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Analysis

COVID-19: Updated state and local tax due date relief developments

Multistate Tax alert | May 21, 2020

This alert summarizes due date relief provisions of Internal Revenue Service (IRS) Notice 2020-18 and 2020-23; and various state and local responses.

Overview

In response to the Novel Coronavirus (COVID-19) pandemic, state and local governments are employing various strategies to propose due date relief to businesses and individuals through tax guidance and legislation.

While some states have conformed to Internal Revenue Service (IRS) Notice 2020-18 and moved their filing and payment deadline(s) to July 15, others have not provided any guidance or only conform for certain types of taxpayers.1 A few states have provided guidance for fiscal year filers and for estimated payments. A handful of states have granted due date relief but moved the filing and payment deadline(s) to a date other than July 15. A few states have responded to Notice 2020-23, but it remains to be seen whether more states may further revise their payment and due date relief guidance.2

Many jurisdictions have responded to COVID-19 by providing relief beyond the income tax. These states have provided a wide range of relief measures for certain indirect taxes including the sales and use tax as well as a variety of other taxes. The relief granted outside the income tax due date context cannot easily be categorized.

Refer to the PDF on this page for a state-by-state summary of the COVID-19 relief issued to date.3 All updates made since the previous issuance of this alert on May 12, 2020, are highlighted.

Additional state and local considerations

Although many legislatures and taxing authorities are providing due date relief, most states have not yet addressed other timing issues, including extensions with respect to statute of limitations for appealing tax assessments, refund claim denials and determinations by tribunals and administrative processes. In many states, these tim ing issues are statutory and not discretionary. For more information on how state tax controversies may be impacted by COVID-19, please see Deloitte's alert, State Tax Controversies⁠—The COVID-19 Effect.4

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References

1 Notice 2020-18, available here, is further discussed in prior issuances of this alert, available here.

2 Notice 2020-23, available here, is further discussed in prior issuances of this alert, available here.

3 The following is current through May 7, 2020.

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Contacts:

Valerie Dickerson, partner—Deloitte Tax LLP, Washington, DC, +1 202 220 2693

Joe Garrett, managing director—Deloitte Tax LLP, Birmingham, +1 205 321 6062

Shaheen Bakaya, manager—Deloitte Tax LLP, New York, +1 212 436 2594

Amber Rutherford, Senior Manager—Deloitte Tax LLP, Nashville, +1 615 259 1830

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The authors of this alert would like to acknowledge the contributions of Lauren Kim to the drafting process. Lauren is a Tax Senior in the Washington National Tax practice of Deloitte Tax LLP.

For further information, visit our website at www.deloitte.com/us/multistatetax

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This alert contains general information only and Deloitte is not, by means of this alert, rendering accounting, business, financial, investment, legal, tax, or other professional advice or services. This alert is not a substitute for such professional advice or services, nor should it be used as a basis for any decision or action that may affect your business. Before making any decision or taking any action that may affect your business, you should consult a qualified professional adviser. Deloitte shall not be responsible for any loss sustained by any person who relies on this alert.

 

About Deloitte

As used in this document, “Deloitte” means Deloitte Tax LLP, a subsidiary of Deloitte LLP. Please see www.deloitte.com/us/about for a detailed description of our legal structure. Certain services may not be available to attest clients under the rules and regulations of public accounting.

Copyright © 2020 Deloitte Development LLC. All rights reserved.

Multistate Tax alert archive

The Multistate Tax alert archive includes external tax alerts issued by Deloitte Tax LLP's Multistate Tax practice during the last three years. These external alerts highlight selected developments involving state tax legislative, judicial, and administrative matters. The alerts provide a brief summary of specific multistate developments relevant to taxpayers, tax professionals, and other interested persons.

View the list of archived Multistate Tax alerts.

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