Tax Extensions due to COVID-19

By Bill Claffey, Esq., Partner, Tax Services
Mar 19, 2020

Updated 4/15/20 10:40 a.m. EDT – the original post was published on 3/19/20 at 3:43 p.m. EDT

As expected, in response the federal government’s announcement regarding extensions of federal tax payments, additional states issued formal guidance regarding their response to the Covid-19 pandemic.  In addition, most states have updated their guidance.  For purposes of this post, we will not publish rumors or intentions regarding state specific guidance, but rather report official guidance issued by the various jurisdictions.  Below is a summary of the updated and new guidance: 

The IRS and Treasury announced (Notice 2020-18) an automatic extension to July 15, 2020 of all individual and corporation income tax returns due on April 15, 2020 including the following: 

  • Forms 1040, 1040SR, 1040NR, 1040 NR-EZ, 1040 PR, 1040 SS 
  • Forms 1041, 1041-N, 1041 QFT 
  • Forms 1120, 1120-C, 1120-F, 1120-FSC, 1120-H, 1120-L, 1120-ND, 1120-PC, 1120-POL, 1120-REIT, 1120-RIC, 1120-SF 
  • Form 8960 
  • Form 8991 
  • Forms 990, 990T, 990PF 

Further, an automatic extension is available for all federal income tax payments to July 15, 2020.  This applies to 2019 income tax payments otherwise due on April 15, 2020 and Q1 estimated tax payments.   

These extensions are automatic and do not require the filing of additional forms. Please note, the filing deadline of informational returns (i.e. partnership, S Corp, etc.) remain unchanged.  

Further, the IRS issued an FAQ regarding the Notice 2020-18.  Below are key answers we’d like to highlight: 

  • Fiscal year filers that have a return due on a date other than April 15, 2020 have not be granted an extension as of now.  
  • Relief does not apply to payroll taxes, excise taxes, or estate and gift taxes.  
  • Estimated payment relief does not extend to Q2 payments due on June 15, 2020 at this time.   
  • The Notice does provide extension to make IRA contributions to July 15, 2020.   

In response to the federal guidance, States have issued their own set of relief provisions.  Here’s what has been formally announced thus far: 

