Notice 2020-23 automatically postpones exempt organization (and disqualified person) filing and payment dates for (original or extended) forms and payments due on or after April 1, 2020, and before July 15, 2020, until July 15, 2020:
- Form 990*
- Form 990-EZ*
- Form 990-PF
- Form 990-T
- Form 990-W
- Form 1120-POL
- Form 4720
*Although not specifically itemized, but by reference to Rev. Proc. 2018-58, original and extended Forms 990 and Forms 990-EZ due between April 1 and July 15, 2020 are automatically extended to July 15, 2020. Therefore, the extension applies to all information returns, tax returns, excise taxes and income taxes.
Although exempt organizations (and disqualified persons) do not need to take any additional action to extend their filing or payment dates to July 15, 2020, those who need additional time to file may submit a Form 8868 on or before July 15, 2020. The extension date may not go beyond the original statutory or regulatory extension date (i.e., generally six months from the original due date).
Additional extensions
By incorporating Rev. Proc. 2018-58, Notice 2020-23 also extends the due date of certain notices, applications and other exempt organization activities due between April 1 and July 15, 2020, until July 15, 2020 (see section 10 of the revenue procedure):
- Application for Recognition of Exemption (Form 1023 and 1024)
- Section 501(h) Elections and Revocations (Form 5768)
- Political Organization Notices and Repots (Forms 8871 and 8872)
- Notification of Intent to Operate as a section 501(c)(4) Organization (Form 8976)
- Community health needs assessments (CHNAs)
- Private foundations notifying the IRS of their intent to begin a 60-month termination period
- Group exemption holders providing an annual update to the IRS at least 90 days before the end of their tax years
For additional information and a general discussion about Notice 2020-23, please read Overview of relief provided by Notice 2020-23
