Last updated April 14, 2020

IRS
Filing and paying 2019 tax return: You’re probably already aware that the April 15 deadline has been pushed back to July 15. This means both filing and paying your taxes: late-payment and late-filing penalties don’t start until July 16.

Audits:
Audits are generally suspended. There are no in-person meetings. IRS will continue to work on refund claims where it can, without meeting with taxpayers. Unless IRS sees an emergency, it will not start any new audits until after July 15.

Collection:
No new collection activity (liens and levies) will take place until after July 15. “Field revenue officers will continue to pursue high-income non-filers  and perform other similar activities where warranted.” This means that if the IRS has identified you as a particular scofflaw, it will not stop its efforts, but most collection officers are sitting on their hands at home and not trying to collect.

Installment Agreements:
Payments due between April 1 and July 15 are suspended. Interest is not suspended, however, so if you can make the payments despite the suspension, it is in your financial interest to do so.

Further information on these initiatives is available here: https://www.irs.gov/newsroom/irs-unveils-new-people-first-initiative-covid-19-effort-temporarily-adjusts-suspends-key-compliance-program

FTB
Filing and paying 2019 tax return

California residents can’t file a state income tax return until they file a federal income tax return. Deadlines for filing and paying the 2019 tax return have been delayed to July 15.

Audits:
FTB will not start new audits until at least after April. Current audits are continuing, using telecommunications rather than in-person meetings. It has announced that it is liberally granting extensions of time to respond to document requests.

Collection:
Wage attachments, bank levies, liens, and field agent calls are suspended through July 15. The FTB is no longer suspending business entities for nonpayment of franchise taxes. If FTB has granted you a financial hardship, the hardship period has been extended through July 15.

Installment Agreements:
Unlike IRS, FTB is not automatically suspending payments. However, if it is a hardship to make your installment payment, you may request a suspension.

Further information on the FTB is available here: https://www.ftb.ca.gov/about-ftb/newsroom/covid-19/help-with-covid-19.html

EDD

Filing and paying current payroll taxes: Employers may request an extension of up to 60 days to file payroll reports and deposit payroll taxes without penalty or interest.

Audits:
There is no published policy.  It is hard to imagine the EDD starting an audit in this climate, however, because so many other tax authorities have curtailed their activities.

Collection:
Again, no published policy, but no collection agents have contacted me since March 1.

Installment Agreements:
There is no published policy, but my clients with installment agreements have had them suspended until further notice.

Further information on the EDD is available here: https://www.edd.ca.gov/about_edd/coronavirus-2019/employers.htm

CDTFA

Filing and paying current sales and other taxes: If your return is due between now and July 31, you have an automatic three-month extension.  If your sales tax liability is less than $50,000, you may request a 12-month, interest-free payment plan.

Audits:
No published policy. Anecdotally, audits are suspended.

Collection:
No published policy.

Installment Agreements:
No published policy.

Further information on the CDTFA is available here: https://www.cdtfa.ca.gov/services/covid19.htm

Courts:
Every courthouse in the state of California is locked to the public. All judicial work is being done by phone.

However, state and federal courts, including the Tax Court, have shut down except for criminal and urgent family matters. Ventura County Superior Court: non-essential hearings and trials have been suspended for 90 days. U.S. District Court, Central District of California: non-emergency hearings are canceled.

The big exception is bankruptcy courts. The courthouses are closed, but cases are being filed, trustee meetings are taking place, hearings are being held. All court business is being done in phone hearings.

This list is far from complete. As always, if you have questions, give me a call.

April 14, 2020

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