On April 9, 2020, the IRS issued Notice 2020-23, which amplifies Notice 2020-18, 2020-15 IRB 590 (April 6, 2020) and Notice 2020-20, 2020-16 IRB 660 (April 13, 2020). This new notice provides additional relief to affected taxpayers with a federal tax payment obligation or federal tax return or other form filing obligation, which is due to be performed (originally or pursuant to a valid extension that ends) on or after April 1, 2020, and before July 15, 2020, an automatic postponement to file and/or pay to July 15, 2020.
The Notice also granted relief to a variety of time-sensitive actions, including those listed in Rev. Proc. 2018-58. Section 10 of Rev. Proc. 2018-58 covers certain tax-exempt entities assuming they qualify as an affected taxpayer. Affected taxpayers are defined in the Notice as any person or organization performing a “time-sensitive action” between April 1, 2020, and before July 15, 2020. Time-sensitive actions relevant to nonprofits and foundations include:
Form 990s with a previous six-month extension to file must file on or before July 15, 2020. If the original due date of Form 990 is May 15, 2020, the organization may either:
This relief is automatic; affected taxpayers do not have to call the IRS, file any extension forms or send letters or other documents to receive this relief. However, affected taxpayers who need additional time to file may choose to file the appropriate extension form by July 15, 2020, to obtain the extension. All filings may not go beyond the original statutory or regulatory extension date.
Forms 5500 with June 30, 2019 – August 31, 2019 year ends receive additional time to file under Notice 2020-23 to July 15, 2020.
Under the Notice, calendar year Forms 990, 990-PF and Form 990-T returns due May 15, 2020, are now due on or before July 15, 2020. Form 8868, Application for Automatic Extension of Time to File an Exempt Organization Return, may be filed to request an additional extension of time to file to November 15, 2020. Note that taxes owed with Form 990-PF and Form 990-T are due at the time of the filing of the extension, July 15. An organization, with a fiscal year ended June 30, 2019, which has previously extended the filing of its 2018 Form 990, Form 990-PF and or Form 990-T must file its 2018 return on or before July 15, 2020.
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