On Friday, April 10, 2020, the Internal Revenue Service issued Notice 2020-23 that provides further clarification and relief to affected taxpayers, including tax exempt organizations. This notice expands upon earlier announced modifications of certain federal tax return due dates as provided by Notice 2020-18 and Notice 2020-20. As a result, the tax filing deadlines for federal returns and related federal tax payment obligations previously due between April 1, 2020 and July 15, 2020 have been postponed until July 15th, 2020 for the following forms filed by tax exempt organizations:
Form 990, 990EZ and Form 990N Return of Organization Exempt from Income Tax
Form 990-T Exempt Organization Business Income Tax Return (including 6033(e) proxy tax)
Form 990-PF Return of Private Foundation or Section 4947(a)(1) Trust treated as a Private Foundation
Form 4720 Return of Certain Excise Taxes
Form 990-W Quarterly Estimated Tax on Unrelated Business Taxable Income for Tax-Exempt Organizations
Prior to this relief – Form 990 series returns were due on the 15th day of the 5th month after the entity’s tax year end [Example: A calendar year end entity’s filings would have been due on May 15, 2020].
The revised original due date for calendar year entities will be July 15, 2020, with an opportunity to request an extension until November 15, 2020.
The revised extended due date for fiscal year entities whose extended filing due date falls within the period April 1, 2020 through July 15, 2020 are now due July 15, 2020 [ Example: the filings for tax year ended June 30, 2019 which was originally on extension until May 15, 2020, are now due July 15, 2020.]
For any tax-related questions about this Tax Alert, please contact any of the following individuals: