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HARMON CURRAN NONPROFIT LAW BLOG

990 and Other Filing Deadlines Extended to July 15

Ordinarily, organizations are required to file the Form 990 on the 15th day of the 5th month following the end of their fiscal year. For tax-exempt organizations that operate on a fiscal year ending December 31, that would mean filing their Form 990 by May 15. The IRS announced last month that tax-exempt organizations will have until July 15, 2020 to file their federal Form 990-series returns and pay any tax due.

This extension applies to Forms 990, 990-EZ, 990-PF, 990-BL, 990-N (e-postcard), and 990-T, among other tax filings that may be due between April 1, 2020 and July 15, 2020. This relief is automatic; organizations do not need to take any action to receive this relief.  See Notice 2020-23 and Rev. Proc. 2018-58 for more information, including a complete list of affected forms and tax payments.

What if you need more time?

Organizations that need additional time to file Form 990, 990-PF, 990-T, 990-EZ, or 990-BL may use Form 8868 to request an extension past the new July 15 deadline. However, the extension date may not go beyond the original statutory or regulatory extension date. For example, to request a 6-month extension for a Form 990 filing originally due May 15, a Form 8868 may be filed by July 15, but the 6-month extension will only be until November 15, 2020.

Exemption Applications

Organizations seeking recognition of exemption under section 501(c)(3) must file the Form 1023 to apply for that recognition no later than the end of the 27th month after the month in which they were created in order for the status to be retroactive to the date of incorporation. Organizations operating under section 501(c)(4) must file Form 8976 within 60 days of creation, and organizations seeking recognition of exemption under any subsection of section 501(c) (other than 501(c)(3), (9), (17), or (29)) must file Form 1024 or 10124-A within a similar 27-month period in order for the ruling to be retroactive. All of these filing deadlines that fall within the period of April 1 – July 15, 2020 will automatically be extended until July 15.

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