All of us have been impacted to some degree by the novel coronavirus (COVID-19) and are making changes in our daily lives as we adjust to the new normal. It is also important that taxpayers make every effort to file and pay their taxes based on the currently published deadlines. State and local governments continue to update and develop their policies daily, and failing to pay obligations on time comes with consequences.
Rest assured Ryan will continue to monitor official announcements and developments daily. These developments include extensions of filings and payments, updates on penalties and interest, and closures of revenue agencies and legislatures. Our state-by-state matrix of these developments can be accessed below and will be updated regularly.
If you are considering making a tax decision that may be impacted by the COVID-19 crisis, we recommend that you seek formal advice from a knowledgeable tax professional.
Ryan offers no assurance that the information contained in these summaries is not subject to change or that a local taxing jurisdiction might disagree with our interpretation and treat the tax situation differently.
Ryan believes that the below summaries are accurate, but these items will change over time, and clients are advised to seek independent verification of each item.
Ryan advises you to seek professional tax advice directly from the affected taxing jurisdiction, or from a knowledgeable tax professional, before executing your tax plan.
U.S. Tax Department Operations by Jurisdiction
U.S. Tax Filing Extensions by Jurisdiction
U.S. Property Tax Extensions by Jurisdiction
U.S. Unclaimed Property Updates by Jurisdiction
U.S. Credits and Incentives Relief Programs
Australian Tax Developments
European Tax Developments
Canadian Tax Filing Extensions by Jurisdiction
Canadian Property Tax Payment Extensions
Canadian Government Assistance
COVID-19 News & Insights (United States)
Potential Property Tax Relief in Illinois for COVID-19 Damage (Tax Development)
Ryan is exploring opportunities for property tax relief in Illinois for COVID-19 damage. Under the Illinois Property Tax Code § 200/13-5, taxpayers may apply for reassessment of any taxable property that was “substantially damaged” by a disaster. Read more...
Louisiana Property Tax Relief and COVID-19 (Tax Development)
On March 22, Governor John Bel Edwards issued a shelter-in-place order for the state of Louisiana. Just two days later, he requested and received a major disaster declaration for the state. Both were done based on the soaring number of COVID-19 cases spawning from the outbreak that started in the New Orleans metropolitan area. Read more...
2020 Alabama COVID-19 Impacts Will Be Addressed in 2021 (Tax Development)
The Alabama market has been deeply impacted by COVID-19, especially as it relates to hospitality, retail, multifamily, and office assets. Unfortunately, many jurisdictions in the state have significantly increased values over the last two years as a result of the Alabama Department of Revenue (DOR) updating its appraisal manual. The COVID-19 situation, on top of an increased tax base, adds to the struggle property owners are facing. Read more...
COVID-19 Is Slowing the Remedy for Unconstitutional Property Tax Practices in Delaware (Tax Development)
On May 8, 2020, the Delaware Court of Chancery (“Court”) ruled that the assessment practices of all Delaware counties (New Castle, Kent, and Sussex) fail to comply with state statute and the Delaware Constitution. Delaware statute requires real property to be assessed at its present fair market value, and the Delaware Constitution requires that all taxes be uniform upon the same class of subject properties within the territorial limits of the taxing authority (Uniformity Clause). Read more...
Nashville Property Tax Rate Increase Update (Tax Development)
In March, Ryan began to closely follow the potential 2021 Nashville property tax increases proposed by Mayor John Cooper. On April 28, 2020, the mayor announced his push again via press conference. While the mayor’s first-round budget proposal reflects a possible 32% increase in the property tax rate, the budget and rate must be approved by the Metro Council prior to June 30. Read more...
2020 Dallas/Fort Worth Property Tax Appeals – COVID-19 Crisis Impacts (Tax Development)
Dallas/Fort Worth (DFW) has been one the fastest-growing and desirable real estate markets in the country since we came out of the Great Recession of 2008/2009. Unfortunately, DFW is experiencing the harmful impacts of the COVID-19 “shelter-in-place” orders, resulting in high unemployment and catastrophic losses for hotel owners, retailers, restaurants, and many other businesses. This has put the DFW area chief appraisers in a very tough situation. Read more...
