On March 31, 2020, Becca Chappell was quoted in Law360 regarding the lack of deadline uniformity for informational returns and estimated tax payments for 2020.
According to the article, after President Trump declared a national emergency because of the coronavirus, the Internal Revenue Service (IRS) extended various filing and payment deadlines related to federal income tax, Tax Cuts and Jobs Act's transition tax, base erosion and anti-abuse tax, and federal gift and generation-skipping transfer tax. Meanwhile, deadlines such as the remaining quarterly estimated taxes due in 2020 for individuals and corporations, as well as other informational reporting deadlines, were not extended.
The disparity in tax deadlines means there are many traps for unwary individuals and corporations, according to Chappell.
For example, U.S. citizens who live abroad typically have to file a Form 114, Report of Foreign Bank and Financial Accounts (FBAR), with the Financial Crimes Enforcement Network to disclose any assets held in foreign financial institutions. Traditionally FBARs are filed on the same day someone files a federal tax return, but the forms usually aren't submitted together, Chappell said.
The IRS said that informational returns are not postponed, which could create some confusion and even result in a U.S. citizen living abroad inadvertently neglecting to file an FBAR, she said.
There could also be administrative problems for companies, because some do not have tax years that end on December 31. Those whose taxes are not due on April 15 did not actually have deadlines extended by the IRS, she told Law360.