Nonprofit Tax Filing Due Dates Extended to July 15, 2020

In a seemingly never-ending changing landscape, IRS Notice 2020-23 was issued on April 9, 2020, and once again extended the filing and payment deadlines for a number of returns required to be filed by nonprofit entities, including Form 990s.

The notice relates to any returns and payments that normally would have been due on or after April 1, 2020, but before July 15, 2020, and extends the filing and payment dates until July 15, 2020.

In addition to the regular individual, corporate, partnership, and estate and gift filings, the following exempt organization filings were explicitly included in the notice:

• Exempt organization business income tax and other payments and return filings on Form 990-T, Exempt Organization Business Income Tax Return (and proxy tax under section 6033(e) of the Code);
• Excise tax payments on investment income and return filings on Form 990-PF, Return of Private Foundation or Section 4947(a)(1) Trust Treated as Private Foundation;
• Excise tax payments and return filings on Form 4720, Return of Certain Excise Taxes under Chapters 41 and 42 of the Internal Revenue Code; and
• Quarterly estimated income tax payments calculated on or submitted with Form 990-W, Estimated Tax on Unrelated Business Taxable Income for Tax-Exempt Organizations, and 1120-W, Estimated Tax for Corporations.

While at first glance it appears that federal Form 990 is strangely absent, the notice does state that all specified forms covered by Rev. Proc. 2018-58 related to federally-declared disasters, which specifically includes Form 990, are also extended through July 15, 2020. This extension covers all schedules and attachments that are normally filed with the Form 990.

In addition, the State of New York issued a notice that provides an automatic six-month extension for the filing of state Form NY CHAR-500, which is required to be filed by many nonprofit organizations. Other states are sure to revise filing due dates as we approach other filing deadlines.

While the deadlines have been extended, Marcum is still up and running and dedicated to help all of our nonprofit clients file their returns without delay.

If you have any questions, do not hesitate to contact your Marcum tax professional or contact Frank Smith, Nonprofit Tax Leader, at 202.227.4120 or email Frank.

Coronavirus Resource Center

Have more questions about the impact of the coronavirus on your business? Visit Marcum’s Coronavirus Resource Center for up-to-date information.