Rent Caps in Washington, D.C. May Complicate the Commercial Real Estate Market (Tax Development)
The D.C. Council approved the COVID-19 Response Supplemental Emergency Amendment Act, which included a provision that prohibits residential landlords from raising rent during the public health emergency. This move brings much needed relief to the individuals suffering from job loss and reduced incomes, as a result of the pandemic. The council took it a step further, and on April 21, extended the proposal to protect commercial tenants from rent hikes during the crisis for the duration of 30 days after the state of the emergency has ended. Read more...
COVID-19 and Transfer Pricing (Article)
As transfer pricing documentation requirements have become pervasive globally, certain transfer pricing positions have also become widespread. Due to the economic downturn caused by COVID-19, at least some of these common transfer pricing positions should be reassessed. One specific position that appears to have become a globally accepted term is low risk distributor (LRD) or low risk service provider (LRSP). This specific theory states that LRDs and LRSPs cannot ever lose money. COVID-19 and the present economic downturn warrant a review of this axiom. Read more...
Opportunity to Reassess California Property Based on COVID-19 Damage (Tax Development)
Given the large losses in market value caused by COVID-19 restrictions in California, reassessment to reflect those losses presents an opportunity for significant relief from property taxation for taxpayers in California. Read more...
COVID-19 Tax Developments in Massachusetts (Tax Development)
This week, the Massachusetts Department of Revenue issued a Technical Information Release (TIR)1 and a Directive2, both relating to issues coming out of the work-from-home orders in the state. The TIR explains that the state will not confer nexus for tax purposes based upon employees working from home. Read more...
Minnesota Department of Revenue Announces No Nexus Filing Requirement for Working from Home (Tax Development)
The Minnesota Department of Revenue (DOR) announced on April 14, 2020 that it will not impose a nexus filing requirement on companies with employees working from home in Minnesota. This is an update to our previous release on April 7, 2020. Minnesota now joins the District of Columbia, Indiana, Mississippi, New Jersey, and Pennsylvania as jurisdictions that will not determine nexus based on employees working from home in their state.
New York Department of Taxation and Finance Temporarily Accepting Digital Signatures on Certain Documents (Tax Development)
The New York Department of Taxation and Finance (“Department”) is temporarily authorized to accept digital signatures in place of handwritten signatures on documents related to the determination or collection of tax liabilities. Governor Cuomo’s Executive Order No. 202.15 and Department Notice N-20-3 provide that the temporary period runs through May 9, 2020. Read more...
New Jersey Real Estate Taxes (Tax Development)
Local Relief from Penalties and Interest
In what could become a growing trend, depending on anticipated tax collection shortfalls, experts at Ryan are aware that one New Jersey municipality is granting forgiveness of penalty and interest on late real estate tax payments. Read more...
Possible Texas Property Tax Exemption for COVID-19 Damage (Tax Development)
Ryan is exploring potential property tax relief as a result of harm caused by COVID-19 to real and business personal property in Texas. Under newly enacted Texas Tax Code § 11.35, taxpayers suffering damage to their property caused by a governor-declared disaster may receive a temporary exemption from a portion of their property tax liability. This exemption is allowed for property that has suffered at least 15% damage caused by a disaster and applies proportionately to property tax liabilities. Read more...
New York 2020-2021 Budget Bill Does Not Adopt the CARES Act Increased Interest Deduction Under IRC Section 163(j) (Tax Development)
As reported by Ryan in a previous article, on March 27, 2020, President Trump signed into law a relief package in response to the economic crisis created by the coronavirus pandemic—the Coronavirus Aid, Relief, and Economic Security Act (HR 748), also known as the CARES Act. Some of the highlights of the CARES Act are the Federal Employee Retention Credit, Net Operating Loss (NOL) and Alternative Minimum Tax (AMT) provisions, and various small and large business relief provisions. Read more...
