Nonprofit Tax News: IRS Offers Additional Extensions Due to Coronavirus, Including Form 990

Published on April 14, 2020

The Treasury Department issued Notice 2020-23, which grants additional relief from tax return and payment obligations, on April 9, 2020. This additional relief augments the earlier extension of most filing and payment obligations due by April 15, and extends until July 15 the time to both file returns and pay taxes due for most returns and payments due between April 1 and July 15. The types of returns specifically listed in the Notice include virtually all flavors of Form 1040 for individual taxpayers, all varieties of Form 1120 for corporate taxpayers, Form 1065 for partnerships, and several other return and payment types, including gift tax, estate tax, trusts, certain excise taxes, and quarterly estimated tax payments.

The Notice also grants relief for Form 990-T, used by exempt organizations to calculate and pay tax on unrelated business income, and Form 990-PF, used by private foundations to calculate and pay excise tax on investment income. Although Form 990 itself is not specifically listed in the Notice, filing relief is granted for “time-sensitive acts” described in an earlier piece of guidance, Revenue Procedure 2018-58, which includes all Form 990-series forms.

Organizations needing additional time to file beyond July 15 may request an extension by filing Form 8868, but may only request an extension of six months from the original due date. For calendar-year Form 990 filers, fully extended returns will still be due on November 16, 2020.

If you have any questions about this, contact the Johnson Lambert team.

This communication is intended to provide general information on legislative COVID-19 relief measures as of the date of this communication and may reference information from reputable sources. Although our firm has made every reasonable effort to ensure that the information provided is accurate, we make no warranties, expressed or implied, on the information provided. As legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that may modify some of the provisions in this communication. Some of those modifications may be significant. As such, be aware that this is not a comprehensive analysis of the subject matter covered and is not intended to provide specific recommendations to you or your business with respect to the matters addressed.