While much of the new CARES Act focuses on stimulus for taxable entities, tax-exempt entities also received some relief and clarifications on filing and payment due dates, albeit buried in subsequent guidance issued weeks later.
Revenue Procedure 2020-23 was issued on April 13, 2020, to amplify Rev. Procs. 2020-18 and 2020-20. This latest guidance lists out additional affected taxpayers whose returns and payments that would have otherwise been due between April 1, 2020, and July 15, 2020, can now enjoy a postponement relief until July 15, 2020. Typical tax-exempt filings such as Forms 990-T, 990-PF, 990-W, and Form 4720 were all listed, but curiously enough, Form 990 was left off the list.
However, the Notice also states that ‘any person performing a time-sensitive action listed in…Rev. Proc. 2018-58…, which is due to be performed on or after April 1, 2020, and before July 15, 2020, is an Affected Taxpayer.’ Rev. Proc. 2018-58 lists Form 990, and in the most round-about way possible, even by IRS standards, the non-profit world releases a collective sigh of relief in confirming postponement filing for tax-exempt entities until July 15, 2020.
In addition, the NYS Charities Bureau has announced that any organization whose filing deadline, including extensions, was originally after February 15, 2020, will be given an additional six-month extension to files it's annual financial report.
The information and advice we are providing for this matter relates to COVID-19 legislative relief measures. Because legislative efforts are still ongoing, we expect that there may be additional guidance and clarification from regulators that could modify some of the advice and information provided to you, after the conclusion of our engagement. We therefore make no warranties, expressed or implied, on the services provided hereunder.