You are now cleared to start filing revisions to the second quarter Form 941 if you have some to fix. The IRS has released the revised Form 941-X[1] that will allow revising Forms 941 that are impacted by provisions found in the Families First Coronavirus Relief Act and/or the CARES Act that impacted second quarter payroll. The related revised instructions to the form were also issued at the same time.[2]

On August 17 the IRS had asked employers not to use the prior version of Form 941-X to attempt to amend a second quarter 2020 Form 941 and to wait for this form, which existed in draft form on that date, to be finalized sometime in “late September.”[3]

Congress had enacted various payroll tax credits as part of the Families First Coronavirus Relief Act and CARES Act, as well as providing for the deferral of the employer portion of the old age, survivors and disability insurance (OADSI) portion of the employer FICA tax.

Employers who had been delaying filing revised Forms 941 for the second quarter awaiting the finalization of this form should now file those revisions.

[1] Form 941-X, Adjusted Employer’s QUARTERLY Federal Tax Return or Claim for Refund, (Rev. July 2020), September 11, 2020 https://www.irs.gov/pub/irs-pdf/f941x.pdf (retrieved September 14, 2020)

[2] Instructions for Form 941-X, (Rev. July 2020), September 11, 2020 https://www.irs.gov/pub/irs-pdf/i941x.pdf (retrieved September 14, 2020)

[3] Ed Zollars, CPA, “IRS Warns Employers Not to File Form 941-X to Change Second Quarter Forms 941 Until Revised Version Issued in Late September,” Current Federal Tax Developments website, August 21, 2020