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COVID-19 Benefit Plan Opportunities

The Pension Benefit Guaranty Corporation (PBGC) announced the IRS has extended deadlines for upcoming premium payments and other filings with the agency. This extension only applies to filings due before July 15, 2020. It does not extend to calendar year 2019 Form 5500 filings originally due July 31, 2020.

The IRS issued Notice 2020-23 to provide additional filing relief for taxpayers affected by the ongoing Coronavirus pandemic. Due dates for filings or actions that would otherwise have been due on or after April 1, 2020, and before July 15, 2020, have been extended to July 15, 2020. The relief is automatic, and taxpayers do not have to call the IRS, file extension forms, or send letters or other documents to receive this relief. Additional filing extensions beyond July 15 must be requested using the appropriate extension form by July 15, but the extension may not go beyond the original or regulatory extension date.

“The PBGC understands the far-reaching effects COVID-19 is having on workers, families, and companies across the country,” PBGC Director Gordon Hartogensis said. “This move will offer flexibilities to deliver relief that many employers and pension plan service providers need during this unprecedented time.” the extended due dates do not apply to particularly important or time-sensitive filings on the “Exceptions List” that may indicate a high risk of harm to pension plan participants or the insurance program, but such filers may request individual extensions.


References: 1 CARES Act of 2020, H.R. 748, 116th Cong. § 2202 (2020)  2 CARES Act of 2020, H.R. 748, 116th Cong. § 2203 (2020)  3 CARES Act of 2020, H.R. 748, 116th Cong. § 3607 (2020)  4 CARES Act of 2020, H.R. 748, 116th Cong. § 3608 (2020)  5 CARES Act of 2020, H.R. 748, 116th Cong. § 3609 (2020)

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