Form 5500 Relief Deadline Approaching

The IRS issued Notice 2020-23 which addresses Form 5500, Annual Return/Report of Employee Benefit Plan filings due between the period April 1, 2020, through July 15, 2020. This relief does not include calendar year end 2019 Form 5500 filings due July 31, 2020.

The relief is for Form 5500 filings that were either due to be filed originally or through an extension. The relief due date for filings has been extended to July 15, 2020. The extension automatically applies to Form 5500 filings for plan years that ended in September, October or November 2019 because the regular due dates for these filings would have been, respectively, April 30, June 1 (because May 31 was a Sunday), and June 30, 2020; these filings are now due July 15, 2020.

Taxpayers do not need to file official extension forms or send other documents requesting the relief. However, additional filing extensions beyond July 15 must be requested using the appropriate extension form by July 15, but the extension may not go beyond the original or regulatory extension date.

Notice 2020-23 states that Specified Time Sensitive Actions are covered and refers taxpayers to Rev. Proc. 2018-58 which explicitly addresses Form 5500.