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
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Sophia Yen is a Senior Principal at EY and the Strategy & Innovation Leader in the Insurance Consulting practice, focused on working with clients to drive profitable growth through strategic ventures, market trends & insights, innovation, and digitization and emerging technologies. She also serves on the EY Americas Insurance Leadership team.

Sophia has over 20 years of experience in the insurance industry with deep experience in reinsurance, insurance, banking, disruptive technologies and digital transformation. She has led global initiatives focusing on growth, M&A integrations and separations, integrated business and financial strategy planning, and streamlining target operating models.

Sophia has a unique combination of industry and consulting experiences as she started in consulting and then spent half of her career in the insurance and banking industry before returning to consulting. Some of her notable accomplishments included driving the transformation at UBS Investment Bank where she achieved more than 30 million in cost savings. Prior to UBS, she was at Swiss Re and held several senior leadership roles, including running their Americas Client Solutions team, SVP of Financial Services Origination, Chief of Staff to the CEO and COO and Head of Operations and Reporting, where she was responsible for the strategic financial planning, reporting, and operations of a $2.5+ billion portfolio and was a member of the Americas Executive Committee.

She holds an MBA from Columbia Business School and a Bachelor of Science (dual major: Finance & Computer Science) from Boston College and graduated both with high honors. She is a sought-after speaker at industry conferences throughout the Americas, EMEIA, and Asia on such topics as strategic transformation, digital transformation, enabling innovation, culture change, and diversity & inclusion. Sophia lives in Chappaqua, NY with her husband and daughter.

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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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