IRS expands filing and payment deadline extension

Still no extension for estimated tax


Authored by RSM US LLP

Yesterday, the Internal Revenue Service (IRS) announced expanded relief for certain other deadlines that individuals would normally have to meet by April 15. Notice 2021-21 describes additional tax deadlines which are now postponed until May 17, and lists other related deadlines that are now postponed until June 15, 2021. Affected Taxpayers do not have to file any form, including Form 4868, Application for Automatic Extension of Time to File U.S. Individual Income Tax Return, to obtain this relief.  

On March 17, 2021 the IRS had announced a postponement of the filing deadline for income tax returns of individuals (the Form 1040 series of returns) and the payment of 2020 income taxes by such taxpayers, from April 15, 2021 to May 17, 2021. The IRS has clarified in the Notice 2021-21 that relief includes the filing of all schedules, returns and other forms that are filed as attachments to the Form 1040 series or are required to be filed by the due date of the Form 1040 series, including, for example, Schedule H and Schedule SE, as well as Forms 965-A, 3520, 5329, 5471, 8621, 8858, 8865, 8915-E and 8938. In addition, elections that are made or required to be made on a timely filed Form 1040 series (or attachment to such form) will be timely made if filed on such form or attachment, as appropriate, on or before May 17, 2021. Notice 2021-21 makes clear that the postponement includes the filing and payment obligations of foreign trusts and estates with federal income tax filing or payment obligations that file Form 1040-NR.

In addition, the new announcement applies the postponed deadline to 2020 contributions to Individual Retirement Accounts (IRAs and Roth IRAs), Health Savings Accounts (HSAs), Archer Medical Savings Accounts (Archer MSAs) and Coverdell Education Savings Accounts (Coverdell ESAs). Thus, an individual has until May 17 to make deductible or nondeductible IRA contributions or deductible HSA contributions, treat the contributions as having been contributed for the 2020 tax year, and take any applicable tax deductions on the taxpayer’s 2020 tax return.  

Likewise, the due date for filing Form 5329 to report early withdrawals from IRAs and qualified retirement plans (such as 401(k) plans) has been extended to May 17, 2021.

The due date for Form 5498 series returns related to these retirement and savings accounts is postponed from June 1, 2021 to June 30, 2021 under the Notice. Such returns include Form 5498, IRA Contribution Information, Form 5498-ESA, Coverdell ESA Contribution Information, and Form 5498-SA, HSA, Archer MSA, or Medicare Advantage MSA Information.

Notice 2021-21 also postpones the date that a claim for refund for the tax year 2017 must be made. A taxpayer must file a claim for refund within three years of the date the original return was filed, which is typically April 15. For tax year 2017 individual income tax returns, the deadline to claim a refund has been postponed to May 17, 2021. 

The Notice does not alter the April 15, 2021, deadline for estimated tax payments for the first quarter of 2021; these payments remain due on April 15, 2021.