23 March 2020

Treasury Issues Additional Guidance on Extension of Federal Income Tax Payment and Filing Deadlines

***Information and guidance in client updates was up to date at time of publication. During the pandemic, information and guidance has been changing rapidly. If you have any questions about the information contained in a client update, please contact the author(s) or your Miller Johnson attorney.***

On March 20, 2020, the Treasury Department issued official guidance supplementing Treasury Secretary Steve Mnuchin’s announcement earlier in the day that the federal government is postponing both the April 15 federal income tax return filing and tax payment deadlines to July 15. The guidance, issued under IRS Notice 2020-18 (the “Notice”) provides that:

  1. The new July 15 due date applies to all federal income tax returns and payments generally due April 15 (including full year returns and payments for calendar year 2019 and federal estimated income tax payments for the first quarter of 2020 that are due on April 15, 2020);
  2. The new July 15 due date applies to all taxpayers (including individuals, trusts, estates, partnerships and corporations); and
  3. The new July 15 due date applies regardless of the amount of income tax due (the $1.0 million per individual and $10.0 million per business limitations announced earlier in the week for postponed payments no longer apply).

The Notice is welcome news as prior announcements and guidance were not entirely clear on the types of taxpayers impacted and as previously mentioned, put limitations on the federal income tax liability that could be postponed.

Taxpayers who expect a refund can still file now and receive refunds once their income tax return is processed.

At this time, it still is not certain whether Michigan will follow suit in postponing April 15 deadlines to July 15. However, we would expect Michigan will adopt the July 15 deadline given Michigan income tax returns rely on calculations included in federal income tax returns.

Miller Johnson is actively monitoring guidance and announcements from the Treasury Department and will provide an update as developments occur.