Which deadlines have been extended so far?

  • On March 20, in Notice 2020-18, the IRS extended April 15 deadline to July 15. The extension applies to individuals, Schedule C filers, 2019 IRA and HSA contributions. On April 9, the IRS expanded this relief to all taxpayers that have a filing or payment deadline falling on or after April 1, 2020, and before July 15, 2020. The relief applies for filing and payment of taxes. Taxpayers requesting additional time to file should estimate their tax liability and pay any taxes owed by the July 15, 2020, deadline to avoid additional interest and penalties. Moreover, taxpayers who need additional time to file beyond the July 15 deadline need to request an extension to Oct. 15, 2020 by filing a Form 4868.
  • The IRS announced on March 27, 2020 that the deadline to restate 403(b) plans is extended from March 31, 2020 to June 30, 2020.  They also announced the extension of the restatement deadline for certain defined benefit plans from April 30, 2020 to July 31, 2020.
  • PBGC filing and premium payment deadlines due on or after April 1, 2020, and before July 15, 2020, have been extended to July 15, 2020.
  • Additionally, the IRS, in Notice 2020-23 published on April 9, announced a limited relief for certain 'time-sensitive' actions that have due dates between April 1 and July 14 extending it to July 15:
    • Corrective distribution of excess deferrals from 401(k) and 403(b)
    • Corrective distributions due to a failed ADP or ACP tests (nondiscrimination test for employee elective salary deferrals, match, and after-tax contributions)
    • Substantially equal periodic payments from retirement accounts, including IRAs
    • Corrective distributions of excess contributions to IRAs
    • Recharacterization of IRA contributions
    • Indirect rollovers for rollover-eligible distributions received between February 1, 2020 and May 14, 2020 (subject to the once in a 365-day period limit applicable to indirect rollovers)
    • Limited relief for Form 5500 filers that will benefit a small subset of retirement plan sponsors with fiscal plan year end with filing due dates from April 1, 2020 to July 15, 2020. These plans received an extension to file until July 15, 20202. Plans with calendar year end are yet to see a sign of relief from the regulators.
  • Not yet extended:
    • Form 5500 - The CARES Act specifically gave the DOL the authority to postpone the filing deadline, but they have not yet done so for calendar year retirement plans as of May 1, 2020.

NOTE: The DOL, on April 29, 2020 aligned with the IRS to provide limited relief to certain 5500 filers through July 15, 2020.

    • Deadlines for correction of certain non-discrimination tests for calendar-year plans
    • Deduction deadlines - other than those falling between April 15 to July 14 being extended to July 15 - i.e. normal rules continue to apply.

Cetera Retirement Plan Specialists is a third-party administrator and may not offer tax, legal or investment advice. Plan sponsors should consult their own tax, legal or investment professionals.