IRS Extends Tax Deadlines for Nonprofits

April 13, 2020

On April 9, the IRS issued Notice 2020-23 providing an automatic extension to organizations affected by the COVID-19 pandemic. The automatic extension applies to various tax filings due between April 1 and before July 15, 2020. This Notice also extended Forms 990, 990-PF and 990-T that are generally due on May 15 through July 15. Form 990, “Return of Organization Exempt From Income Tax,” is filed by public charities; Form 990-PF, “Return of Private Foundation,” is filed by various private foundations; and Form 990-T, “Exempt Organization Business Income Tax Return,” is filed by both public charities and private foundations to report taxable income. All of these forms are extended through July 15, even though there is no direct reference to some of these forms in the Notice. However, Rev. Proc. 2018-58 lists the forms and provides the much-needed extension.

The relief is automatic, and affected taxpayers do not have to call the IRS or file any extension forms or send any 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. The additional extension is to the original extended due date and only postpones the filing of the return and the payment of any tax that may be due. For calendar-year filers, the tax and extension, if needed, will have to be filed by July 15, 2020 to extend the deadline until November 15, 2020. Nonprofits that operate on a fiscal year ending June 30, 2019 now have until July 15 to file their Form 990. There is no extension beyond July 15 for them.

In addition, the New York Attorney General’s Charities Bureau currently grants an automatic six-month extension to charities required to file an annual financial report with the Charities Bureau. For example, the annual financial report of organizations whose year-end is December 31, 2019 is due to be filed by May 15, 2020, but with the automatic extension, the report is not due until November 15, 2020. However, due to the COVID-19 pandemic, any organization whose filing deadline, including the automatic six-month extension, was originally after February 15, 2020 will be given an additional six-month extension to file its annual financial report.

For further information concerning this new development, please contact your Marks Paneth nonprofit advisor. You may also reach out to our Response Team or visit our Pandemic Resource Center for additional updates and guidance on the coronavirus (COVID-19).