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.


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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 |

Preston Quesenberry | +1 202 533 3985 |

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