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.
Ed Boyle is the CEO of Medici Bank. A payments and digital banking expert, Boyle has more than 15 years' experience in varied product and marketing roles at American Express. After serving as U.S. managing director of Fidor Bank in Germany, Boyle brings a deep customer orientation and knowledge of banking technology, and partnership development to create more open and efficient solutions.
Robin I. Frank is a partner with Shapiro, Blasi, Wasserman & Hermann PA, a litigation and transactional law firm in South Florida. She focuses on labor and employment law and has extensive experience both prosecuting and defending against nationwide “collective action” claims for unpaid overtime or minimum wages under the Fair Labor Standards Act. Reach her at (561) 477-7800 or rfrank@sbwh.law.
Eden Amirav is CEO and co-founder of Become.
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?
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.
