The IRS issuance of Notice 2020-17 is important first step into providing COVID-19 specific relief under Code section 7508A, which permits (but does not require) Treasury to postpone various deadlines under the Code for benefit related (and other) provisions following a federally declared disaster.
The availability of this relief was of some question as the President issued an “emergency” (rather than a “disaster”) declaration under the Stafford Act. Although the guidance is limited to postponing federal income tax payments from April 15, 2020 until July 15, 2020, it may signal future guidance for benefit related relief. Notably, this extends the payment (but not the filing) of Form 990-T unrelated business income taxes (UBIT) for calendar year qualified plans and IRAs (but not other tax-exempt organizations). Revenue Procedure 2018-58 sets forth the possible provisions that could be postponed, which includes 44 items related to employee benefits, including Form 5500 reporting relief, IRA contribution relief, minimum required distribution relief, loan repayment relief, etc. So stay tuned!