University of Texas at Arlington and a Masters of Public Affairs degree with a focus on Policy Analysis/Public Finance from the University of Texas at Austin. Lamine was born in the former Soviet Republic of Azerbaijan and came to the United States as a refugee prior to serving in the Marine Corps. Lamine speaks four languages and resides in Austin, Texas with his family.

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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