Tax Incentive Compliance and Confidence During and After COVID-19 (Tax Development)
What the Federal Government has put into place to date is summarized in the following:
- Phase 1 – “Coronavirus Supplemental Appropriations,” which provides financial aid for the federal, state, and local public health response
- Phase 2 – “Families First Coronavirus Response,” which targets relief for individuals, including mandatory, but refundable, paid family leave to small businesses
- Phase 3 – “Coronavirus Aid, Relief, and Economic Security Act” (CARES Act), which is designed to deliver cash to individuals, small businesses, as well as the retail and hospitality industries to help them weather the economic downturn
New Tax Assessments to Be Sent in Cook County, Illinois (Tax Development)
This week, the Cook County Assessor announced that he will restart the clock on this year’s round of property valuations based on the COVID-19 pandemic. New assessment notices will be mailed to property owners in the nine townships that had already been notified from his office earlier this year. With the new assessment notices, the Assessor’s Office will consider the impact that the COVID-19 pandemic has had on the region’s real estate market. Read more...
Colorado Extends Filing Deadlines Because of COVID-19 (Tax Development)
On April 2, 2020, the Governor of Colorado signed an executive order (DOR E.O. 2020-022) extending the 2020 business personal property filing deadline to June 15, 2020. Also extended, to May 15, are the state-level filing deadlines for public utilities, taxable natural resource property, airline and rail transportation companies as well as taxable oil and gas property. The protest period will be adjusted based on this extension. Read more...
Working From Home - Part Two (Article)
In our article posted on March 31, 2020, we noted that working from home could open a Pandora’s box of tax problems when multiple states are involved. The Oregon/Washington border clash was apparent, with Oregon issuing a warning to Washington businesses with employees working at home in Oregon. The outcome could be an unexpected tax bill if state income taxes were not withheld from the Oregon employees. Read more...
Nashville to Increase Property Tax Rate (Tax Development)
On Tuesday, March 31, 2020, Nashville Mayor John Cooper announced during his first State of Metro that he will propose a “sharply” increased property tax rate despite the uncertainty the nation is facing as a result of the ongoing virus and the inevitable recession that will follow. This move is a stark contrast to the rest of the nation that seemingly understands the hardship that the hospitality and entertainment industry is going through—a considerable portion of downtown Nashville’s economy. Read more...
Indiana Coronavirus Property Tax Relief (Tax Development)
On March 19, 2020, Governor Eric Holcomb issued Indiana Executive Order 20-05 (EO 20-05), which extends several Indiana property tax deadlines. Implementation of EO 20-05 has been clarified by additional executive orders as detailed below. Read more...
Working From Home: Impact on Tax Obligations (Article)
As if we weren’t already living in uncertain times, a workforce almost totally on lockdown or sheltering in place comes with potential tax implications for employers. There could be exposure to additional payroll withholding taxes, corporate income tax, and sales tax. Read more...
CARES Act Signed into Law (Tax Development)
On March 27, 2020, President Trump signed into law a relief package developed by lawmakers in response to the global economic crisis created by the coronavirus pandemic. The Coronavirus Aid, Relief, and Economic Security Act (HR 748), also known as the CARES Act, is estimated to be more than $2 trillion in stimulus to protect workers and businesses. Read more...
Pay Your Taxes Timely (White Paper)
Oftentimes during a business crisis, taxpayers overlook their obligations to pay taxes due. Some businesses that find themselves in a cash shortage forget that trustee taxes (sales and payroll taxes) are not the taxpayers’ funds but money that belongs to the government. As government property, they must be remitted timely. Failure to remit trustee taxes, many times, results in severe penalties and sanctions with little to no relief. Read more...
Louisiana Legislature (Tax Development)
Louisiana Governor Suspends All Legal Deadlines; Legislature Recessed until March 31, 2020
On Monday, March 16, 2020, Governor John Bel Edwards issued Proclamation Number JBE 2020-30. The Proclamation suspends all legal deadlines, including administrative agencies and boards, “…until at least Monday, April 13, 2020.” This includes Title 47 of the Louisiana Revised Statutes, which deals with revenue and taxation. Therefore, this will be applicable to the Louisiana Board of Tax Appeals and the Louisiana Department of Revenue. Read more...
