The pandemic makes it difficult to meet the September 15 filing deadline
As the September 15 tax filing deadlines approach, some tax practitioners have expressed concern that they will not be able to meet these deadlines for various reasons related to the global pandemic. The issues mentioned by AICPA members range from extra time spent with economically disadvantaged clients; unforeseen deadlines due to assistance with Paycheck Protection Program (PPP) loan applications and the PPP loan forgiveness process; customers, members and staff incapacitated by COVID-19.
In July, the AICPA expressed concerns to the Treasury and the IRS in a letter to David J. Kautter, Assistant Secretary of the Treasury for Tax Policy, and IRS Commissioner Charles P. Rettig. The AICPA has requested automatic waiver of penalties for failure to report and non-payment for taxpayers affected by the coronavirus pandemic. Since then, the AICPA has been in communication with the IRS to share the concerns of tax professionals and their clients.
From these discussions, the AICPA understands that the IRS is ready to work with taxpayers who need relief. Practitioners who have made a good faith effort to meet filing deadlines on behalf of their clients, but who are unable to do so due to COVID-19, should write “COVID-19” in an attachment to the statement briefly describing why they cannot meet the deadlines or, if possible, should write “COVID-19” at the top of the tax return to indicate the need for penalty relief.
The AICPA suggests that practitioners contact their software vendors with any questions regarding appropriate form notations. If the software vendor requires a state-specific disaster code, these can be found with the Federal Emergency Management Agency (FEMA) Declared disasters page.
If an affected taxpayer who had indicated a need for penalty relief due to COVID-19 receives a late filing or late payment penalty notice from the IRS, the practitioner should gather the appropriate facts and call the number. phone on the notice to solve the problem. publish. In addition, practitioners should be aware that under reasonable cause standards, “[a]Any reason which establishes that a taxpayer has exercised professional prudence and prudence, but has nevertheless not complied with the tax law may be considered for relief from penalties ”(Internal Revenue Manual §126.96.36.199 .2.1).
The September 15 deadline applies to a number of federal income tax returns, including Form 1120S, U.S. tax return for an S corporation, for calendar year S corporations that have requested a six month extension and Form 1065, US Return of Partnership Income, for partnerships that have requested a six-month extension.
Earlier this year, due to the pandemic, the IRS postponed a number of tax filing and payment deadlines that were between April 1 and July 15 (notice 2020-23), but didn’t has not postponed the deadlines after this period, except in the case of taxpayers affected by certain natural disasters.
For more information and stories on the coronavirus and how CPAs can handle the challenges of the outbreak, visit JofA‘s coronavirus resource page.
For tax resources, visit the AICPA website coronavirus (COVID-19) tax resources page.
– Alistair M. Nevius, JD, ([email protected]) is the JofAeditor-in-chief of, taxation.