On April 9, the IRS issued Notice 2020-23 giving not-for-profit organizations relief on tax returns and tax payments originally due between April 1, 2020 and July 15, 2020.
Notice 2020-23 provides relief for filers of Form 990, Form 990-EZ, Form 990-N, Form 990-PF, and Form 990-T. These returns, along with any tax payments, are now automatically due July 15, 2020. While Notice 2020-23 does not explicitly state Form 990 as a form with relief, it is addressed indirectly. The notice refers to “time-sensitive actions” which, according to Revenue Procedure 2018-58, include acts that are to be performed within the April 1 to July 15 time frame.
This change in due date applies both to organizations whose initial or final due date falls within the time frame. Therefore, fiscal year organizations on their final, extended due date now have additional time to file and pay any tax due.
For organizations whose initial due date falls within the time frame, they are eligible to file for an additional extension by July 15. However, the extension only extends the return to its normal extension deadline. For example, a calendar year organization whose initial tax deadline is May 15 now has their due date automatically extended to July 15. If additional time is needed, the organization may request an extension to November 15.
Tax payments relating to Form 990-PF and Form 990-T due between April 1 and July 15 are also extended to July 15, 2020. There is no limitation on the amount that may be postponed. The IRS will also waive any interest, penalties, or additional tax for failure to file on these returns and payments during this automatic extension period.
Notice 2020-23 also clarifies that any forms attached to the federal return, such as foreign filings (Form 926, Form 5471, etc.), are also automatically extended. This was an area of confusion previously with Notice 2020-18.
If you have any questions regarding how this may impact your not-for-profit organization, please contact a Clark Nuber professional.
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