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Certain 2018 Form 5500 Due Dates Extended

IRS Notice 2020-23 provides additional time for employee benefit plan sponsors to file 2018 Forms 5500 due on or after April, 1, 2020 and before July 15, 2020. Plans with original due dates or extended due dates falling within this period now have until July 15, 2020 to file their forms.

The IRS's Notice 2020-23 also extends to the Department of Labor's 5500 requirements through Rev. Proc. 2018-58 #40 (Postponement for Federally Declared Disasters) which states "whatever postponement of the Form 5500 series filing due date is permitted by the IRS under section 7508A will also be permitted by the Department of Labor and PBGC for similarly situated plan administrators and direct filing entities."

Note that for certain plans that have not yet been extended during this window, filing an extension for an additional 2-1/2 months on Form 5558 may provide additional time beyond July 15, 2020. Therefore, be sure to review the plan years and due dates carefully before deciding whether to forgo a regular extension application during this time.

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