Earlier this year the Internal Revenue Service (“IRS”) extended April 15, 2020 tax filing deadlines in an effort to help individuals and businesses adversely affected by the COVID-19 public health crisis. Recently, the extension was expanded to deadlines associated with retirement plans. IRS Notice 2020-23 (“Notice”) extends several plan-related deadlines ordinarily occurring between April 1, 2020 and July 14, 2020. If a deadline falls within that period, it was extended to July 15, 2020.

The extension applies to the following:

  • Defined contribution plan loan repayments.
  • IRS Form 5500 filing deadline for plan years that ended in September, October or November of 2019. The deadline for calendar year plans remains July 31, 2020.
  • Excess contributions to retirement plans and deferral corrections, as well as HSA and MSA distributions.
  • Indirect rollovers for distributions taken between February 1, 2020 and May 15, 2020.
  • ESOP elections and distributions.
  • Required Minimum Distributions under Code Section 401(a)(9).
  • Certain early withdrawal penalty relief under Code Section 72(t).
  • The deadline to make contributions to an HSA or MSA for 2019.

Nyhart will continue to monitor the situation as it relates to retirement and health and welfare plans. If you have any questions, please contact your Nyhart consultant for more information.