Retirement Savings Plans,For Plan Sponsors,For Individuals,Custom

IRS Extends Certain Time-Sensitive Deadlines Until July 15

April 21, 2020

On April 9, 2020, the Internal Revenue Service (IRS) released Notice 2020-23. This guidance extends the deadlines until July 15, 2020 for certain actions required by the federal tax rules that are otherwise due to be performed on or after April 1, 2020, and before July 15, 2020. This is the latest in a series of deadline extensions IRS has issued because of the COVID-19 pandemic. The Notice states that any time-sensitive action listed in Revenue Procedure 2018-58 is included in the extension. This Revenue Procedure, issued previously in connection with natural disasters, lists a number of deadlines that apply to retirement plans and IRAs. Thus, the following deadlines have been extended to July 15, 2020 for governmental plans:

  • If the due date for a participant’s loan payment, including the grace period, falls during the period April 1 to July 15, the due date to avoid a deemed distribution is extended to July 15. This extension is in addition to the extension made available under the CARES Act.
  • The April 15 deadline for distributing excess participant elective deferrals under Internal Revenue Code section 402(g).
  • The 60-day deadline for completing rollovers.
  • The deadline for making distributions to satisfy the substantially equal periodic payment exception to the 10% early distribution penalty.
  • The 90-day deadline to complete a permissive withdrawal under an automatic enrollment arrangement.
  • The deadline for required minimum distributions (RMDs). Note that the CARES Act waives RMDs for 2020 for defined contribution plans and IRAs, but not for defined benefit plans.
  • The deadline to complete a self-correction under the IRS’s Employee Plans Compliance Resolution System. Notice 2020-23 also extends a number of deadlines for non-governmental plans, such as the deadline to file the plan’s annual report on Form 5500.

Finally, a number of IRA deadlines are extended until July 15, including:

  • The deadline for making IRA contributions for 2019.
  • The deadline for removing excess IRA contributions.
  • The deadline for recharacterizing IRA contributions.
  • The June 1 deadline for filing and furnishing Form 5498 from IRA trustees.

Plan sponsors may reach out to their local ICMA-RC representatives with questions. We will proactively provide updates and clarifications as quickly as possible.

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