The IRS recently published Notice 2020-23, which extends the due date for some governmental filings as a result of the COVID-19 pandemic. As background, in March the IRS announced that taxpayers generally have until July 15, 2020, to file and pay federal income taxes originally due on April 15. No late-filing penalty, late-payment penalty or interest will be due. Notice 2020-23 expands this relief to additional returns, tax payments and other actions. As a result, the previously announced extensions generally now apply to all taxpayers who have a filing or payment deadline falling on or after April 1, 2020, and before July 15, 2020.
For Form 5500, this means that Form 5500 filings that would otherwise be due on or after April 1 and before July 15, 2020, are now due on July 15, 2020. This extension is automatic — plan sponsors do not need to file an extension request, form or other letter. This automatic extension to July 15, 2020, would apply to plan years that ended in September, October or November 2019. Normally, Form 5500 would be due for those plan years on April 30, June 1 (since May 31 is a Sunday) and June 30, 2020, respectively. An extension beyond July 15, 2020, would still be available, although the 2.5 month extension would be measured from the regular due date (not the July 15, 2020, due date).
The automatic extension also applies to Form 5500 deadlines that fall within the relief window due to a previously filed extension. For example, if a plan year ended June 30, 2019, and the employer timely filed a Form 5558 extension extending the due date to April 15, 2020 (from January 30, 2020), then the Form 5500 would be due on July 15, 2020.
Importantly, the extension does not apply for calendar year plans (which is the majority of plans). Thus, the deadline for 2019 Form 5500 filings for calendar year plans is July 31, 2020. Because that due date falls outside the special COVID-19-related extension, the July 31, 2020, filing date is not extended. Those plans may obtain a regular 2.5 month extension by timely filing Form 5558.
NFP Benefits Compliance will continue to monitor the situation in case other extensions are granted relating to COVID-19 or other circumstances.
Source: NFP BenefitsPartners