CARES Act and Tax Update

Blog post #438

The IRS, Federal Reserve, Congress and the President have enacted various measures in response to Covid-19. The goal in this post is to provide you with a summary of key information that could be most relevant to you.

Income Tax Return and Payment due dates delayed

The normal Federal tax deadline of April 15, 2020 for filing tax returns and making payments has been moved to July 15, 2020. Most states have made the same change.

  • You do not need to file any extension.
  • You don’t need to make payments that would have been due on 4/15/20…until July 15, 2020, if you owe money or would have needed an estimated payment for 1 Qtr. 2020.
  • The due date for funding a 2019 IRA or Roth IRA is now July 15, 2020.
    • Key point: If you intend to do this, you should make your deposit now…while the market is low (maybe it will be higher in July, we don’t know).
  • However, the 2nd quarter estimate due date of June 15, 2020 still applies….. so yes, that is now due before the 1st quarter due date of 7/15/2020. Leave it to the IRS!
  • If you usually have withholdings from IRA Required Minimum Distributions, you may not need to take the RMD in 2020, so you may need to pay estimated taxes in 2020. Discuss this with your CPA or tax preparer.
  • For more information on these changes, see the following link for a more detailed Q&A.

CARES ACT

The CARES Act was signed into law about a week ago and will impact almost everyone in the US. We are trying to provide a summary of the most relevant information of wide-ranging legislation, that impacts businesses, individuals, and others.

Within a day after the bill passed the Senate, one of the thought leaders of our national firm, Jeffrey Levine, produced a 25-page detailed summary (if a 25-page article can be both detailed and a summary!). We are providing a link here to the website, where you can find a PDF of Jeff Levine’s article. Jeff is the Director of Advanced Planning for Buckingham Strategic Partners, our national back office firm. Jeff is one of the country’s top financial planning’s experts. The link is at Kitces.com, where Jeff and his partner, Michael Kitces, write lengthy articles on financial planning. Michael is one of the top national speakers on financial, tax and estate planning, and both are great additions and resources to our firm, as they are now part of our national alliance partner firm.

As each topic is addressed below, if you want more detailed information, please see the instructions at the bottom of the post on how to access the PDF article* to view the appropriate page within the PDF.

Recovery Rebates for Individuals:

  • Married joint filers to receive $2,400, other filers receive $1,200, increased by up to $500 per child under age 17.
  • However, high income taxpayers will not receive any money at all.
    • Phaseouts are based on your AGI (adjusted gross income) for 2018, or 2019, if you have filed a 2019 income tax return, beginning at the following levels:
        • Married Joint: $150,000
        • Head of Household: $112,500
        • All other filers: $ 75,000
    • The exact amount of the phaseout depends on how many children you have under the age of 17.
    • See chart on top of page 8 of the PDF, for more details on the refundable tax credits.
  • The initial “recovery rebate amount” will be based on whatever income tax return you have filed, either 2018 or 2019, subject to when the IRS processes your return, and when they process/review whether you are eligible.
    • The rebate amount will later be adjusted based on your actual 2020 federal income tax return.
    • Unfortunately, if you earned $200K in 2018 and 2019, but expect to earn only $75,000 in 2020 due to this outbreak, you will not get a recovery check until mid-2021. However, if you make more in 2020 than in prior years, you won’t have to pay back the excess.
    • Key point: If you earned significantly less in 2019 than in 2018 or would fall below the above threshold levels for 2019, but not in 2018, it would make sense to file your 2019 Federal income tax return as soon as possible. 
    • Key point: If you had a baby or adopted a child in 2019, you should file your 2019 Federal income tax return as soon as possible, if you think you will qualify for a recovery payment.
    • See pages 6-10 of the PDF for more information on the refundable tax credits.
  • No one knows the exact date of when these payments will be issued. They may not be issued until May.
    • If the IRS has a bank account on file that was used for a 2018 or 2019 direct deposit refund or withdrawal, they will use that bank account.
    • If the IRS does not have a bank account on file, and you are eligible, it will be mailed to your last address of record.

Required Minimum Distributions are Waived in 2020:

  • Key point: If you are subject to taking a Required Minimum Distribution (RMD) from a retirement plan, such as an IRA or 401(k), which is generally those over age 70 ½, you don’t need to take an RMD for 2020.
    • We will discuss this with each of our clients as 2020 progresses. 
    • Key point: If you don’t need the RMD money for living expenses, this can substantially reduce your 2020 income taxes and allow you to keep the RMD amount in your IRA.
    • If you have already taken your RMD in the past 60 days, there are ways to return the funds, if you don’t need them. Contact us to discuss this!
    • Key point: If you will not be taking an RMD for 2020, but in past years you have used the RMD for your federal or state withholdings, you should contact us or your tax preparer, to discuss paying tax estimates, the first of which will be due on 6/15/2020.
    • This also applies to those who are beneficiaries of stretch distributions, for IRAs you received upon an inheritance.
    • For more information, see pages 11-15 of the PDF.

