IRS 90-day Extension Update

UPDATE: March 21, 2020

The IRS has issued Notice 2020-18, which clarifies some provisions for extended returns, but leaves other questions unanswered.

Here are the questions that were answered:

The April 15 income tax payment deadline has been extended to July 15 for all taxpayers, not just those below the tax due thresholds previously mentioned;

  • The filing and payment extensions apply to individuals, trusts, estates, partnerships, corporations, associations, and companies;
  • The relief applies only to income tax returns and income taxes, no extension is provided for the payment or deposit of any other type of federal tax, or for the filing of any federal information return;
  • Payroll tax filings and payments are not extended by this notice; and
  • Estimates due on April 15 are extended to July 15 (there is no discussion of second quarter estimates).

There is no discussion about extensions other than the July 15 date. We assume if a taxpayer wants an extension to October 15, an extension may be filed on or before July 15.

Download a copy of IRS Notice 2020-18 Here

UPDATE: March 20, 2020


The Treasury Secretary announced today that the April 15 filing deadline has been extended to July 15 for all taxpayers and businesses. This means taxpayers will no longer be required to file extensions for federal purposes. They also have until July 15 to pay, so long as they fall below the thresholds of $10 million due for C corporations, and $1 million due for all other taxpayers.

The information released today did not address the March 15 filing deadline, second quarter estimate payments, payroll tax filing deadlines, or IRA contribution deadlines. We will update you on this information as it becomes available.

The new federal filing extension means taxpayers will not file an extension on April 15, and that they will have until July 15 to file without extension. The IRS has not issued any written guidance on this issue, so at this time we are not certain how further extensions will work.


The FTB is postponing until July 15 the filing and payment deadlines for all individuals, trusts, and business entities for:

  • 2019 tax returns;
  • 2019 tax return payments;
  • 2020 1st and 2nd quarter estimate payments;
  • 2020 LLC taxes and fees; and
  • 2020 Non-wage withholding payments.

The FTB extended their initial extension period of June 15, 2020, to be more consistent with the IRS extension relief. Like the IRS extension, the FTB extension applies to both filing and payment deadlines, but does not limit the payment extension to those below $1 million ($10 million for corporations), and applies to estimated tax and withholding payments.

Like the IRS, the FTB is also extending this relief to all taxpayers, not just those "affected by the COVID-19 pandemic."

Download a copy of IRS Notice 2020-17 Here

If you have any questions about this extension program, please contact us!

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