Extended Employee Benefit Plan Deadlines

When the IRS issued Notice 2020-23, they provided needed guidance for business owners as a result of the extended July 15, 2020 deadline to file and pay taxes. This Notice is specifically regarding the “specified actions” and filing obligations that are normally due on or after April 1, 2020, pushing these back to the July 15, 2020 deadline. The “specified actions” are any time-sensitive actions specified on the Revenue Procedure 2018-58 list, which includes actions having to do with employee benefit plans.    

Your business will automatically be qualified for the July 15, 2020 deadline, so there is no need to worry about submitting additional information to the IRS. If you will still need an extension beyond the July 15 deadline, you will need to submit an appropriate extension form; however, the extension will not go past the usual regulatory extension date.

Highlights for Employee Benefit Plans

Form 5500. The July 15, 2020 deadline includes filing Form 5500 for plan years that have ended in September-November 2019, and any extension request deadlines within that window. It is very important to note that this extension does not include the 2019 Form 5500 July 31, 2020 filing deadline for calendar-year plans. If you need an extension for the July 31 deadline, you may file Form 5558.

Retirement plans. If you need to correct excess contributions, aggregate contributions, and deferrals, the July 15, 2020 deadline apply to you. It also applies to retirement plan loan payments, the 60-day rollover completion timeframe, and filing Form 8955-SSA to give information on any participants of a separated plan with undistributed vested benefits. Since Form 8955-SSA always has the same deadline as Form 5500, the extension applies the same way.  

Health Savings Accounts (HSAs). The 60-day completion timeframe for HAS or Archer Medical Savings Account (MSA) rollovers has been extended. You also have until July 15, 2020 to report any contributions on Form 5498-SA and provide that information to account holders.

As a business owner or plan administrator, you should meticulously review Notice 2020-23 and Revenue Procedure 2018-58 to see what tax relief your business may qualify for. The Notice has may great tax advantages, but some deadlines fall outside of the relief window. Contact us to see what your business qualifies for and how to take advantage of all the relief available.