Update: July 15, 2020 is the Last Day for Making IRA and HSA Contributions

On March 23, 2020 we suggested that April 15, 2020 was the safe date for making contributions to traditional and Roth Individual Retirement Accounts (“IRAs”) and Health Savings Accounts (“HSAs") to have them count for 2019.  Notice 2020-23, issued on April 9, 2020 by the Internal Revenue Service (“IRS”) clarifies that these contributions are considered “specified time sensitive activities.” As such, IRA and HSA contributions for the 2019 tax year can be made up until July 15, 2020, the extended date for filing and paying 2019 individual income taxes.

Contributions to traditional and Roth IRAs and HSAs must be made no later than “the time prescribed by law for filing the return for such taxable year (not including extensions thereof)”. See Code Section 219(f)(3).  For most taxpayers eligible to make these contributions, this usually means April 15th whether or not an extension to file the Federal income tax return has been requested.

Notice 2020-18, issued on March 20, 2020, suggested that in 2020 July 15th would be the last day for making IRA and HSA contributions but the guidance did not specifically grant an extended period to make the contributions.  Fortunately, we now have clarity on this issue.

This blog/web site presents general information only. The information you obtain at this site is not, nor is it intended to be, legal advice, and you should not consider or rely on it as such. You should consult an attorney for individual advice regarding your own situation. This website is not an offer to represent you. You should not act, or refrain from acting, based upon any information at this website. Neither our presentation of such information nor your receipt of it creates nor will create an attorney-client relationship with any reader of this blog. Any links from another site to the blog are beyond the control of Pullman & Comley, LLC and do not convey their approval, support or any relationship to any site or organization. Any description of a result obtained for a client in the past is not intended to be, and is not, a guarantee or promise the firm can or will achieve a similar outcome.

Subscribe to Updates

About Our Labor, Employment and Employee Benefits Law Blog

Alerts, commentary, and insights from the attorneys of Pullman & Comley’s Labor, Employment Law and Employee Benefits practice on such workplace topics as labor and employment law, counseling and training, litigation, union issues, as well as employee benefits and ERISA matters.

Other Blogs by Pullman & Comley

Connecticut Health Law Blog

Education Law Notes

For What It May Be Worth

Recent Posts


Jump to Page