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IRS Grants Additional Extensions and Suspends Collection Activity

Client Alert

More Extensions Granted for Filing Returns

In addition to those previously announced, the IRS has granted extensions for filing of the following returns and payments of amounts due for any of the returns listed below due after April 1, 2020 and before July 15, 2020:

  • Form 706 - Estate and Generation-Skipping Transfer Tax;
  • Form 8971 – Information Regarding Beneficiaries Acquiring Property form a Decedent;
  • Form 709 – United States Gift (and Generation-Skipping Transfer) Tax;
  • Any Estate Tax payment due as a result of an election under sections 6166, 6161, and 6163;
  • Form 990-T – Exempt Organization Business Income Tax;
  • Form 990-PF – Return of Private Foundation or Section 4947 Trust;
  • Form 4720 – Return of Certain Excise Taxes; and
  • All estimated payments made on Form 990-W; 1040-ES, 1041-ES, 1120-W.

(This is a change from the extension of only the first quarter estimate to include the June 15, 2020, estimate).

Collection Actions

The IRS is suspending most collection actions between April 1, 2020 and July 15, 2020.  The specific actions are outlined below:

  • Installment Agreements
    • Those which are currently in place will have all payments suspended between April 1 and July 15. However, if you are paying by automatic debit, you must contact your bank to suspend the payment.  If you do so, please remember to contact your bank to have payments resume in July.
    • New installment agreements may be submitted on the IRS website for those eligible to automatically be qualified for an installment arrangement. All others will not currently be processed.
  • Offers in Compromise
    • Those with pending OICs will have until July 15 to provide any requested information. No request will be closed before July 15 unless the taxpayer has requested the closure;
    • All payments under current OICs may suspend payments until July 15. Be advised that interest continues to accrue during this period;
    • Any current OIC will not be defaulted for failure to file their 2018 return provided they file the return on or before July 15; and
    • New OIC applications may be filed but will not be worked. As a practical matter, these applications should not be prepared or submitted until closer to the July 15 date in order to avoid having to provide updated information.
  • Liens, Levies, and Passport Certifications
    • Automated liens and levies will be suspended during this period;
    • Liens and Levies initiated by field revenue officers will be suspended;
    • High income non-filers will continue to have collection actions during this period; and
    • New certifications to the Department of State for passport holds will be suspended during the period.
  • Private Debt Collection has not been suspended. However, from a practical standpoint there may not be much if any activity from private debt collectors.
  • Audits and Appeals
    • All in-person meetings have been suspended, but examiners will continue to work on matters remotely. Taxpayers are encouraged to respond to any correspondence they receive if they are able.
    • New audits (including correspondence audits) will not be started UNLESS the IRS deems it necessary to protect the government’s interest.
    • Appeals officers will continue to work cases. Conferences will be held by telephone or videoconference.

For questions, or more information, please contact BMD Tax Member, Priscilla Grant at pag@bmdllc.com or 330.253.5934.


Supreme Court Eliminates Higher Burden for Majority-Group Plaintiffs in Title VII Claims

In Ames v. Ohio Department of Youth Services, the U.S. Supreme Court unanimously ruled that all Title VII plaintiffs, whether from majority or minority groups, must meet the same evidentiary standard. The decision eliminates the “background circumstances rule” and reinforces equal treatment in workplace discrimination claims.

Blue Cross Blue Shield Provider Settlement Opportunity

A proposed $2.8 billion settlement in the Blue Cross Blue Shield Antitrust Litigation may offer payments to eligible healthcare providers who delivered services between July 24, 2008 and October 4, 2024. Claims must be submitted by July 29, 2025.

Understanding Reasonable Fear vs. Credible Fear Interviews: A Critical Guide for Immigrants Facing Removal

In his latest article, Immigration Attorney and former Immigration Judge Rob Ratliff offers a clear breakdown of Reasonable Fear vs. Credible Fear Interviews—key procedures for noncitizens seeking protection from persecution or torture. Citing Judge Brian Murphy’s recent ruling on unlawful deportations to South Sudan, Ratliff connects these critical legal standards to current judicial developments. Read the full article at www.removal-defense.com.

House Republicans Propose Cuts to Medicaid to Finance Savings

House Republicans have introduced legislative language that proposes substantial cuts to the Medicaid entitlement program, aiming to achieve significant budget savings through policy changes. The proposed measures include stricter eligibility verification, work requirements for certain adults, and federal funding cuts to states providing coverage to undocumented residents. The Congressional Budget Office (CBO) estimates that the proposed healthcare provisions would reduce spending by $715 billion and could result in 8.6 million fewer people having health insurance by 2034.

Protecting Your Image in the Age of AI-Generated “Deepfakes”

The rapid evolution of artificial intelligence (AI) has transformed how we create and consume digital content, but it also poses significant risks. Among the most troubling developments in AI is the proliferation of AI-generated fraudulent content, often called “deepfakes”.