COVID-19 Update #6 - Individual Economic Impact Payments

To further assist in stabilizing the economy the CARES Act provides for economic impact payments to be automatically distributed to taxpayers.  According to IRS Information Release 2020-61, the payments will begin to be distributed within the next three weeks.  While the provision does not directly affect nonprofit organizations and churches, this information does affect your staff, members and those you serve.   The following information discusses the various aspects of the this new benefit.

Who may receive the payment & how much will it be?

The Act provides for a credit on a taxpayer's 2020 Form 1040 of $1,200 to individuals and $500 for each dependent child.  (The child must be a dependent under the age of 17.  This leaves a large number of young adults who will not be eligible for any payments because they are 17 or older and still dependents of their parents.)  The full credit is provided to tax filers whose adjusted gross income does not exceed $75,000 for single taxpayers and $150,000 for married couples filing a joint return.  For those with adjusted gross income in excess of these amounts, the credit phases out until it is totally unavailable when the taxpayer's adjusted gross income is $99,000 for single taxpayers and $198,000 for married couples filing jointly. 

While the Act provides for a credit (an item that would be applied directly to a person's federal tax liability)  calculated on a person's 2020 Form 1040, the Act also allows for an advance payment of the credit.  This is the payment qualifying taxpayers will soon receive from the IRS.  When a taxpayer files their 2020 Form 1040, the advance credit will be reconciled to the actual amount allowed.  If a greater credit is due, the taxpayer will get the additional amount.  This could occur, if the taxpayers income in 2019 (or 2018, see below) is in the range where the credit was either reduced or disallowed when calculating the amount of the advance payment. 

Obviously, the credit and advance system is confusing to taxpayers, so an example might best clarify the situation.

Example 1:  Sue is a single taxpayer making $65,000 a year as reported on her 2019 Form 1040 (Sue is a very with it taxpayer having already filed her return!)  The IRS sees that Sue's AGI (adjusted gross income) is less than $75,000, so they send her the full $1,200.  Sue enjoys her $1,200 of additional money during our time of economic disruption.  In 2021, Sue files her 2020 Form 1040.  Sue's return shows the following:

Economic Impact Credit Allowed:               $1,200
Economic Impact Advance Received:          $1,200

Credit to claim against 2020 tax liability:        -0-

The credit/advance arrangement has no affect on Sue's 2020 tax liability.  She will have the same tax liability she would have had without the passage of the credit.  Therefore, the $1,200 is additional money to Sue.

Example 2:  Sue is a single taxpayer making $105,000  a year as reported on her 2019 Form 1040.   The IRS sees that Sue's AGI is more than $99,000, so they do not send her any payment.  However, Sue is unable to work all of 2020, so her AGI in 2020 is $50,000.   In 2021, Sue files her 2020 Form 1040.  Sue's return calculates the economic impact credit as follows:

Economic Impact Credit Allowed:               $1,200
Economic Impact Advance Received:          $   -0-

Credit to claim against 2020 tax liability:     $1,200

Because Sue did not qualify for the advance payment but did qualify for the final credit, she may take the credit against her 2020 income tax liability.   The result being that if a taxpayer qualifies for the $1,200 (or any part of it) he/she will get that money either as an advance paid by the IRS in the upcoming weeks or as a credit against income taxes on the 2020 Form 1040. The credit is a gift from Congress that is either received in advance from the IRS or received by reducing the 2020 tax liability.  This is simply a timing issue of when you receive the "free" money.

Initial information indicates that if the reconciliation on the 2020 return determines the advance credit paid was larger than it should have been, the excess received does not have to be paid back. Therefore,  the 2020 federal tax liability will either be exactly the same as it would have been without the credit (Example 1) or it will be a little less, creating a refund, with the credit/advance adjustments (Example 2).

How will the IRS determine the advance credit payment? 

The IRS will use a taxpayer's 2019 Form 1040 to determine qualification for the payment and the amount of the payment.  If the 2019 return has not been filed, then the IRS will base the payment on the 2018 return. If a taxpayer has not filed a Form 1040 for either 2018 or 2019, they should file a return immediately.  

Many older taxpayers do not file returns since their income is below the filing thresholds.  The Act does provide for the IRS to based the payment qualification on the SSA-1099 issued to recipients of Social Security if the tax returns are not available.  Therefore, if older taxpayers have not filed due to the filing thresholds, they may still receive their payment.  The IRS originally advised these taxpayers to file a return for 2019, so their information is in the system and their payment is not delayed.  However, in a recent press release, the IRS has announced they will use the SSA-1099 to determine payment recipients and these taxpayers do not need to file a return to receive a payment. 

How will the payments be delivered?

It is the desire of the IRS to direct deposit the payments into a taxpayer's bank account based on the information provided on the tax return utilized to determine the payment.  However, many taxpayers do not include this information on their tax returns unless they are receiving a refund.  

For taxpayers who have not provided banking information on a prior return, the IRS is establishing a web-based portal for taxpayers to use in providing the information to the IRS.  If the IRS does  not receive any banking information for direct deposit, it will mail checks to the taxpayers.  However, this significantly delays a taxpayer receiving the payment.  

The IRS is required to send a notice, by mail, to the taxpayer within 15 days of issuing the payment.  The notice will provide IRS contact information for a taxpayer to use, if the payment is not received. 

Note:  If a taxpayer's information, either mailing or direct deposit information, on the 2018 Form 1040 has changed and the 2019 Form 1040 has not been filed, then a taxpayer may desire to quickly file the 2019 return with updated information to avoid delays in receiving the advance credit payments. 

With all the isolation orders, how can a tax return be completed? 

This is a great question considering many people are currently under an isolation order and most tax preparers have closed their doors to any outside clientele.  However, CPA firms and tax preparers are resilient people and most have established mechanisms for continuing to serve their clients.  At Sommerville & Associates, P.C. we are utilizing our client portals and electronic communications to continue to prepare returns.  Clients are encouraged to submit tax documents electronically through their client portals and completed returns are electronically submitted to the client alleviating any exchange of physical packages.  While our staff is working remotely, we continue to work on client returns.  Most tax preparers have similar structures in place, so taxpayers should continue to seek a preparer that can move forward in preparing the 2019 Form 1040.  The due date for the 2019 Form 1040 has been extended to July 15, 2020 as well as the payment of related taxes.  If a taxpayer owes with their 2019 Form 1040, they should still proceed with filing the return.  The taxes due with the return would still be due at July 15, 2020.  

As with all of our COVID-19 posts, the information contained in the post is based on guidance issued at the time of the post.  Continual guidance is being issued by the IRS and the DOL, so above information may be updated in the future as guidance is published. This blog was updated on 4/3/2020.