On April 9, 2020, the IRS announced filing deadline extensions for certain Form 5500s in an effort to provide relief from the impact of COVID-19. IRS Notice 2020-23 extends the Form 5500 filing deadline for retirement and welfare plans subject to ERISA. Please note that this relief only applies to plans with filing deadlines on or following April 1, 2020 and before July 15, 2020. The Notice extends the Form 5500 filing due date for these plans to July 15, 2020. This means that the relief applies practically to plans with filing deadlines occurring prior to July 1, 2020. The most common Form 5500 filing deadline for calendar year benefit plans is July 31, which is the final day of the seventh month after the plan year ended. Plans with a Form 5500 filing deadline of July 31, 2020 or later have not been granted extensions and should plan to file their Form 5500 or extension requests by their filing due date.
This extension of filing deadlines went into effect immediately for ERISA-covered plans, with no need to file extension request forms to be included in this relief. Filing extension requests beyond the July 15, 2020 deadline would require a Form 5558, filed by July 15, 2020.
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