  1. Alabama –Corporate and individual tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Note that Q2 estimated payments not expected to be postponed. 
  1. Alaska –Automatically follows any federal filing extension for corporations and partnerships.  Any payment due between April 15 and July 15 are automatically extended to July 15. 
  1. Arizona – Corporate, individual and fiduciary tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates are extended to July 15, 2020. 
  1. Arkansas – Individual, S corporation, partnership and fiduciary tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.   
  1. California –The Franchise Tax Board (FTB) has extended the filing and payment deadlines for all businesses and individuals to July 15, 2020 for the following: (1) 2019 tax returns, (2) 2019 tax return payments (3) 2020 1st and 2nd quarter estimates, (4) LLC taxes and fees and (5) 2020 non-wage withholding payments.  Taxpayers do not need to claim any special treatment or file special relief forms.  Through May 15, 2020 individuals and businesses impacted by Covid-19 may seek filing and payment extensions of all taxes administered by CDTFA (i.e. sales tax). 
  1. Colorado – Corporate and personal tax payments extended to July 15, 2020 for payments originally due April 15, 2020.  Extension of all income tax returns to October 15, 2020.    
  1. Connecticut – see below (IMPORTANT UPDATES ON 4/14/20) 
    • Individual Income Tax Returns – filing and payment extension to July 15, 2020.  Q1 & Q2 payments extended to July 15, 2020  
    • Corporate Tax Returns- filing and payment extension to July 15, 2020.  Q1 & Q2 estimated payments extended to July 15, 2020 (UPDATED on 4/14/20) 
    • PET Returns – filing and payment extension to July 15, 2020; Q1 & Q2 estimated payments extended to July 15, 2020 (UPDATED on 4/14/20) 
    • Sales/Use Tax Returns – taxpayers with less than $150k in annual sales tax liability are permitted an extension to file and pay sales tax returns due March 31 and April 30 to May 31, 2020 (note that DRS guidance doesn’t indicate extension date, however, extension also applies for room and occupancy filers and that date is May 31, 2020.     
    • Trust & Estate – Form CT-1041 filing and payment extension to July 15, 2020; Q1 & Q2 estimated payments extended to July 15, 2020 (UPDATED on 4/14/20) 
    • Estate Tax Return – Form CT 706/709 filing and payment extension to July 15, 2020.   
    • Gift Tax – filing and payment extended from April 15, 2020 to July 15, 2020.   
  1. Delaware – individual and corporate tax return filings and payments are extended to July 15, 2020.  Q1 estimates are extended to July 15, 2020.  Q2 estimates remain due June 15, 2020. 
  1. District of Columbia – deadline to file and the pay the following 2019 returns are extended to July 15, 2020: 
    • Individual and fiduciary income tax returns  
    • Partnership tax returns  
    • Franchise tax returns (Corporate and Unincorporated)  
  1. Georgia – Corporate and individual tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates are extended to July 15, 2020.  No extension is provided for the filing, payment, or deposit of any other type of state tax (including employee withholding and sales tax) or for the filing of any state information returns.)  
  1. Hawaii – Corporate and individual tax filing and payment deadline extended to July 20, 2020 for returns / payments originally due April 20, 2020. 
  1. Idaho – Corporate, business entities and individual tax filing and payment deadline extended to June 15, 2020 for returns / payments originally due April 15, 2020. 
  1. Illinois – Corporate and individual tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Note that Q1 and Q2 installments of estimated payments deadline has not changed. 
  1. Indiana – Extension of individual and corporate income tax filings and payments, including estimated payments originally due April 15, 2020 (or April 20, 2020 for some corporate tax returns) are now due July 15, 2020.  Corporate tax returns and payments originally due May 15, 2020 are now due August 17, 2020. Indiana will also respect any federal extensions requested without the requirement of an Indiana state extension.  
  1. Iowa – Extension of all individual and business income tax filings and payments (i.e. individual tax returns, composite, corporate, s corp, partnership, fiduciary) due between March 19, 2020 and before July 31, 2020 are now due July 31, 2020.  Note: the extension does not apply to estimated tax payments.  
  1. Kansas – Corporate, privilege, individual and fiduciary income tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020 to July 15, 2020.  Estimated payments deadline has not changed. 
  1. Kentucky – all income tax filing and payment deadlines extended to July 15, 2020, however, interest will be charged on payments made after April 15, 2020 deadline. 
  1. Louisiana – income and franchise returns due between April 15, 2020 through May 15, 2020 are extended to July 15, 2020. 
  1. Maine – Corporate, individual and fiduciary tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  This extension includes any estimated income tax payments originally due by April 15, 2020.  Sales tax and payroll tax payments will continue as normal. 
  1. Maryland – Corporate and individual income tax filing and payments extended to July 15, 2020. Federal extension automatically grants a 90-day state extension. Filing deadlines otherwise remain unchanged. Payment extension applies to 2020 Q1 payments.    
  1. Massachusetts – On March 27, 2020 Governor Charlie Baker, Lt. Governor Karyn Polito, Senate President Karen Spilka and House Speaker Robert DeLeo announced an agreement to extend the 2019 state individual income tax filing and payment deadline from April 15 to July 15 automatically. 
  1. Michigan – All state and city income tax filing and payment deadlines extended to July 2020 for returns / payments originally due April 2020. Returns and payments otherwise due on April 15, 2020, are now due on July 15, 2020. Returns and payments otherwise due on April 30, 2020, are now due on July 31, 2020. This applies to: a) annual state and city income tax returns and payments; b) estimated state and city income tax payments; and c) estimated city income tax extension payments. 
