PUBLISHED 4/14/2020

Prepared by Michigan Community Resources with information from the Internal Revenue Service (IRS)

The IRS has extended its filing deadline to July 15, 2020, which applies to Form 990-series returns and notices for nonprofit organizations. 

Tax-exempt organizations are required to file their Form 990-series annual information returns or notices (Forms 990, 990-EZ, 990-PF, 990-BL, 990-N e-postcard) no later than 4½ months after the end of their fiscal year. For nonprofits that operate on a fiscal year ending Dec. 31, that would normally mean filing their Form 990 by May 15.

Tax-exempt organizations that had a May 15 deadline will now have until July 15 to file their 990 without having to file an extension because of the novel coronavirus (COVID-19). This extension is important temporary relief from paperwork as nonprofits continue to focus on their missions and response to COVID-19 as well as attending to the organizational challenges resulting from this unprecedented time.

Please see below for the full April 14 e-news update from the IRS that includes helpful links and information related to COVID-19 and the IRS response:

From the Exempt Organizations Update: e-News for Charities & Nonprofits

April 14, 2020

IRS EXTENDS MORE TAX DEADLINES, INCLUDING FORM 990-SERIES RETURNS AND NOTICES

Last month, the IRS announced that certain taxpayers generally have until July 15, 2020, to file and pay federal income taxes originally due on April 15. The IRS has extended this relief to additional returns, tax payments and other actions. As a result, the extensions generally now apply to all taxpayers that have a filing or payment deadline falling on or after April 1, 2020, and before July 15, 2020. The extensions apply to many forms and tax payments made by tax-exempt organizations, including: 

• Form 990-series annual information returns or notices (Forms 990, 990-EZ, 990-PF, 990-BL, 990-N (e-postcard))
• Forms 8871 and 8872
• Form 5227
• Form 990-T
• Form 1120-POL
• Form 4720
• Form 8976

See Notice 2020-23 and Rev. Proc. 2018-58 for more information, including a complete list of affected forms, tax payments and other time-sensitive actions.

IRS OPERATIONS DURING COVID-19: MISSION-CRITICAL FUNCTIONS CONTINUE
In response to the coronavirus (COVID-19) crisis, the IRS is continuing with mission-critical activities for the nation but is limiting some operations. To protect the public and employees, and in compliance with orders of local health authorities around the country, certain IRS services such as live assistance on telephones, processing paper tax returns and responding to correspondence are extremely limited or suspended until further notice. As a result, the following services related to Tax Exempt and Government Entities are suspended until further notice:  

• Telephone customer accounts services 
• Some updates to Tax Exempt Organization Search 

The IRS strongly urges taxpayers applying for recognition of exempt status under IRC Section 501(c)(3) to use the electronically-submitted Form 1023 or, if eligible, the Form 1023-EZ.

IRS.gov remains the best source for tax law questions. Continue to visit IRS.gov and our Charities and Nonprofits page for information, news, and educational resources about charities and other tax-exempt organizations. Refer to Revenue Procedure 2018-32 for more information for grantors and contributors to tax-exempt organizations on deductibility and reliance issues.

IRS updates on COVID-19 related issues are posted on IRS.gov/coronavirus.
 
THE FAMILIES FIRST CORONAVIRUS RESPONSE ACT (FAMILIES FIRST ACT) AND THE CORONAVIRUS AID, RELIEF, AND ECONOMIC SECURITY (CARES) ACT 
The Families First Act and the CARES Act provide considerable relief for exempt organizations, including grants, loans, tax credits, and other assistance. Visit IRS.gov/coronavirus for the latest information about eligibility details and other requirements for the tax provisions under these Acts.

ACCEPTANCE OF IMAGED AND DIGITAL SIGNATURES AND THE ELECTRONIC TRANSMISSION OF DOCUMENTS
As part of the response to the COVID-19 emergency, the IRS will temporarily allow employees to accept: 

• Images of signatures (scanned or photographed) and digital signatures on documents related to the determination or collection of tax liability
• Documents via email and to transmit documents to taxpayers using SecureZip or other established secured messaging systems

 This change expires July 15, 2020. Visit IRS.gov for details (PDF).

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If you have a technical or procedural question about Exempt Organizations, visit the Charities and Nonprofits homepage on IRS.gov.
If you have a specific question about exempt organizations, call EO Customer Account Services at 877-829-5500.

CONTACT US:
Michigan Community Resources is continuing to offer trusted guidance for nonprofit organizations during this time. Please contact the MCR Legal Team at 313.962.3171 ext. 101 or legal@mi-community.org.

As part of our service to our clients, Michigan Community Resources regularly compiles and shares short reports on new and interesting developments and the issues they raise for nonprofit organizations. Please recognize that these reports do not constitute legal advice and that we do not attempt to cover all such developments. Your comments are always welcome.

Please note: These resources have been prepared by Michigan Community Resources as information only and does not constitute legal advice.  This information is not intended to create and receipt of the information does not constitute a client-lawyer relationship.