New and Important International Tax Issues Related to the Coronavirus Pandemic

April 9, 2020

Hal Webb, Jennifer Wioncek, and Paul D'Alessandro, Jr. host a webinar to discuss U.S. tax residency issues for those who may be unable to leave the U.S., updates to the CARES Act, U.S. international information reporting deadlines and extension matters, and how to finalize and execute on estate plans during the shutdown.  

Responding to COVID-19, Webinar Update: After the conclusion of this webinar, the IRS issued Notice 2020-23 and announced it is working to update Frequently Asked Questions further expanding the relief previously issued by IRS Notices 2020-18 and 2020-20.  Notably, IRS Notice 2020-23 clarifies that the automatic extension relief applies to Specified Forms (as defined therein) as well as all schedules, returns, and other forms that are filed as attachments to Specified Forms or are required to be filed by the due date of such Specified Forms, including IRS Forms 3520, 5471, 5472, 8621, 8858, 8865, and 8938 and that quarterly estimated income tax payments due before July 15, 2020, are automatically postponed to July 15, 2020.  Notice 2020-23 does not specifically address payment of withholding tax on effectively connected taxable income allocable to foreign partners (IRS Form 8813).
Further, elections that are made or required to be timely filed on Specified Forms will be deemed timely made if filed on or before July 15, 2020.  The calculation of interest, penalties, and additions to tax for failure to file Specified Forms or failure to file pay Specified Payments will disregard the period of April 1, 2020 through July 15, 2020.
Notice 2020-23 can be found here.


For access to the video, please email


This information is intended to inform our clients and other friends about legal developments, including recent decisions of various municipalities, legislative, and administrative bodies. Because of the rapidly changing landscape related to COVID-19, we intend to send out regular updates. The information we provide is not intended as legal advice and viewers/readers should not rely on information contained in these materials to make business or legal decisions. Before making any legal decisions, consult your lawyer. Please do not hesitate to contact us should you need assistance responding to the many issues which have arisen, and will continue to arise, out of this situation.



Hal J. Webb
Jennifer J. Wioncek
Practice Group Leader, Tax & Private Wealth
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