Notice 2020-18 provides limited relief to exempt organizations

Mar 24, 2020
Mar 24, 2020
0 min. read

Revised as of March 25, 2020

Exempt organizations required to file 990 series tax returns will see little impact from the filing and payment relief issued in response to the Coronavirus pandemic. On March 20, 2020, the IRS and the Department of Treasury released Notice 2020-18, which automatically postpones the April 15, 2020 filing and payment date to July 15, 2020. Read the RSM Tax Alert.

Certain Forms 990-T and 1120-POL affected

However, the notice applies exclusively to income tax returns and payments due on April 15, 2020. Forms 990, 990-EZ and 990-PF are information returns (not income tax returns), and their original due date (for 2019 calendar year taxpayers) is May 15, 2020 (not April 15, 2020). Therefore, the extension does not apply to these returns. Even calendar year organizations with unrelated business taxable income and a Form 990-T filing requirement generally will not have relief under the notice because the due date for most returns is also May 15, 2020.

Nevertheless, the notice affords relief to a limited subset of exempt organization returns:

  • Forms 990-T filed by certain exempt trusts with a December 31 year end (e.g., section 401(a) pension trusts have an original due date of April 15, 2020);
  • Forms 1120-POL filed by political organizations and certain exempt organizations with political activity that have a December 31 year end (e.g., section 527 political action committees and section 527(f) political expenditures); and
  • Forms 990-T and 1120-POL filed by fiscal year taxpayers with original or extended due dates of April 15, 2020.

The notice automatically extends the April 15, 2020 filing date to July 15, 2020. If April 15, 2020 was the original due date, the taxpayer may request an additional extension of time to file by submitting a Form 8868 (Form 990-T) or Form 7004 (Form 1120-POL) on or before July 15, 2020. 

Certain estimated tax payments of UBIT extended

The notice also postpones the due date for making estimated income tax payments, originally due April 15, 2020, until July 15, 2020. This extension affects most calendar year Form 990-T filers (excluding private foundations) and some fiscal year Form 990-T taxpayers that have quarterly estimated tax payments due April 15, 2020.

Summary and FAQs

On March 24, 2020, the IRS posted Filing and Payment Deadlines Questions and Answers to its website, providing additional clarity with respect to Notice 2020-18 and its application to specific tax returns.

The chart below summarizes the impact of Notice 2020-18 on due dates for exempt organization tax returns:

Tax Return

Tax Year End

Due Date

Form 1120-POL

Dec. 31, 2019

July 15, 2020

Form 990-T – 401(a) trusts, IRAs (including SEPs and SIMPLEs), Roth IRAs, Coverdell ESAs, or Archer MSAs

Dec. 31, 2019

July 15, 2020

2019 fiscal year Forms 990-T and 1120-POL with a 4/15/2020 original or extended due date

Tax years ending 2019

July 15, 2020

Estimated income tax payments due 4/15/2020

Tax years ending 2020

July 15, 2020

Due dates with respect to all other tax-exempt information returns, tax returns and excise tax returns not specifically listed above remain unchanged.


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