In response to COVID-19, the IRS released Notice 2020-23 (the Notice) to extend tax deadline relief for additional returns that were not included in Notice 2020-18. This extended relief postpones the due date for all returns in the Form 990 series to July 15, 2020. Nonprofit organizations with a filing or tax payment obligation between April 1, 2020 and July 15, 2020 automatically qualify for the postponed due date.
Private Foundations
The Notice impacts excise tax payments on investment income and return filings on Form 990-PF, Return of Private Foundation and excise tax payments and return filings on Form 4720, Return of Certain Excise Taxes under Chapters 41 and 42 of the Internal Revenue Code.
Nonprofits with Unrelated Business Income
The Notice extends 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).
Public Charities and Other Tax-Exempt Organizations
The Notice postpones the filing due date for all other returns in the Form 990 series. A cross-reference to Revenue Procedure 2018-58 confirms that annual returns of organizations exempt from tax under Section 501(a) qualify for the postponed due date as “Specified Time-Sensitive Actions.”
California Returns
The Franchise Tax Board has extended the due date for all state return filings and tax payment obligations to July 15, 2020.
Nonprofits that need additional time to file may choose to file the appropriate extension form by July 15, 2020.
For questions or more information, please contact Chérie Williams at cwilliams@windes.com or at 844.4WINDES (844.494.6337).