March 25, 2020

Mr. Dave Kautter
Assistant Secretary for Tax Policy
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220

Mr. Michael Desmond
Chief Counsel
Internal Revenue Service
1111 Constitution Ave, NW
Washington, D.C. 20224

Re: Information reporting deadlines and other relief relating to the COVID-19 pandemic

Dear Mr. Kautter and Mr. Desmond,

The Securities Industry and Financial Markets Association (“SIFMA”)1 appreciates the opportunity to submit comments on behalf of our member firms during this period of uncertainty and disruption. We would like to thank the Department of the Treasury and the Internal Revenue Service (“IRS”) for the tax filing deadline extension in response to the COVID-19 pandemic, and offer below several other recommendations to help ease the burden on taxpayers, the financial institutions that serve them, and IRS personnel.

Our industry is committed to helping “flatten the curve” and has taken actions to minimize our on-site work force by having employees work from home (“WFH”), where possible, and significantly limiting travel. In addition, several states and municipalities are requiring non-essential personnel and individuals to shelter in place, further limiting the activities of our workforce in many areas. These critical efforts, which are necessary to mitigate the spread of COVID-19, will likely impede SIFMA members’ ability to meet their tax deadlines. Furthermore, due to the worldwide impact of COVID-19, similar circumstances exist for non-U.S. financial institutions with U.S. tax filing and reporting obligations. SIFMA has identified several issues below where we believe relief should be granted to help alleviate the negative impact during this challenging time.

Information Returns and Other Filing Extensions

SIFMA requests that for filing purposes, all information returns required to be filed or corrected pursuant to Chapter 3, 4, and 61 of the Internal Revenue Code be given an automatic blanket extension to July 15. This date would align the filing date for these information returns with the recent IRS guidance under Notice 2020-18, the Relief for Taxpayers Affected by Ongoing Coronavirus Disease 2019 Pandemic. These returns include, but are not limited to, all Forms 1099, 1098, 1042-S, 8966, 2439, etc. Also, extensions requiring a request for IRS approval of an extension should be treated as automatic.

1 SIFMA is the leading trade association for broker-dealers, investment banks and asset managers operating in the U.S. and global capital markets. On behalf of our industry’s nearly 1 million employees, we advocate for legislation, regulation and business policy, affecting retail and institutional investors, equity and fixed income markets and related products and services. We serve as an industry coordinating body to promote fair and orderly markets, informed regulatory compliance, and efficient market operations and resiliency. We also provide a forum for industry policy and professional development. SIFMA, with offices in New York and Washington, D.C., is the U.S. regional member of the Global Financial Markets Association (GFMA).