Form 5500 Filing Relief for Filings Due Before July 15, 2020

The IRS issued Notice 2020-23 which includes Form 5500, Annual Return/Report of Employee Benefit Plan due to be filed between the period April 1, 2020 through July 15, 2020.  The relief is pursuant to Form 5500’s that were either due to be filed originally or through an extension.  The relief due date for filings has been extended to July 15, 2020.  It is an automatic extension in which taxpayers do not need to file official extension forms or send other documents requesting the relief.  However, additional filing extensions beyond July 15 must be requested using the appropriate extension form by July 15, but the extension may not go beyond the original or regulatory extension date.  The IRS filing relief for Form 5500 comes through Rev. Proc. 2018-58 . Notice 2020-23 states that Specified Time Sensitive Actions are covered and refers taxpayers to Rev. Proc. 2018-58 which explicitly includes Form 5500.  This relief does not include calendar year end 2019 Form 5500 filings due July 31, 2020. 


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