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IRS Extends Filing Deadlines For Tax Exempt Organizations

April 16, 2020

On April 14, 2020, the IRS confirmed that, in response to the coronavirus (COVID-19) pandemic, the deadline imposed on tax exempt organizations for filing Form 990-series annual information returns (Forms 990, 990-EZ, 990-PF, 990-BL, 990-T, and 990-N e-postcard) that are due between April 1 and July 15 has been extended to July 15. This clarifies information contained in IRS Notice 2020-23.

A Form 990 series annual information return is normally due on or before the 15th day of the fifth month following the fiscal year end for a tax exempt organization. For those organizations that have December 31 year ends, this would mean that the 990 is normally due on or before May 15. For those with January 31 year ends, the filing would normally be due by June 15. The extension now extends these filing deadlines to July 15 without the need to request an extension to file later.

In addition to the 990 Series, the IRS Notice applies to many other forms and payments by a tax exempt organization that are due between April 1 and July 15, including: Forms 8871 and 8872; Form 5227; Form 1120-POL; Form 4720 and Form 8976.

The extension of the deadlines will give tax exempt organizations more time to focus on their missions during this time of crisis. The IRS’ action will also give tax exempt organizations more time to collect needed information and work with accountants (if necessary) to prepare and file these forms. This is important as many organizations are operating with reduced staff, who may also be working from home, and they may not have access to the needed information or the ability to meet with professionals to prepare and file forms.

This is part of our series of COVID-19 alerts providing clients with practical advice on measures they can take to navigate through these challenging times. Please contact the authors or your Miller Canfield attorney with further questions.

This information is based on the facts and guidance available at the time of publication, and may be subject to change.