When is My 990 Form Due?

April 3, 2020

On March 13, 2020, the President of the United States declared a national emergency due to the coronavirus outbreak.  The declaration instructed the Secretary of the Treasury “to provide relief from tax deadlines to Americans.”  In response to the mandate, the Internal Revenue Service (IRS) issued Notice 2020-17 and Notice 2020-18, the latter of which expanded the initial Notice 2020-17.  Both of these notices extended the income tax return deadlines and related payments until July 15, 2020.  Does this apply to nonprofit tax filings?  The short answer is no, without further action.

The related notices extended the April 15, 2020 due dates for income tax returns.  However, since 990 returns, both 990s and 990-PFs, are not considered income tax returns, they are not extended.  However, Form 990-T, which is considered an income tax return, has been extended until July 15, 2020 for returns originally due on April 15, 2020 with November 30, 2019 year ends.

As of this date, the series of 990 returns due by May 15, 2020 has not changed.  In addition, the 990-PF and 990-T forms are also due by that day.

Various groups have reached out to the IRS to extend the May 15th deadline, but that has not yet happened.  For calendar-year filers, the May 15, 2020 deadline can be extended until November 15, 2020. However, for fiscal year filers with a year end of  June 30, 2019, the final due date is May 15, 2020 and no extension can be filed.

It is important to note that for most large nonprofits with revenues over $1 million, the failure to file on time results in a penalty of $100 per day.  The IRS penalty notice is automatically generated and even though most likely the penalties would be waived, this creates an additional administrative burden on nonprofits, which serve such a vital role in our communities already strained for resources.

We will continue to monitor the situation and provide you with the most current information as it becomes available. If you have any questions, please contact Magdalena Czerniawski or Robert Lyons. You may also visit our Pandemic Resource Center for additional updates and guidance on the coronavirus (COVID-19).

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