While most taxpayers are focused on the individual tax filing due date, there’s another deadline looming. In addition to being the revised individual and corporate due date for the 2019 tax year, July 15, 2020, marks the filing deadline for many tax-exempt organizations.
Information returns for tax-exempt organizations are ordinarily due on the 15th day of the fifth month after the close of the tax year. If the due date falls on a Saturday, Sunday, or legal holiday, the due date is the next business day. This means that May 15 is usually the deadline for most tax-exempt organizations to file. However, for the 2019 tax year, the deadline for tax-exempt organizations was pushed to July 15, 2020.
A regular filing requirement used to only apply to organizations that brought in a lot of donations or held significant assets. However, that changed with the Pension Protection Act of 2006, which made it mandatory for most tax-exempt organizations to file an annual information return with the Internal Revenue Service (IRS) regardless of how little income the organization receives. Failure to do so for three consecutive years results in an automatic loss of tax-exempt status (exceptions apply for churches and some church-related organizations).
Small tax-exempt organizations with average annual receipts of $50,000 or less have the option of filing a Form 990-N, e-Postcard. If you want to skip the e-Postcard, you can submit a longer form 990 or 990-EZ, but you have to complete the entire form.
The e-Postcard only takes a few moments to fill out and requires just a few pieces of information:
- Name of the organization (including any alternative names);
- The mailing address for the organization;
- The organization’s Employer Identification Number (EIN);
- Tax year (typically, if you’re filing in 2020, the tax year is 2019);
- Name and address of a principal officer;
- The website address for the organization, if any;
- Confirmation that the organization’s annual gross receipts are $50,000 or less; and
- Confirmation that the organization has terminated or is going out of business, if applicable.
Filing the e-Postcard is free and is only available online via the IRS website here (there is no paper version). If you haven’t completed an e-Postcard before, you’ll need to register online before you can proceed. If you registered last year, just log into the site using your existing user ID. If you’re still not sure how to proceed, the Internal Revenue Service (IRS) created a reference guide (Pub 5248 downloads as a pdf).
For all other tax-exempt organizations, the filing requirements are as follows:
- For tax-exempt organizations with annual gross receipts of less than $200,000 and total assets of less than $500,000, file form 990-EZ or a form 990-EZ.
- For tax-exempt organizations with annual gross receipts of $200,000 or more or total assets of $500,000 or more, file form 990 (downloads as pdf).
- Organizations classed as private foundations must file a form 990-PF (downloads as pdf) regardless of assets or receipts.
Failure to file for three consecutive years will result in an automatic loss of tax-exempt status. If that happens, the organization will not be eligible to receive tax-deductible contributions. There is no appeal process: The organization will have to file for reinstatement, even if it was not originally required to apply for an exemption. In other words, be sure to file since reinstatement can be time consuming and expensive.
If you need more time to file a Form 990, you can request a six-month extension (remember, though, that the extension will only extend the filing deadline from the original due date of May 15, not the revised due date of July 15). Simply file form 8868, Application for Extension of Time to File an Exempt Organization Return (downloads as a pdf) on or before the due date. There is no extension available for Form 990-N (e-Postcard), but there is also no penalty if you file it late.
It’s also important to note that parts of forms in the 990 series will be available for public inspection. Some information on Form 990-N is also available to the public via the new IRS Tax Exempt Organization Search (TEOS) tool on the IRS website. Some forms 990, 990-EZ, and 990-PF are also available online using TEOS, and more will be added this year as they are filed. That means that you should not include Social Security Numbers (SSNs) of officers, donors, clients, or other individuals on the series 990 forms for privacy reasons.
Finally, even though there’s no tax due for most tax-exempt organizations, be sure to file a complete or accurate return. If the return is incomplete or if you use the wrong form for the organization, the IRS will send it back.