Notice 2021-01: Delayed e-filing requirements, Form 4720 filed by private foundations

Delayed e-filing requirements, Form 4720

The IRS today released an advance version of Notice 2021-01 announcing a delay to a requirement for electronic filing of Form 4720 by private foundations.


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A provision of the Taxpayer First Act of 2019 (Pub. L. No. 116-25) provides that tax-exempt organizations under section 501(c)(3) that are classified as private foundations under section 509(a) must electronically file Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code, but allows the Treasury Secretary to delay the application of the e-filing requirement (but not later than for tax years beginning on or after July 1, 2021).

Notice 2021-01 [PDF 119 KB] announces because the Taxpayer First Act provisions “rendered unfeasible the ability for a private foundation and other persons to jointly file the same Form 4720 electronically,” the electronic filing requirement is delayed. The notice states that the IRS expects that a modified paper version of the Form 4720 will be available for use at the beginning of 2021. Under the authority granted to the Secretary, private foundations may continue to file the paper version of the Form 4720 until electronic filing of Form 4720 is available and the IRS announces that electronic filing of the Form 4720 is required (expected to be in early 2021).

Once electronic filing is required, any Forms 4720 filed thereafter by private foundations must be filed electronically in accordance with the instructions to Form 4720.

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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