Is there an extension for 990 Forms?
The IRS and the Department of Treasury released Notice 2020-18 on March 20th in response to the Coronavirus pandemic. At first glance, this notice had little impact on tax-exempt organizations and not-for-profits. The Notice 2020-18 applied exclusively to income tax returns and payments due on April 15, 2020, postponing the due dates for those to July 15, 2020. Forms 990, 990-EZ, and 990-PF are information returns (not income tax returns), which has an original due date for calendar year taxpayers of May 15, 2020.
However, additional clarification has been released via Notice 2020-23 to include Form 990s.
The IRS extended the relief granted in Notice 2020-18 to additional returns, tax payments, and other actions, including Forms 990, 990-EZ, and 990-PF. As a result, the extensions generally now apply to all taxpayers that have a filing or payment deadline falling on or after April 1, 2020, and before July 15, 2020. The extensions apply to many forms and tax payments made by tax-exempt organizations, including:
- Form 990-series annual information returns or notices (Forms 990, 990-EZ, 990-PF, 990-BL, 990-N (e-postcard))
- Forms 8871 and 8872
- Form 5227
- Form 990-T
- Form 1120-POL
- Form 4720
- Form 8976
Certain Estimated Tax Payments of UBIT Extended
Notice 2020-18 postpones the due date for making estimated income tax payments, originally due April 15, 2020, to July 15, 2020. This extension affects most calendar year Form 990-T filers and some fiscal year Form 990-T taxpayers that have quarterly estimated tax payments due April 15, 2020.
Notices 2020-18 and 2020-23 Impacts on Tax-Exempt Organization Returns
See the following chart which summarizes Notice 2020-18 and 2020-23 impacts for tax-exempt organization returns.
| Tax Return | Tax Year End | Due Date |
| 2019 fiscal year Forms 990-T and 1120-POL with an original or extended due date of 4/15/20 to 7/15/20 | Tax years ending 2019 | July 15, 2020 |
| Forms 990, 990-N, 990-EZ and 990-PF | Dec. 31, 2019 | July 15, 2020 |
| Form 1120-POL | Dec. 31, 2019 | July 15, 2020 |
| Estimated income tax payments due 4/15/2020 | Tax years ending 2020 | July 15, 2020 |
| Form 990-T – 401(a) trusts, IRAs (including SEPs and SIMPLEs), Roth IRAs, Coverdell ESAs, or Archer MSAs | Dec. 31, 2019 | July 15, 2020 |
