Deadline Extension for Form 990 Filers in Response to COVID-19

Notice 2020-23 from the Department of Treasury extends the timeline for Form 990 filers

Since President Trump’s declaration of emergency under the Robert T. Stafford Disaster Relief and Emergency Assistance Act in response to the COVID-19 global pandemic, the Department of Treasury (the “Treasury Department”) has taken multiple steps to provide affected taxpayers with relief from established filing deadlines and payments due. Until now, those steps were focused on taxpayers filing income tax, excise tax and other assessment-type returns, including individuals, corporations, and partnerships. Excluded from that relief were filers obligated to report activity on informational returns, such as Form 990, Return of Organization Exempt from Income Tax.

On April 9, 2020, the Treasury Department issued Notice 2020-23 clarifying that “any person…with a Federal tax payment obligation… or [emphasis added] a Federal tax return or other form filing obligation… which is due to be performed (originally or pursuant to a valid extension) on or after April 15, 2020, and before July 15, 2020 is affected by the COVID-19 emergency for purposes of the relief described [herein]….” Further, the Treasury Department affirmed that “any person” required to perform a “time-sensitive action” (such as filing an information return) during the period beginning April 15, 2020 through July 15, 2020 is an “Affected Taxpayer” and therefore shall benefit from the same relief previously provided. As a result, all filing obligations, regardless of their nature, are due no later than July 15, 2020.

In short, Federal Forms 990, 990-T and 990-PF with original filing due dates of May 15, 2020, are now due July 15, 2020. If you have questions about this development or other not-for-profit matters related to COVID-19, please reach out to your Keiter service team or review Keiter’s COVID-19 knowledge library at the link below.