United States

Changes to e-filing requirements for tax-exempt organizations

TAX ALERT  | 

A recent IRS news release summarizes the new requirement that tax exempt organizations electronically file information returns and related tax forms for tax years beginning after July 1, 2019, as enacted by the Taxpayer First Act.

This requirement applies to the following IRS forms:

  • Form 990, Return of Organization Exempt from Income Tax
  • Form 990-PF, Return of Private Foundation or section 4947(a)(1) Trust Treated as Private Foundation
  • Form 8872, Political Organization Report of Contributions and Expenditures
  • Form 1065, U.S. Return of Partnership Income (if filed by a section 501(d) apostolic organization)

Forms 990-T and 4720 implementation delayed

Form 990-T, Exempt Organization Business Income Tax Return, and Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code, are also subject to the requirement to e-file. However, the IRS will continue to accept these forms on paper for the 2020 filing season (i.e., reporting on tax year 2019). The IRS anticipates having these returns ready for e-filing in 2021 (reporting on tax year 2020). 

Forms 990-EZ transition relief

Organizations eligible to file Form 990-EZ, Short Form Return of Organization Exempt from Income Tax, may file either paper or electronic Forms 990-EZ for tax years ending before July 31, 2021. For tax years ending July 31, 2021 or later, organizations must electronically file Form 990-EZ.

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