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IRS Form 5500 Extension Comes Up Short

Regulatory Compliance

Under Notice 2020-23, released April 9, the extensions[i] 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.  

On the other hand, the news will be of little comfort to those plans with calendar year-ends—for which their July 31 deadline is fast approaching.

“We certainly hope and expect that there will be further guidance automatically extending the Form 5500 deadline for calendar year plans from July 31 to October 15, particularly considering that the IRS Ogden Service Center has been shut down—and there is now no place to send the Form 5558 to ask for an extension,” commented Brian Graff, CEO of the American Retirement Association.

[i]If you’re having trouble locating the reference to Form 5500 in the IRS Notice, it’s in the following:

The Secretary of the Treasury has also determined that any person performing a time-sensitive action listed in either § 301.7508A-1(c)(1)(iv) – (vi) of the Procedure and Administration Regulations or Revenue Procedure 2018-58, 2018-50 IRB 990 (December 10, 2018), which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer. For purposes of this notice, the term Specified Time-Sensitive Action also includes an investment at the election of a taxpayer due to be made during the 180-day period described in section 1400Z-2(a)(1)(A) of the Code.

This triggers 44 time sensitive items in Rev. Proc. 2018-58, #40 of which is the Form 5500 (IRC section 6057).