  1. Minnesota – Individual income tax filing and payment extended to July 15, 2020.  2020 estimated payment dates are not changed.  The Minnesota due date has not changed for Corporation Franchise, S Corporation, Partnership, or Fiduciary taxes. However, automatic extension rules still apply.  
  1. Mississippi – Corporate and individual income tax filing and payment extended to May 15, 2020.  Q1 estimated payments extended to May 15, 2020. Withholding tax payments for the month of April are extended until May 15, 2020. The extension does not apply to sales tax, use tax, or any other tax types. 
  1. Missouri – corporate and individual income tax filing and payment deadline extended to July 15, 2020.  Q1 estimate payment extended to July 15, 2020.  
  1. Montana – individual income tax filing and payment deadline extended to July 15, 2020.  Q1 estimate payment extended to July 15, 2020. 
  1. Nebraska – Governor announced state income tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates are extended to July 15, 2020.  Interest and penalty relief may be granted upon request from The Tax Commissioner. 
  1. New Hampshire – Business Tax taxpayers who owed $50,000 or less in taxes (total BPT and BET tax liability) for tax year 2018 and I&D taxpayers who owed $10,000 or less in taxes for tax year 2018 are granted an extension of BPT, BET and I&D filing and payment until June 15, 2020 if they were impacted by the COVID-19 pandemic and are unable to pay an amount due on April 15, 2020.  
    This extended due date is in addition to the expansion of the qualifications for the automatic extension and the estimate payment safe harbor.  The DRA will not assess interest or penalties against taxpayers who file their returns and pay any remaining balance due within the automatic 7-month extension, if by April 15, 2020 they have paid an amount no less than their total tax year 2018 tax liability. 
  1. New Jersey – proposed legislation passed the house and senate is expected to be signed by the Governor.  The legislation will automatically extend corporate and individual filing and payment dates to July 15, 2020.  Q1 estimates are also extended to July 15, 2020, however, Q2 estimates due June 15, 2020 are unchanged.   
  1. New Mexico – Corporate, individual and fiduciary tax returns and withholding tax filing and payments extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 and Q2 payments extended to July 15, 2020.     
  1. New York – Corporate, individual and fiduciary tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates are extended to July 15, 2020. 
  1. North Carolina – individual, corporate, franchise, partnership and estates and trusts tax filing and payment deadline extended to July 15, 2020, however, interest will still apply for payments after April 15, 2020.  
  1. North Dakota – penalties and interest waived for individuals and businesses unable to file or pay by April 15, 2020 if filed/paid by July 15, 2020.  It is believed this will apply to Q1 estimates.    
  1. Ohio – Individual, pass-through entity, school district income taxpayers that have the Tax Commissioner administer the municipal net profit tax through the state’s centralized filing system are granted filing and payment deadline extension to July 15, 2020 for returns / payments originally due April 15, 2020. 
    Individuals, estates, trusts and certain businesses’ Q1 & Q2 estimated payments normally scheduled for April 15 and June 15, 2020 have both been extended to July 15, 2020. 
  1. Oklahoma – Corporate and individual tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates are extended to July 15, 2020. 
  1. Oregon – Corporate and individual tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates due date remains unchanged. 
  1. Pennsylvania – individual filing and payment deadline extended to July 15, 2020.  Q1 & Q2 payments extended to July 15, 2020.   
  1. Rhode Island – individual and corporate filing and payment deadline extended to July 15, 2020.   
  1. South Carolina – Corporate and individual tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates are extended to July 15, 2020.  Extension of the due date for sales and use tax returns and payments originally due April 1, 2020 through June 1, 2020, are now due June 1, 2020.  
  1. Tennessee – Franchise and excise tax filing and payment deadline extended to July 15, 2020 for returns / payments originally due April 15, 2020.  Q1 estimates are extended to July 15, 2020. 
  1. Utah – Individuals, corporations and pass-through entities tax filing and payment deadline extended to July 15, 2020.   
  1. Virginia – Extension of payments originally due April 1, 2020 through June 1, 2020, are now due June 1, 2020.  
  1. Vermont – individual, fiduciary, and corporate income tax filing and payment deadlines extended to July 15, 2020.  Q1 estimate extended to July 15, 2020. 
  1. Washington – For annual filers an automatic tax filing and payment deadline extension to June 15, 2020 for returns / payments originally due April 15, 2020.  For quarterly filers, an automatic filing and payment extension to June 30, 2020 applies to Q1 filers.  Upon request, the Department will provide extensions for filing and payment of tax returns for 60 days (monthly filers) or 30 days (quarterly filers).  This impacts B&O tax, sales tax, real estate excise tax and other taxes administered by the Department.    
  1. Wisconsin – individual, trusts, estates, partnership, associations and corporate income tax filing extended to July 15, 2020.  Payment deadlines extended to July 15, 2020.  Q1 estimate extended to July 15, 2020. 
  1. West Virginia – Governor has announced through a press release (3/25/2020) a request for the income tax filing and payment deadline to be extended to July 15, 2020 for returns / payments originally due April 15, 2020.   

FML anticipates that unlisted states will issue guidance or updates shortly. FML will be monitoring this situation and will update this post as verified information is released. If you have a specific state question, please reach out to Bill Claffey at bclaffey@fmlcpas.com or 860-657-3651 x239. If you have a specific federal question please contact Lisa Willauer at lisa@fmlcpas.com or 860-657-3651 x211.