On April 9. 2020, the Internal Revenue Service (the “IRS”) issued Notice 2020-23, which extends a number of key filing deadlines in the wake of the COVID-19 pandemic. The guidance provides welcome relief to individuals and plan sponsors who must perform certain “time-sensitive actions” on or after April 1, 2020 and before July 15, 2020. For Notice 2020-23 purposes, “time-sensitive actions” are described, in part, in Revenue Procedure 2018-58, and include key filings such as Forms 5500, 990, and Section 83(b) elections. Because the relief is provided only for filings due during the period from April 1, 2020 to July 15, 2020, certain individuals and plan sponsors will remain subject to normal filing deadlines. For example, the calendar year plan Form 5500 filing deadline (generally July 31, 2020 without extension) is unaffected.
Individuals and plan sponsors may want to review Notice 2020-23 for additional detail and for a more detailed list of affected filings. Notice 2020-23 amplifies Notices 2020-18 and 2020-20 and modifies Revenue Procedure 2014-42.