On March 25, 2020, the Illinois Department of Revenue (“IDOR” or “Department”) announced the extension of certain income tax filing and payment deadlines in response to the COVID-19 outbreak, in light of the federal government providing similar taxpayer relief in Notice 2020-18. The IDOR issued Informational Bulletin FY 2020-24 (the “Bulletin”) outlining its guidance to date. A summary of this guidance as well as additional commentary follow.
Automatic Extension to July 15, 2020
Pursuant to the Bulletin, taxpayers filing income tax returns and making corresponding income tax payments due April 15, 2020 will be allowed an automatic extension for such filings and payments to July 15, 2020. Therefore, as stated in the Department’s announcement, taxpayers do not need to communicate with or send any specific form to the IDOR to obtain an extension.
Relative to eligible taxpayers, the Bulletin indicates the automatic extension applies specifically to individual, C corporation and trust income tax returns and associated income tax payments due April 15, 2020. With regard to partnerships, based on the Bulletin’s language as well as initial informal guidance from the Department, since partnerships pay a personal property tax replacement income tax (“replacement tax”) at the entity level, it is unclear at this time whether such taxpayers will be afforded an automatic extension to July 15, 2020 to file partnership returns and make replacement tax payments. We expect more clarity from the IDOR concerning partnership returns and payments in the coming days, including for example, income tax payments due by partnerships on behalf of nonresident partners (i.e. withholding).
The automatic extension relief does not apply to either first or second quarter estimated income tax payments due April 15 and June 15, 2020.
The Department will continue to process refunds for those taxpayers filing ahead of the new deadline. In fact, all taxpayers are encouraged to file returns and request any refunds as soon as possible as well as to do so electronically by requesting direct deposit into a checking or savings account.
If you have additional questions, please contact FGMK’s State and Local Tax (“SALT”) team.
Matthew T. Fuller
The summary information in this document is being provided for education purposes only. Recipients may not rely on this summary other than for the purpose intended, and the contents should not be construed as accounting, tax, investment, or legal advice. We encourage any recipients to contact the authors for any inquiries regarding the contents. FGMK (and its related entities and partners) shall not be responsible for any loss incurred by any person that relies on this publication.
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