Extension of Tax Filing Deadlines for Tax-Exempt Organizations in 2020

IRS Notice 2020-23, issued on April 9, 2020, clarifies that tax-exempt organizations are fully included in COVID-19 relief. Specifically, the filing and tax payment deadlines for IRS Form 990 series (990, 990-EZ, 990-PF and 990-T) normally due between April 1, 2020 and July 15, 2020 are automatically extended to July 15, 2020. The deadline for IRS form 4720 (commonly used by private foundations to report certain excise taxes due) is similarly extended. Form 990-T is specifically mentioned in Notice 2020-23 and this new guidance differs from the original interpretation that 990-T filing (and tax payments) were still due according to the original deadlines. The extension to July 15, 2020 is automatic and exempt organizations do not need to file any request for extension. If an organization needs even more time, it can file Form 8868 before July 15, 2020, however any additional extension cannot exceed the original statutory or regulatory extension date (i.e., generally six months from the original due date).