The Internal Revenue Service released Notice 2020-23
in which it expands the tax filing relief to tax exempt organizations. An automatic extension has been provided until July 15, 2020. In the body of the notice there are specific forms and payments that are listed out such as:
- Form 990-T: Exempt Organization Business Income Tax Return and payments
- Form 990-PF: Private Foundation Filings
- Excise Tax Payments on Investment Income
- Form 4720: Return of Certain Excise Taxes Filings and Excise Tax Payments
- Quarterly estimated income tax payments related to unrelated business income for tax-exempt organizations
Although the Form 990 is not specifically mentioned in the notice, there is a reference to stating that any filing referenced in Revenue Procedure 2018-58, which is due on or after April 1, 2020 and before July 15, 2020, will also receive an automatic extension. Revenue Procedure 2018-58 references the following forms:
- Form 990: Return of Organization Exempt From Income Tax
- Form 990-EZ: Short Form Return of Organization Exempt From Income Tax
- Form 1023: Application for Recognition of Exemption Under Section 501(c)(3)
The extension applies to all tax-exempt organizations, including fiscal-year files with a final due date of April 15, 2020, May 15, 2020 and June 15, 2020.
California had already granted tax-exempt organizations an extension on tax payments and filings of the Form 199 and Form 109 until July 15, 2020.
This much needed extension comes at a crucial time for nonprofits who are currently struggling with their own COVID-19 impact. The additional time will allow nonprofits to continue to focus on operations, cash flow, employees’ safety, etc.
If you have any questions or concerns about this extension, please contact our Nonprofit Tax Practice Leader Lizbeth Nevarez.