Yesterday, the IRS released a list of frequently asked questions regarding the guidance issued last week postponing the tax return filing and payment deadline until July 15, 2020. The IRS intends to update these questions and answers periodically.

Specific highlights from the FAQ include:

• Only returns or payments due on April 15, 2020, have been postponed – the relief does not apply to federal income tax returns or payments due on any other date. For example, the due date for taxpayers whose Form 990-T is due on May 15, 2020, has not been postponed.

• Second-quarter 2020 estimated income tax payments are still due on June 15, 2020. Only the first quarter of 2020 estimated income tax payments have been postponed from April 15 to July 15, 2020.

• If you do not think you can file your tax return by July 15, 2020, and need to extend to October 15, 2020, you must file an automatic extension request by July 15, 2020. To avoid interest and penalties when filing your tax return after July 15, 2020, you should pay the tax you estimate as due to your extension request.

• The relief does not currently apply to estate and gift taxes or to payroll and excise taxes. Under the Notice, normal filing, payment, and deposit due dates continue to apply to estate and gift taxes and payroll and excise taxes.

• The deadline for contributing to an IRA, HSA, or Archer MSA for 2019 has been extended to July 15, 2020.

• If a taxpayer has made excess elective deferrals to his or her workplace-based retirement plan in 2019, those excess deferrals must be taken out of the retirement plan no later than April 15, 2020, to be excluded from income.

Our attorneys continue to monitor the impact of coronavirus on the markets, and we have developed a dedicated COVID-19 Resource Library to provide insights on regulations and/or changes to the law. Please contact your Pryor Cashman attorney for specific advice or counsel.