IRS Extends Filing Deadline for All Forms 990

by: Smith and Howard

April 13, 2020

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As a result of the economic impact derived from the COVID-19 pandemic, the IRS announced in Notice 2020-23, published on Friday, April 10, 2020, an extension of the filing deadlines for nonprofit organizations and foundations. The original filing deadline of May 15 has been extended to July 15. Here is what you need to know.

Tax Relief

Previously, the IRS had stated that individuals or businesses with a federal tax payment obligation or federal tax return obligation due on or after April 1, 2020 and before July 15, 2020 would receive an automatic extension to file and/or pay to July 15, 2020.

With the April 10, 2020 notice, nonprofits required to file Forms 990 during the above time period now have until July 15, 2020, an extension of the prior filing deadline of May 15. This affects the entire Form 990 series – Form 990, 990T and 990PF (either originally due or extended).

Tax Exempt Time-Sensitive Actions

Additionally, the IRS provides extension relief to tax-exempt businesses that are considered an affected taxpayer. An affected taxpayer is any person performing a time-sensitive action which is due to be performed on or after April 1, 2020, and before July 15, 2020 (Specified Time-Sensitive Action). Time-sensitive actions specific to nonprofits and foundations include:

  • The filing of Form 990 series annual returns.
  • The filing of Form 1023, Application for Recognition of Exemption under 501(c)(3).
  • Tax-exempt hospital organizations conducting a community health needs assessment.
  • Extension Details for Forms 990, 990-T, 990-PF

Organizations with Forms 990 that have a filing date of May 15, 2020 can file an extension of time on or before July 15, 2020, extending the final due date to November 15, 2020. Forms 990 with a previous 6-month extension must file on or before July 15, 2020.

Additional returns that qualify for the July 15, 2020 extended filing deadline include:

  • Form 990
  • Form 990-T
  • Form 990-PF
  • Form 4720

It is important to note that this relief is automatic and organizations do not need to contact the IRS to receive the relief mentioned above. Affected taxpayers who need additional time to file beyond July 15, 2020 must file their extension form by July 15, 2020.

If you have questions on any of the information above, please contact your Smith and Howard advisor. Even though an extension of the filing deadline has been issued, we encourage you to get your information to us as soon as possible, so that there is ample time to prepare and meet the July 15, 2020 deadline.

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