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Internal Revenue Manual Part 3. Submission Processing · 2026-10-03 edition · updated 2026-10-04 · United States

The CARES Act, authorized advance payments of the Credit for Qualified Sick and Family Leave Wages. Advance payments of these credits was associated with wages paid after March 31, 2021 but before October 1, 2021. The CARES Act authorized advance payments of the ERC. Advance payments of the ERC associated with wages paid after June 30, 2021 and before January 1, 2022. The American Rescue Plan Act of 2021(ARP), included a provision authorizing advance payments of the COBRA premium assistance credit. See, IRM 21.7.2.7.3, COBRA Premium Assistance Credit — The American Rescue Plan Act of 2021 ( ARP), for more information about that credit.

The Coronavirus Aid, Relief and Economic Security (CARES) Act deferred the required payment due date for the employer’s share of social security taxes for wages normally due March 27, 2020 through December 31, 2020, as well as deposits and payments due after December 31, 2020 required for wages paid during the quarter which ended on December 31, 2020. See IRM 21.7.2.7.8, Deferred Payment of Social Security Taxes for 2020, for more information.

Notice 2020-22 stated that employers that reduced deposits were not subject to FTD penalties, so long as they paid qualified wages prior to the time such deposits were due, the amount not deposited was less than or equal to the anticipated amount of the associated credits for the applicable calendar quarter, and the employer did not request an advance payment of credits on Form 7200 in addition to reducing deposits.

Notice 2020-23 extended the due date for filing a claim for credit or refund due on or after April 1, 2020 but before July 15, 2020 for eligible persons (including individuals, trusts, estates, corporations, and any type of unincorporated business entities) to July 15, 2020.

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