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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.


HHS Revokes Public Comment Requirement on Certain Policy Changes

The U.S. Department of Health and Human Services (HHS) has revoked the Richardson Waiver, eliminating the requirement for public notice and comment on certain policy changes. This decision allows HHS to implement new policies more quickly, potentially affecting healthcare funding rules like Medicaid work requirements. While it speeds up policymaking, it also reduces opportunities for stakeholder input, raising concerns over transparency and unintended consequences for healthcare providers, states, and patients.

Don't Get Caught Dazed and Confused: Another Florida Court Weighs in on Employer Obligations to Accommodate Medical Marijuana Use

A Florida trial court ruled in Giambrone v. Hillsborough County that employers may need to accommodate off-duty medical marijuana use under the Florida Civil Rights Act (FCRA). This contrasts with prior rulings and raises new compliance challenges for employers. With the case on appeal, now is the time to review workplace drug policies.

Corporate Transparency Act to be Re-evaluated

Recent federal rulings have impacted the enforceability of the Corporate Transparency Act (CTA), which took effect on January 1, 2024. While reporting requirements were briefly reinstated, FinCEN has now paused enforcement and is reevaluating the CTA. Businesses are no longer required to submit reports until further guidance is issued. For updates and legal counsel, contact BMD Member Blake Gerney.

Ohio Recovery Housing Operators Beware: House Bill 58 Seeks to Make Major Changes

Ohio House Bill 58 proposes significant changes to recovery housing oversight, granting ADAMH Boards authority to inspect and investigate recovery residences. The bill also introduces a Certificate of Need (CON) program, requiring state approval for major facility changes. OMHAS will assess applications based on cost, quality, accessibility, and financial feasibility. The bill also establishes a recovery housing residence fund to support inspections. For more information, contact BMD attorneys Daphne Kackloudis or Jordan Burdick.

January 2025 Notice of Proposed Rulemaking Brings Notable Changes to HIPAA Security Rule

In January 2025, the U.S. Department of Health and Human Services proposed amendments to the HIPAA Security Rule, aiming to enhance cybersecurity for covered entities (CEs) and business associates (BAs). Key changes include mandatory compliance audits, workforce training, vulnerability scans, and risk assessments. Comments on the proposed rule are due by March 7, 2025.