"As a result of the extension of the due date for making a minimum required contribution under Section 3608(a) of the CARES Act, if an employer that is a calendar year taxpayer maintains a single employer defined benefit plan that is subject to Section 430 with a calendar year plan year fails to pay the minimum required contribution for the 2019 plan year by the extended due date of January 1, 2021, then there would be an unpaid minimum required contribution for the 2019 plan year and the employer would become subject to the excise tax under Section 4971(a). Similarly, if the employer fails to pay a required installment under Section 430(j)(3) to satisfy a liquidity shortfall by the delayed due date of January 1, 2021, the excise tax under Section 4971(f) would apply. However, absent the relief provided in this announcement, the due date for the employer's reporting and payment obligations for the excise taxes with respect to these unpaid contributions would be September 15, 2020.
"In order to coordinate the due date for reporting and paying the Sections 4971(a)(1) and 4971(f)(1) excise taxes with the extended due date for paying the minimum required contributions to which those excise taxes apply (January 1, 2021, pursuant to Section 3608(a) of the CARES Act), the Treasury Department and the IRS are postponing the reporting and payment due date for those taxes. The new due date for reporting and paying the Sections 4971(a)(1) and 4971(f)(1) excise taxes with respect to a minimum required contribution to which Section 3608(a) of the CARES Act applies is January 15, 2021.
"This announcement overrides the due date provided on Form 5330 and under the Form 5330 instructions for reporting and paying the excise taxes under Sections 4971(a)(1) and 4971(f)(1) with respect to a minimum required contribution to which Section 3608(a) of the CARES Act applies. This announcement does not apply to the due dates for other excise taxes required to be reported on Form 5330."
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