The COVID-19 pandemic has caused enormous business disruption, leading to the announcement in March that Federal tax deadlines in April were delayed by 90 days. Many state and local tax jurisdictions followed suit, delaying their deadlines. IRS Notice 2020-17 clarified that all federal taxes due between April 15 and July 15 were delayed.
Filers of Form 5500, which is used for retirement, health and welfare benefit plans, were hoping to see similar relief from the July 31 reporting deadline. Form 5500 satisfies both IRS and ERISA annual reporting requirements and plans with a calendar year have a July 31 reporting deadline.
Under Notice 2020-23, released April 9, the extensions generally now apply to all taxpayers that have a filing or payment deadline falling on or after April 1, 2020, and before July 15, 2020. Individuals, trusts, estates, corporations, exempt organizations and other non-corporate tax filers qualify for the extra time.
The extension will surely be welcome news for those June 30 plan year-ends that had filed for an extended deadline of April 15 (the regular Jan. 31 deadline + 2.5 months)—and which will now have until July 15 to file.
To the disappointment of many plan sponsors, the IRS notice only applies to taxes/reporting due between April 1 and July 15 and therefore provides no relief for the many Form 5500 filers facing an impending July 31 reporting deadline.
Individuals should be aware that the notice indirectly extends individual retirement account rollover rules until July 15th for any distributions taken earlier in the year; this rollover rule is typically a 60-day period. Also, the Coronavirus Aid, Relief and Economic Security (CARES) Act made changes to the minimum distribution requirements, which have been waived for 2020. It is important to note that this relief does not apply to non-spouse beneficiaries.
If your plan operates on a calendar year and you have questions about your Form 5500 filing, please reach out to the Frazier & Deeter Employee Benefit Plan Advisory Group.