COVID-19 News & Insights (Canada)
Government Waives Tariffs on Certain Medical Goods (Tax Development)
On May 6, 2020, Finance Minister, Bill Morneau issued a news release, “Government provides tariff relief to importers of certain medical goods,” which announces that the importation of personal protective equipment (PPE) (e.g., masks and gloves) and other critical medical equipment will not be subject to tariffs. This tariff waiver is part of the government’s efforts to ensure that Canadians have access to PPE and other essential medical equipment and will remain in place until the COVID-19 crisis diminishes. This measure is intended to help protect workers, guarantee a well-functioning supply chain for these items, and may lower the cost of imported PPEs, since tariffs as high as 18% can be levied on these goods.
The Canada Emergency Wage Subsidy (Tax Development)
The Government of Canada has released further details on the Canada Emergency Wage Subsidy (CEWS). The CEWS is intended to help employers of all sizes and from every industry—and their employees—through the challenges created by the COVID-19 pandemic. For eligible employers, up to 75% of employee wages and salaries will be subsidized for a period of 12 weeks, retroactive to March 15, 2020. However, the subsidy is only available to organizations that experience a decrease in revenue of 15% for the period between March 15 and April 11, and 30% in the two subsequent periods. Read More...
Temporary Wage Subsidy for Employers (Tax Development)
Prior to the Canada Emergency Wage Subsidy (CEWS), the Government of Canada announced the Temporary Wage Subsidy for Employers, which is a three-month subsidy allowing eligible employers to reduce their payroll deduction remittances to the Canada Revenue Agency (CRA). Read more...
Canada Emergency Wage Subsidy Calculator Released by the CRA (Tax Development)
The Canada Emergency Wage Subsidy (CEWS) was introduced to help businesses and their employees through the challenges created by the COVID-19 pandemic and received Royal Assent on April 11, 2020. The subsidy, equal to 75% of an eligible employer’s wages and salaries for a period of 12 weeks starting on March 15, 2020, was designed to help a broad group of private sector employers of all sizes and from various industries.
The Canada Revenue Agency (CRA) has now released a CEWS calculator to aid employers with their application for CEWS. This calculator will lead an employer through a process to determine if they are an eligible employer, their eligible employees, the subsidy amount they are entitled to, and how to apply for the subsidy. The CEWS calculator may be accessed on the CRA website at: Canada Emergency Wage Subsidy Calculator
Manitoba Extends Deadline for International Fuel Tax Agreement Tax Returns (Tax Development)
Manitoba has announced in Information Notice Fuel 20-04, “International Fuel Tax Agreement (IFTA) – Extension of IFTA 1st Quarter 2020 Tax Return Due Date”, that it is extending the deadline for filing IFTA returns for the first quarter of 2020 because of the COVID-19 pandemic.
IFTA returns that would ordinarily have been due April 30, 2020 will now become due on July 31, 2020. However, where organizations have outstanding debts prior to the April deadline, interest will continue to accrue on those amounts.
Alberta Extends International Fuel Tax Agreement Quarterly Tax Return Filing Deadline (Tax Development)
Alberta has announced in International Fuel Tax Agreement (IFTA) Special Notice Vol. 10 No. 4, “Extension of Quarterly Tax Return Filing Deadline”, that interjurisdictional carriers will be granted an additional two months to file their IFTA first quarter 2020 returns. Returns previously due on April 30, 2020 will become due on June 30, 2020. Therefore, no penalty will accrue for late returns for the first quarter where the returns are submitted on or before the revised due date.
Although additional time is granted for filing the first quarter 2020 IFTA Quarterly Tax Return, no changes have been made to the due date for related payments. Organizations may need to make an estimated payment to avoid interest accruing on any fuel tax payable for January–March 2020.
Emergency Use of Imported Goods During COVID-19 (Tax Development)
Manitoba Postpones Sales Tax Changes (Tax Development)
On March 26, 2020, Manitoba Premier Brian Pallister announced that, due to financial challenges created by the COVID-19 pandemic, the province will defer the implementation of key sales tax measures announced in its 2020 budget. The provincial sales tax (PST) rate reduction from 7% to 6%, the introduction of a provincial green levy equal to a flat rate of $25 per tonne of carbon dioxide equivalent emissions, and a planned tobacco tax rate increase – all previously scheduled to take effect on July 1, 2020 – have been deferred until further notice.
