Extension on 5498-SA Reporting

[JOH]

Has anyone heard that 5498-SA filing deadline has been pushed to August 31?  The only thing I know if that Notice 2020-23 extending the filing and contribution date to 7.15.  We have an HSA sponsoring saying their filing deadline was extended to August 31.

[Lois Baker]

Maybe this?

IRS Notice 2020-23:

"For an Affected Taxpayer with respect to Specified Filing and Payment Obligations, the due date for filing Specified Forms and making Specified Payments is automatically postponed to July 15, 2020.... This relief is automatic ... The Secretary of the Treasury has also determined that any person performing a time-sensitive action listed in ... Revenue Procedure 2018-58 ...  which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action), is an Affected Taxpayer."

Rev. Proc. 2018-58 -- See page 45

[EBECatty]

I was curious about the 5498 deadline too. IRA contributions can now be made until July 15...but the 5498 filing deadline is also July 15. I don't see where there has been any lag time like there typically is after the normal April 15 tax filing deadline. It seems both deadlines (contributions and 5498 filing) are now both extended to the same day.

[JOH]

4 hours ago, EBECatty said:

I was curious about the 5498 deadline too. IRA contributions can now be made until July 15...but the 5498 filing deadline is also July 15. I don't see where there has been any lag time like there typically is after the normal April 15 tax filing deadline. It seems both deadlines (contributions and 5498 filing) are now both extended to the same day.

Hi EBE- that's the way I understood it as well, that Individual tax filing and the 5498 filing have the same extension date of 7.15 and not August.  Thanks

[Bill Sweetnam]

Lois has it right.  Internal Revenue Code sections 7508 and 7508A provide for the automatic postponement of certain deadlines under the Code by reason of a presidentially declared disaster.   IRS Rev. Proc. 2018-58 lists the tax deadlines that will be automatically postponed under these Code sections; Section 8.13 of the Revenue Procedure provides that the filing date of the IRS Form 5498-SA is one of the tax deadlines that is automatically postponed pursuant to Code section 7508 and 7508A.  IRS Notice 2020-23 provides that, due to the COVID-19 pandemic, everyone is under a presidentially declared disaster, so any person that has to meet a deadline under the Code between April 1, 2020 and July 15, 2020 has until July 15, 2020 to take the action to meet that deadline.    Consequently, IRS Form 5498-SA that was required to be filed by May 31, 2020, will now have to be filed by July 15, 2020.

[EBECatty]

13 hours ago, Bill Sweetnam said:

Lois has it right.  Internal Revenue Code sections 7508 and 7508A provide for the automatic postponement of certain deadlines under the Code by reason of a presidentially declared disaster.   IRS Rev. Proc. 2018-58 lists the tax deadlines that will be automatically postponed under these Code sections; Section 8.13 of the Revenue Procedure provides that the filing date of the IRS Form 5498-SA is one of the tax deadlines that is automatically postponed pursuant to Code section 7508 and 7508A.  IRS Notice 2020-23 provides that, due to the COVID-19 pandemic, everyone is under a presidentially declared disaster, so any person that has to meet a deadline under the Code between April 1, 2020 and July 15, 2020 has until July 15, 2020 to take the action to meet that deadline.    Consequently, IRS Form 5498-SA that was required to be filed by May 31, 2020, will now have to be filed by July 15, 2020.

 

I follow this much. My question has to do with filing them (or, in my case, 5498 reporting IRA contributions) on the same day as the tax filing (and IRA contribution) deadline. Usually there's a month and a half between the contribution deadline (April 15) and the 5498 filing date (end of May). I don't see how it's possible to provide and file accurate forms by the same day as the contribution deadline. It seems that the 5498 filing deadlines should be extended until the end of August to keep the same month and a half preparation period, but I don't see anything that has extended the 5498 filing deadline beyond July 15.

[Bill Sweetnam]

In order for there to be a further extension, the IRS would have to affirmatively issue new guidance with that extension.  The reason behind Code section 7508 and 7508A was that the there was an automatic extension of time in presidentially declared disaster areas and for other purposes.  So if that automatic extension is not helpful, the industry would have to ask the IRS to issue guidance for a further delay of the 5498 filing deadline.  They are pretty busy at the IRS and Treasury on a lot of issues dealing with the effects of the COVID-19 pandemic, so it might be difficult for this issue to be considered a priority.