IRA and Benefit Plan Contribution Deadlines Extended to July 15

Blog
March 25, 2020

With the recent extension of the April 15th Federal and State tax filing deadline in Notice 2020-18, many questions remained specifically related to whether various IRA and employer plan deposit deadlines would follow the extension. The IRS recently published guidance in a Q&A format to address many of these questions confirming that the deposit timing rules for IRAs, company sponsored retirement plans and HSAs will follow the tax filing extension of July 15.

Here is a list of the relevant deposit timing questions and answers related to IRAs, company sponsored retirement plans and HSAs pulled directly from the IRS resource.

Q.17 Does this relief provide me more time to contribute money to my IRA?

A17. Yes. Contributions can be made to your IRA, for a particular year, at any time during the year or by the due date for filing your return for that year. Because the due date for filing Federal income tax returns has been postponed to July 15, the deadline for making contributions to your IRA for 2019 is also extended to July 15, 2020. For more details on IRA contributions, see Publication 590-A, Contributions to Individual Retirement Arrangements (IRAs).

With the recent extension of the April 15th Federal and State tax filing deadline in Notice 2020-18, many questions remained specifically related to whether various IRA and employer plan deposit deadlines would follow the extension. The IRS recently published guidance in a Q&A format to address many of these questions confirming that the deposit timing rules for IRAs, company sponsored retirement plans and HSAs will follow the tax filing extension of July 15.

Here is a list of the relevant deposit timing questions and answers related to IRAs, company sponsored retirement plans and HSAs pulled directly from the IRS resource.

Q.17 Does this relief provide me more time to contribute money to my IRA?

A17. Yes. Contributions can be made to your IRA, for a particular year, at any time during the year or by the due date for filing your return for that year. Because the due date for filing Federal income tax returns has been postponed to July 15, the deadline for making contributions to your IRA for 2019 is also extended to July 15, 2020. For more details on IRA contributions, see Publication 590-A, Contributions to Individual Retirement Arrangements (IRAs).

This applies to all IRA contribution types including SEP IRAs.

Q.20 For employer with a federal income tax return due April 15, 2020 , is the end of the 404© grace period under section 404(a)(6) to make contributions to their qualified retirement plans on account of 2019 also July 15, 2020 as a result of this relief?

A20. Yes, because these employers are Affected Taxpayers under Notice 2020-18 for whom the due date for filing Federal income tax returns and making Federal income tax payments that would be due April 15, 2020, is now July 15, 2020, the end of the grace period for these employers is also July 15, 2020 under this relief.  So, for example, if an employer is a corporation with an April 15, 2020 due date for filing the Form 1120, then the grace period under section 404(a)(6) for the employer to make contributions to its workplace-based retirement plan that are treated as made on account of 2019 ends on July 15, 2020.

This applies to all types of employer sponsored qualified retirement plans.

Q.21 Does this relief provide me more time to contribute money to my HSA or Archer MSA for 2019?

A21.  Yes. Contributions may be made to your HSA or Archer MSA, for a particular year, at any time during the year or by the due date for filing your return for that year. Because the due date for filing Federal income tax returns is now July 15, 2020, under this relief, you may make contributions to your HSA or Archer MSA for 2019 at any time up to July 15, 2020.  For more details on HSA or Archer MSA contributions, see Publication 969, Health Savings Accounts and other Tax-Favored Health Plans.

If you have questions about the above deposit timing deadline changes, please contact Mark Flanagan of Aronson’s Compensation and Benefits Practice at 301.231.6257.