“There is no terror in the bang, only in the anticipation of it.”– Alfred Hitchcock
In a good year, CPAs fret over due dates. I’m a glass half-full type of guy, but there aren’t too many measures that could be used to call 2020 a good year. (I digress for one moment and thank my wonderful colleagues at the AICPA and the many CPAs who volunteer to assist the profession, with whom I’ve shared the 2020 journey of achievement.)
Although we’re not finished with 2020, we’re already hearing from members about March and April 15, 2021.
Will the IRS postpone those dates much like they postponed the April 15 date in 2020? What is the AICPA’s position? Now I know what Hitchcock meant — the anticipation of March and April 15 is causing “terror!”
Last spring, when the AICPA heavily advocated for a change in the April 15, 2020, due date, I heard from several members who wanted to hold fast. When the AICPA did not advocate for systemic extension beyond July 15, I heard from several more members who wanted automatic extensions until Oct. 15. I even heard from members who wanted automatic extensions until Jan. 15 or April 15, 2021.
Our members are incredibly diverse and equally passionate in their opinions. We are fortunate that our Tax Executive Committee helps us decipher often dissimilar data points and determines the best course of action for the profession.
As you can imagine, moving the filing deadline is highly controversial.
Many members feel that a deadline change is necessary to meet the compressed workload, while others think it is dragging the workload further out, which makes for a more strenuous filing season. Additionally, there will be pressure to hold to April 15 as Tax Day because of federal revenue considerations. From a state conformity perspective, states will also be under pressure to keep to original due dates because of revenue shortfalls.
The IRS has not spoken publicly about possible changes to filing or payment dates for the upcoming tax filing season. Regardless, taxpayers and their advisers should presume that it will be “business as usual” and engage in their customary busy season readiness activities to gear up for the March 15, April 15 and other due dates that we all face. You can track IRS COVID-related impacts at IRS Operations During COVID-19: Mission-critical functions continue.
The AICPA, too, is not currently advocating a change from the normal filing or payment deadlines.
Importantly, our Tax Section continues to ready members for a strategic advantage — during tax filing season and beyond — in demonstrating CPAs’ value as a trusted provider of professional tax and planning services.
Our Annual Tax Compliance Kit of engagement letters, organizers, checklists and practice guides helps members comply with tax laws and effectively serve your clients.
We are closely monitoring the situation with COVID-19 and the impact on taxpayers, the tax community and tax administration. We will make ongoing assessments in early 2021 so that there will be ample time leading up to the March and April deadlines for all impacted parties to make adjustments.
In addition, the AICPA’s tax advocacy initiatives continue to address the issues taxpayers and tax practitioners are currently struggling with, daily, in their IRS interactions.
- Pushing for an expedited and streamlined reasonable cause penalty abatement process for taxpayers affected by the pandemic
- Protecting taxpayers, their representatives and the IRS, by requesting that the IRS extend the expiration date of the Aug. 28, 2020, memorandum (“Temporary Deviation From Handwritten Signature Requirement for Limited List of Tax Forms”) through Oct. 15, 2021
- Stopping the rash of collection levy notices that have escalated quickly (sometimes without an initial notice) to actual levies, and partly relate to the significant IRS mail backlog
- Changing a new IRS power of attorney pilot program that doesn’t facilitate the process, requires more security measures than wet signatures, is time consuming, and doesn’t provide any real benefit to CPAs
- Facilitating the IRS’s development of a new “Online Tax Pro’s Account” that is workable from a CPA’s perspective
Finally, the Tax Executive Committee has created a task force to consider our COVID-19 tax system experiences in 2020 and 2021 — indeed, we have not yet reached the end of those experiences — and recommend tax practice management and systemic changes. Recommendations, however, are likely not to be made until starting in mid-2021 at the earliest.
One of Alfred Hitchcock’s approaches to moviemaking was to “always make the audience suffer as much as possible.” That’s understandable for a director who was known as the “master of suspense,” but not what CPAs are looking for in tax filing season. We are here to help remove some of the drama from the annual tax show.
Edward S. Karl, CPA, CGMA, Vice President of Taxation, American Institute of CPAs