close
Share with your friends

Form 990, Form 990-PF appear not to be included in Treasury’s filing, payment relief (COVID-19)

Tax-exempt organizations forms, extensions

The IRS on March 20, 2020, released an advance copy of Notice 2020-18 that provides relief for certain taxpayers to file federal income tax returns and make payments of federal income tax.

1000

Related content

Notably absent is relief for charities and other tax-exempt organizations.

Although Notice 2020-18 provides individuals and businesses with April 15, 2020 filing due dates with an extension of time to file income tax returns (and to make income tax payments), hospitals, universities, and other tax-exempt organizations that have Form 990 and Form 990-PF return filing due dates on April 15 and May 15 do not appear to have been given any similar relief.  


Notice 2020-18

Notice 2020-18 [PDF 67 KB] provides that under the president’s March 13, 2020 “Emergency Declaration” relating to the coronavirus (COVID-19) pandemic, relief from federal income tax filing and payment deadlines is being provided to certain U.S. taxpayers who have been adversely affected by the COVID-19 emergency under the authority of section 7508A(a). Notice 2020-18 restates, expands upon the relief provided, and supersedes Notice 2020-17—read TaxNewsFlash.  

Under Notice 2020-18, a person with a federal income tax payment or a federal income tax return due on April 15, 2020, is considered affected by the COVID-19 emergency (“Affected Taxpayer”). The due dates of federal income tax returns and payments (including estimated payments) that are due April 15, 2020, are automatically postponed to July 15, 2020.

Notice 2020-18 further provides that there is no extension provided by the notice for the payment or deposit of any other type of federal tax, or for the filing of any federal information return. 


Form 990

Form 990, Return of Organization Exempt From Income Tax, filed by tax-exempt organizations is generally regarded as an information return, not an income tax return, and thus does not appear covered by the relief granted in Notice 2020-18.  Other information and excise tax returns of tax-exempt organizations would also appear not to be covered, such as the Form 990-EZ, Form 990-PF, and Form 4720.

Form 990-T Exempt Organization Business Income Tax Return, is an income tax return, and in subsequently released "frequently asked questions" (FAQs), the IRS made clear that a Form 990-T due April 15, 2020, is eligible for the relief. Read TaxNewsFlash


Guidance related to interest and penalties

For individuals and businesses, as a result of the postponement of the due date for filing federal income tax returns and making federal income tax payments from April 15, 2020, to July 15, 2020, the period beginning on April 15, 2020 and ending on July 15, 2020, will be disregarded in the calculation of any interest, penalty, or addition to tax for failure to file the income tax returns or pay the federal income taxes postponed by the notice. 

As noted above, this relief from interest, penalties or additions to tax applies only to Form 990-T due on April 15, 2020. Tax-exempt organizations appear to have been granted no relief from interest, penalties or additions to tax for failure to file information or excise tax returns that are required to be filed on April 15 and May 15, 2020.

 

For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Ruth Madrigal | +1 202 533 8817 | ruthmadrigal@kpmg.com

Preston Quesenberry | +1 202 533 3985 | pquesenberry@kpmg.com

The KPMG logo and name are trademarks of KPMG International. KPMG International is a Swiss cooperative that serves as a coordinating entity for a network of independent member firms. KPMG International provides no audit or other client services. Such services are provided solely by member firms in their respective geographic areas. KPMG International and its member firms are legally distinct and separate entities. They are not and nothing contained herein shall be construed to place these entities in the relationship of parents, subsidiaries, agents, partners, or joint venturers. No member firm has any authority (actual, apparent, implied or otherwise) to obligate or bind KPMG International or any member firm in any manner whatsoever. The information contained in herein is of a general nature and is not intended to address the circumstances of any particular individual or entity. Although we endeavor to provide accurate and timely information, there can be no guarantee that such information is accurate as of the date it is received or that it will continue to be accurate in the future. No one should act on such information without appropriate professional advice after a thorough examination of the particular situation. For more information, contact KPMG's Federal Tax Legislative and Regulatory Services Group at: + 1 202 533 4366, 1801 K Street NW, Washington, DC 20006.

Connect with us

 

Want to do business with KPMG?

 

loading image Request for proposal