Alvarez and Marsal

A&M Tax Advisor Weekly

IRS Provides New Grace Period for Certain Taxpayers’ Filing and Payment Deadlines

Alan Cathcart, Senior Advisor

Juan Rubio, Senior Director

Kevin M. Jacobs, Managing Director

June 2, 2020 / North America

The IRS continues to provide guidance as part of its ongoing efforts to implement the CARES Act and respond to the economic challenges arising from the COVID-19 pandemic.  As part of our continuing coverage of COVID-19 relief, this Tax Special Alert highlights Notice 2020-35, which was issued on May 28, 2020.

Extension of Certain Deadlines
Notice 2020-23, which is discussed in greater detail here, provided a grace period for certain filing deadlines associated with the federal income tax. Similarly, Notice 2020-35 provides a grace period for the following Specified Time-Sensitive Actions:

In the case of Specified Time-Sensitive Actions for which there are parallel provisions in the Employee Retirement Income Security Act of 1974 (ERISA), the relief provided in Notice 2020-35 also applies for purposes of those parallel provisions (e.g., Sections 518 and 4002(i) of ERISA).

Certified Profession Employer Organization e-file Waiver
In general, a Certified Profession Employer Organization (CPEO) has to file certain employment tax returns and their accompanying schedules electronically. Notice 2020-35 waives this requirement for Forms 941 (Employer’s Quarterly Federal Tax Return) for the second, third, and fourth quarter of 2020 and Forms 943 (Employer’s Annual Federal Tax Return for Agricultural Employees) for calendar year 2020, and their accompanying schedules. Accordingly, CPEOs are permitted, but not required, to file a paper Form 941 or 943 (as applicable), and their accompanying schedules for these periods.

A&M Taxand Says
The guidance covered in this TAW is part of the government’s efforts to provide relief to taxpayers because of the ongoing COVID-19 pandemic…


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