Business provisions:

  • Key point: If you have a small business and have been impacted by Covid-19, you should carefully review these provisions as soon as possible. Time is important.
    • Business owners should likely contact their CPA for guidance, as these programs interact, and you cannot do all of them. 
  • There are several different programs.
    • Today, April 3, the Paycheck Protection Program and forgivable loan program is scheduled to begin accepting applications via SBA approved banks. As of now, this is to be handled on a first-come, first serve basis. The final loan application has not been released as of Thursday am. These loans are forgivable if a business keeps their workforce largely intact and use the loans for eligible expenses such as payroll, rent and utilities. There is no guidance as to how fast these loans will be processed and funded.
    • If you have a business of less than 500 employees, you should review the provisions on pages 20-24 of the PDF, and evaluate which of the following makes the most sense for your situation, with your advisors:
      • Paycheck Protection Program,
        • If your business get this loan, it is not eligible for the next two items.
      • Employee Retention Credit for Employers,
      • Deferral of payment of payroll taxes, and
      • Net Operating Loss rules changed
  • Due date for funding pension plan contributions for calendar year 2019 plan year is extended to January 1, 2021.

Unemployment Compensation Benefits Expanded:

  • Key point: Self-employed individuals and others who are generally not eligible for unemployment, will now be eligible for up to 39 weeks of benefits.
    • This is a major change and can benefit many individuals who have been impacted, who run their own businesses. Think of independent contractors, consultants, hairdressers, massage therapists, people who own small retail stores, etc. 
  • Unemployment benefits can be increased by states by up to an additional $600 per week, for up to four months, to be funded by the federal government. This will be in addition to whatever state benefit you would be eligible for.
  • If you are now unemployed or have no revenue due to the state mandated shutdowns, you should check online with your state unemployment website. They may not yet be updated to provide for the self-employed provisions (MI was not as of a few days ago), but you should try to apply as soon as possible.
  • Unemployment compensation has been extended to 13 weeks.
  • See pages 19-20 of the PDF.

Coronavirus-Related Distributions:

  • You can take up to $100,000 in distributions from an IRA, employer-sponsored plan (like a 401(k) or 403(b) or a combination of both, during 2020, if you have been significantly impacted by Covid-19 (definition is broad, but there are guidelines).
    • These are exempt from the 10% penalty, for those under age 59 ½.
    • The distributions are not subject to normal 20% federal withholding rules.
    • They can be repaid within 3 years, if you want to. If you pay tax on a distribution and then repay the distribution within 3 years, you can go back and claim a tax refund.
    • They are subject to taxable income, either all in 2020 (if you estimate that this would be the lowest income year) or spread evenly over tax years 2020, 2021 and 2022.
    • See pages 11-12 of the PDF for more details

Loans from Employer Sponsored Retirement Plans:

  • You can borrow $100,000, increased from the normal $50,000. Payments can be delayed for up to one year. See page 13 of the PDF for more details.

Charitable Contributions:

  • If you no longer can itemize, you can now deduct $300 of cash charitable contributions beginning in 2020.
  • If you can afford to make major charitable contributions, and are so inclined to do so, you can deduct up to 100% of your AGI for “qualified charitable contributions” in 2020.
    • If you contribute more than your AGI, the excess can be carried forward 5 years.
    • Contributions to donor advised funds and family charitable foundations are prohibited.
    • Key point….we all know there is great need at this time….if you are so charitably inclined, please contact us or your tax advisor to discuss this impact.

Student Loan Borrowers:

  • Provisions include payment deferral until September 30, 2020, for which no interest will accrue, but it appears you must contact your loan provider, as well as employers can pay up to $5,250 of student loan obligations and that will be excluded from compensation. Please review pages 16-18 of the PDF.

Medical and Healthcare Provisions:

  • The items for “qualified medical expenses” for HSAs, MSAs and FSAs have been expanded, to include over the counter medications and female care products.
  • Other items, such as Covid-19 related expenses and telehealth services are considered covered. See pages 18-19 of the PDF.

For a chart and overall summary, see top of page 4 of the PDF, which covers rebates, IRA distributions, other provisions, unemployment compensation, and small business benefits.

There are likely to be changes to some of these items and this article does not cover all provisions of the CARES Act. Please consult with us or your tax professional before making any decisions.

Please forward this to others who may find it helpful, especially small business owners and those who can benefit from the new self-employed unemployment compensation, as those people may not be aware of these new provisions.

Source:

*Click on article link above.  Once you reach the article, click the printer and then choose PDF.  After choosing PDF, a box will pop up and you will click download your PDF.  Then you will want to save the PDF to your desktop.  After saving to your desktop, you will see a PDF saved as kitces.com… The CAREs….  Click on this to view the PDF.

0 replies

Leave a Reply

Want to join the discussion?
Feel free to contribute!

Leave a Reply

Your email address will not be published. Required fields are marked *