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3520 AND 3520A TAX PENALTIES

IRS Relief for Taxpayers in Israel: Deadlines Now Postponed to Sept. 30, 2027

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IRS Relief for Taxpayers in Israel: Deadlines Now Postponed to Sept. 30, 2027

Form 3520 and Form 3520-A are forms that a person or entity may be required to submit under IRS requirements. If a required form is not submitted on time and there is no extension, a CP15 notice will be issued if the IRS catches the problem. The CP15 notice is what triggers the penalty assessment. Not every late filing results in a CP15 notice or a penalty.

If you are a U.S. taxpayer affected by events in Israel, Notice 2026-63 postpones certain filing, payment, and other tax-related deadlines to September 30, 2027.

What did the IRS announce, and what is the new deadline?

Under section 7508A, the Secretary of the Treasury determined on September 30, 2026, following the procedures in Rev. Proc. 2004-26, that terrorist activity throughout 2025 and 2026 against the State of Israel constitutes terroristic action under section 692(c)(2).

As explained in the IRS IR-2026-116 newsroom release, Notice 2026-63 postpones covered acts due on or after September 30, 2026, and before September 30, 2027, until September 30, 2027. The covered area is Israel, the West Bank, and Gaza.

Who qualifies as an “affected taxpayer” under Notice 2026-63?

The five categories are:

  1. An individual whose principal residence, or a business entity’s or sole proprietor’s principal place of business, is in the covered area.
  2. An individual affiliated with a recognized government or philanthropic organization and assisting in the covered area, such as a relief worker.
  3. An individual, business, sole proprietor, estate, or trust whose tax return preparer or necessary records are located in the covered area.
  4. A spouse of an affected taxpayer, solely regarding a joint return of two married individuals.
  5. An individual visiting the covered area who was killed, injured, or taken hostage as a result of the terroristic action.

Which filings and payments are postponed?

Affected taxpayers have extra time to file income, estate, gift, generation-skipping transfer, excise (other than firearms), harbor maintenance, and employment tax returns. Payments and installments are also covered.

Other covered acts include qualified retirement plan contributions, Tax Court petitions, refund claims, and suits on refund claims. This list is not exhaustive; Notice 2026-63 refers to Treasury Regulation section 301.7508A-1(c)(1) and Rev. Proc. 2018-58.

Rev. Proc. 2018-58, section 12, item 49, identifies Form 3520 as a time-sensitive act. Therefore, affected taxpayers in Israel, the West Bank, and Gaza have their Form 3520 deadline postponed to September 30, 2027, if that due date falls within the postponement window. Form 3520 is generally due with the U.S. person’s income tax return, including extensions.

Form 3520-A remains the foreign trustee’s return and is not expressly listed in item 49 of Rev. Proc. 2018-58. Our Form 3520-A compliance guide provides additional background.

Is postponement the same as an extension to file?

No. A postponement moves a covered deadline. It is not the same as an extension of time to file. Different extension rules apply depending on the return and your circumstances.

Also, an extension of time to file is not an extension of time to pay. Interest or penalties may still apply to late payments. Review the full Notice 2026-63 PDF before relying on the relief.

Friendly flat illustration of a relaxed character with coffee beside an oversized abstract calendar
Friendly flat illustration of a relaxed character with coffee beside an oversized abstract calendar

Is the relief automatic, or must you request it?

The IRS automatically identifies taxpayers whose principal residence or principal place of business is in the covered area, based on previously filed returns.

Other eligible taxpayers, or their representatives, whose filing address is outside the covered area must call the IRS disaster hotline and identify the date they qualified:

  • United States: 866-562-5227
  • International callers: 267-941-1000

How does Notice 2026-63 interact with earlier IRS notices?

Notice 2025-53 generally gave affected taxpayers until September 30, 2026. Notices 2024-72 and 2023-71 provided earlier layers of relief.

Because September 30, 2026, is the first day of the new postponement period, acts previously postponed by Notice 2025-53 — and, where applicable, Notices 2024-72 and 2023-71 — are further postponed to September 30, 2027 for taxpayers eligible under Notice 2026-63. Taxpayers eligible under Notice 2025-53 but not under Notice 2026-63 generally still have until September 30, 2026. See the prior Notice 2025-53 PDF.

What if your Form 3520 is already late or you have a CP15 notice?

Notice 2026-63 applies to acts due within the postponement window. It does not retroactively cure an already-late Form 3520 filed before that period. A CP15 notice triggers a penalty assessment, and a separate reasonable-cause abatement request or appeal may be available.

The notice also postpones certain government acts, including assessing tax, issuing notices or demands, collecting by levy or otherwise, and bringing suit. This may provide additional time while a CP15 notice and the penalty assessment it triggers are pending, but it does not guarantee cancellation.

If you have an overdue Form 3520 or a CP15 notice, check the dates carefully. See our guidance on Form 3520 and 3520-A penalty appeals.

At Law Offices of Jason R. Kovan, we focus exclusively on Form 3520 and Form 3520-A penalty defense, including CP15 responses. Your consultation is private, and protected by attorney-client privilege once an engagement letter is signed.

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