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IRS and New York State Extend the Deadline for Not-For-Profit Organizations to File Federal Tax Returns

April 13, 2020

Recently, both the Internal Revenue Service (“IRS”) and the New York State Attorney General’s Charities Bureau provided guidance on the imminent tax due dates for not-for-profit organizations.



On April 9, 2020 the IRS issued Notice 2020-23, which provides an update to previously issued Notice 2020-18, and expands the relief previously offered to taxpayers on making federal tax payments and filing federal tax returns.

The notice automatically extends the deadlines for not-for-profit organizations with a federal tax payment obligation or a federal tax return filing obligation, which were due (originally or by a valid extension) on or after April 1, 2020 and before July 15, 2020 until July 15, 2020.

The extension applies to the following:

  • Form 990
  • Form 990-EZ
  • Form 990-PF
  • Form 990-T
  • Form 990-W
  • Form 1120-POL
  • Form 4720

For organizations filing Form 1023 and Form 1024, the notice also extends the 27-month period to obtain recognition of exemption from the organization’s formation date.

The extension is automatic, and organizations do not need to file any extension forms or other requests to receive this relief. However, organization that need additional time to file beyond July 15, 2020 may choose to file the appropriate extension form by July 15, 2020 to obtain an extension on filing their return. Additional extension dates may not go beyond the original statutory or regulatory extension date.

New York

Additionally, the New York State Attorney General’s Charities Bureau has announced that, in order to assist charities during the COVID-19 pandemic, an automatic six-month extension of time for filing NY Form CHAR500 will be granted.

This extension applies to any organization whose filing deadline, including the standard automatic six-month extension, was originally after February 15, 2020.

For example, the annual financial report of organizations whose year-end is June 30, 2019, and who utilized the standard, automatic six-month extension, must be filed by May 15, 2020. However, with this additional automatic extension, the report is not due until November 15, 2020.

Please contact your Mazars USA LLP professional for additional information

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