On April 9, 2020, the IRS issued Notice 2020-23, which amplifies prior guidance in Notice 2018-58, for time sensitive act due to a federally declared emergency. Here is how the relief applies to employee benefit plans. Plans with original or extended filing deadlines that fall between April 1, 2020, and July 15, 2020, now have until July 15, 2020, to file their Form 5500.
This relief has very limited applicability. For example, a plan with September 30, 2019, plan year-end originally would have had an April 30, 2020, due date will now have a due date of July 15, 2020. That is the same due date the plan could have requested by filing for an extension using IRS Form 5558. A plan with a May 31, 2020, or June 30, 2020, due date is better off filing for its own extension to August 15, 2020, or September 15, 2020, respectively.
The plans that are receiving relief here are those plans that are already on extension. In the case of plan with a June 30, 2019 year end the extended due date for filing Form 5500 was April 15, 2020. Such a plan now has until July 15, 2020, to complete the work necessary to file the return. This relief is valuable to those plans with extended due dates that fall in April, May, or June.
