Notice 2020-23: Relief for tax-exempt taxpayers affected by coronavirus pandemic (COVID-19)

Relief for tax-exempt taxpayers affected by coronavirus

The IRS released an advance copy of Notice 2020-23 that amplifies and significantly expands the relief previously provided in Notice 2020-18 and Notice 2020-20 in response to the coronavirus (COVID-19) pandemic.


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Notice 2020-23 [PDF 102 KB] automatically postpones due dates for “Affected Taxpayers” (as defined by this notice), with respect to an expanded list of federal tax returns, tax payments, forms, and schedules due on a date during the period beginning April 1, 2020, and ending July 15, 2020. The postponed due date is July 15, 2020. Read also a related IRS release: IR-2020-66 (April 9, 2020).


Relief for exempt organizations

Among the expanded list are numerous federal returns and payments applicable to tax-exempt organizations—including the Form 990, Return of Organization Exempt From Income Tax; Form 990-PF, Return of Private Foundation; and Form 4720, Return of Certain Excise Taxes under Chapters 41 and 42 of the Internal Revenue Code

Notice 2020-23 accomplishes the extension of the deadline to file Form 990 by stating that any person performing a “time-sensitive action” listed in Rev. Proc. 2018-58 that is due to be performed on or after April 1, 2020, and before July 15, 2020, is an Affected Taxpayer. Section 10 of Rev. Proc. 2018-58 lists numerous time-sensitive actions relevant to tax-exempt organizations, including not only the filing of Form 990 series annual returns, but also such actions as filing a Form 1023, Application for Recognition of Exemption under Section 501(c)(3), within 27 months from the end of the month in which the organization was organized and, in the case of a tax-exempt hospital organization, conducting a community health needs assessment at least once every three tax years.

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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