October 28, 2020

Volume X, Number 302


October 28, 2020

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October 27, 2020

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October 26, 2020

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COVID-19 Tax Update: Tax Return Filing and Tax Payment Relief

Last week, in a pair of notices released under President Trump’s March 13, 2020 Emergency Declaration relating to the coronavirus pandemic, the IRS and the Treasury Department offered relief for tax return filing and tax payment deadlines to certain taxpayers.  Notice 2020-17 was released on March 18, 2020.  Notice 2020-18, released on March 20, 2020, restated and expanded Notice 2020-17.

Notice 2020-18 provides that, for Affected Taxpayers,

  • The due date for filing U.S. federal income tax returns due April 15, 2020 is automatically postponed to July 15, 2020.  Affected Taxpayers are not required to file IRS Form 4868, in the case of individuals, or IRS Form 7004, in the case of certain business entities, to qualify for the extension.

  • The due date for making U.S. federal income tax payments (including estimated income tax payments and payments of self-employment tax) due April 15, 2020 is automatically postponed to July 15, 2020.  In a contrast to guidance provided under Notice 2020-17, there is no limitation on the amount of the payment that may be postponed.

  • The period beginning on April 15, 2020 and ending on July 15, 2020 will be disregarded in the calculation of any interest, penalty, or addition to tax for failure to file any U.S. federal income tax return or pay any U.S. federal income tax postponed by Notice 2020-18. Interest, penalties, and additions to tax with respect to such tax return filings and payments will begin to accrue on July 16, 2020.

Affected Taxpayers include individuals, trusts, estates, partnerships and corporations.

Although Notice 2020-18 applies only to U.S. federal income filing and payment requirements, U.S. state and local taxing authorities are expected to adopt parallel extensions in the coming weeks.

© 2020 Bracewell LLPNational Law Review, Volume X, Number 86



About this Author

Elizabeth McGinley, Energy, Tax, Attorney, Bracewell law firm

Elizabeth McGinley is the head of the firm's tax practice. She represents a variety of clients in the oil and gas and electric power industries, including private equity firms investing in oil and gas exploration, production and infrastructure. Her experience includes complex debt and equity financing, joint ventures and project finance, as well as experience with volumetric production payment (VPP) transactions. 

In addition, Elizabeth has experience in partnership and corporate transactions including mergers and acquisitions and spin-off...

Michele J. Alexander, Bracewell, Capital Markets Lawyer, Securities Offerings Attorney

Michele helps clients navigate complex tax issues while ensuring they meet their business goals. In her years of practice, Michele has counseled on an array of transactions, including mergers and acquisitions, capital markets and securities offerings, financings, joint ventures, and restructurings.

In recent years, Michele’s practice has evolved to include a strong focus on private equity and hedge funds and similar investment vehicles. Additionally, she is experienced in real estate investment trusts and the opportunities and challenges of...

Steven Lorch, Tax Attorney Bracewell Law Firm

Steven Lorch advises publicly-held businesses and private clients, including private equity sponsors and investors, on the U.S. tax aspects of mergers, acquisitions, divestitures and joint venture transactions, with a particular focus on  energy and infrastructure transactions.  His clients have included parties to midstream and upstream oil and gas joint ventures, sponsors and investors in development and financing of infrastructure and power projects, and private equity investors in a broad range of transactions, both within and without the energy and infrastructure...

George Rendziperis Tax Attorney Bracewell Law Firm

George Rendziperis provides state and local tax advice to companies in the oil and gas, manufacturing, financial services, private equity, real estate, technology and service sectors. He has more than 15 years of experience advising clients on planning, implementation and compliance issues related to income and franchise tax, sales and use tax, excise and property taxes, unclaimed property, and tax incentives and credits.

Prior to joining Bracewell, George held positions with several leading tax and consulting firms, including most recently as a partner in the state and local tax...


Catherine (PRON. “Catrina”) Engell advises clients in tax matters related to corporate transactions, including mergers and acquisitions.  Previously she represented clients in federal, state, and local tax disputes before the Internal Revenue Service (IRS), the Tax Division of the US Department of Justice and state and local taxing authorities.