Further information about these sales tax changes is available in Manitoba Information Bulletin No. 120, “Taxation Changes – 2020 Budget”.
COVID-19: Alberta Defers Tourism Levy Payments (Tax Development)
Alberta recently announced a deferral of tourism levy payments collected under the Tourism Levy Act in Special Notice Volume 7 Number 9, Deferral of Tourism Levy Remittances. Providers of temporary accommodation in Alberta may defer making tourism levy payments that become due between March 27, 2020, and August 31, 2020, with these amounts now being due on August 31, 2020.
Temporary accommodation providers must file all tourism levy returns as required during this period. However, interest that would otherwise have accrued to amounts becoming due during the period where the payment is deferred will not be levied.
However, where payments related to amounts that become due during the period have already been made, the temporary deferral will not apply.
Canadian Property Tax – COVID-19 Relief Measures (Tax Development)
As Canadian governments at all levels continue to respond to the COVID-19 pandemic, many real estate sectors are experiencing the financial impact of temporary closures. As the single largest expense component of rent for tenants and largest fixed operating cost for business owners, property tax is an area that can be mitigated during this time of crisis to provide much needed financial relief. Read more...
COVID-19 GST/HST Remittance Deferral (Tax Development)
On March 31, 2020, the Canada Revenue Agency (CRA) released a set of 11 FAQs to clarify certain elements of the GST/HST remittance deferral relief announced on March 27, 2020 (and discussed in Ryan Tax Alert | Further Federal COVID-19 Relief Measures). Read more...
Further Federal COVID-19 Relief Measures (Tax Development)
On March 27, 2020, the Government of Canada announced additional relief to support Canadian business during the COVID-19 pandemic. The added measures provide for extended tax reporting and remittance deadlines, deferred payment of customs duties, and significant adjustments to the government’s current administrative policies to help taxpayers meet their obligations. This supplemental assistance, which includes further economic initiatives for small and medium businesses, builds on the extensive COVID-19 related support measures previously announced. Read more...
Ontario’s Action Plan: Responding to COVID-19 (Tax Development)
On March 25, 2020, the Ontario government released a one-year economic and fiscal plan in response to the COVID-19 pandemic. The province’s plan focuses on responding to the ongoing pandemic in a manner that protects the health of residents and the economy of Ontario. Read more...
Provincial COVID-19 Economic Response Plans (Tax Development)
Following the Government of Canada’s announcement of its COVID-19 Economic Response Plan on March 18, 2020, several provinces and territories have announced tax relief measures in relation to the pandemic. Below you will find Ryan’s analysis of significant initiatives recently announced by British Columbia, Manitoba, Alberta, and the Northwest Territories. Read more...
COVID-19 Economic Response Plans (Tax Development)
On March 18, 2020, the Government of Canada announced its COVID-19 Economic Response Plan. Under this plan, a commitment was made to provide roughly $27 billion in monetary support to all Canadians. A number of these commitments apply to Canadian workers, while others focus on helping Canadian businesses deal with the economic implications of the Coronavirus pandemic. To date, Québec and Saskatchewan have also announced specific COVID-19 related tax relief measures, with announcements by other provincial jurisdictions expected in the coming days. Read more...
Charities Directorate (Tax Development)
The Canada Revenue Agency (CRA) recently released the notice Coronavirus Disease (COVID-19): Charities Directorate with details on filing deadline extensions for charities. Charities with a T3010, “Registered Charity Information Return” due between March 18, 2020 and December 31, 2020, will have their filing deadline extended to December 31, 2020. The filing extension has been made as part of the Government of Canada’s Economic Action Plan. This extension recognizes that charities will be focusing their resources on assisting Canadians as they deal with the COVID-19 pandemic and will likely require more time to complete their returns.
The CRA also advises charities to register for the secure online My Business Account service to access new digital services available to them while the Charities Directorate’s operations are suspended.