This notice amplifies Notice 2020-18, and provides additional tax relief under section 7508A of the Code for taxpayers affected by the Coronavirus Disease (COVID-19) emergency. The due date for filing Federal gift and generation-skipping transfer tax returns and making Federal gift and generation-skipping transfer tax payments due April 15, 2020, is postponed to July 15, 2020. Associated interest, additions to tax, and penalties for late payment will also be suspended until July 15, 2020.

Notice 2020-21 provides that employment tax credits for paid qualified sick leave wages and paid qualified family leave wages required by the Families First Coronavirus Response Act (“the Act”) will apply to such wages and compensation paid for periods beginning on April 1, 2020 and ending on December 31, 2020, and that days beginning on April 1, 2020 and ending on December 31, 2020 will be taken into account for credits for paid qualified sick leave equivalents and paid qualified family leave equivalents for certain self-employed individuals provided by the Act.

Generally, U.S. citizens or resident aliens living and working abroad are taxed on their worldwide income. However, if their tax home is in a foreign country and they meet either the bona fide residence test or the physical presence test, they can choose to exclude from their income a limited amount of their foreign earned income ($105,900 for 2019). Both the bona fide residence test and the physical presence test contain minimum time requirements. Revenue Procedure 2020-14 provides a waiver under section 911(d)(4) for the time requirements for individuals electing to exclude their foreign earned income who must leave a foreign country because of war, civil unrest, or similar adverse conditions in that country. Rev. Proc. 2020-14 adds the Democratic Republic of the Congo, Haiti, Sudan, and Venezuela to the list of waiver countries for tax year 2019 for which the minimum time requirements are waived.

26 CFR 1.911-2: Qualified Individuals

(Also: Part I, §§911; 1.911-2.)