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Form 990 Filing Deadline Extended For Some Tax-Exempt Organizations

January 17, 2012

Michelle Y. Hatch, CPA

In December 2011, the IRS issued Notice 2012-4 which notified tax-exempt organizations that the IRS eFile system would not be available from January 1, 2012 through February 29, 2012 for electronic filing of Form 990, Form 990-EZ, Form 990-PF and Form 1120-POL.  For organizations with filing due dates (or first three-month extended due dates) during this period, these organizations have the following options:

  • File electronically between March 1, 2012 and March 30, 2012
  • File in paper during the suspension period (January 1, 2012 through February 29, 2012)

This extension of time to file is automatic and affects tax-exempt organizations with August and September year-ends, and organizations with May and June year-ends that have already filed for a three-month extension.

For organizations that have already obtained two three-month extensions of time to file (i.e. the full six-month extension allowed by statute), the IRS will provide relief from any late filing penalty to these organizations provided their returns are filed by March 30, 2012.  In order to avoid receiving a system-generated penalty notice for late filing, each affected, organization should attach a Reasonable Cause Statement to its return.

If an organization needs to file for an extension of time to file during this period – either a first or second extension (i.e. by February 15, 2012), this date has not been affected and the organization will need to file Form 8868 as originally due.

Organizations should be aware that the above extension of time to file is not an extension of time to pay any tax liabilities that may be due for the year.  Therefore, an organization that has a tax liability for a return that has a due date that falls within the suspension period must make a timely payment of the amount due either by making an estimated tax payment or by filing its return on paper, if permitted, and remitting payment with its return or by electronic fund transfer, if required.

Organizations that file Form 990-N (e-Postcard) can continue to file electronically during this period.

Michelle Y. Hatch, CPA, is a Principal with BlumShapiro, the largest regional accounting, tax and business consulting firm based in New England, with offices in West Hartford and Shelton, CT and Boston and Rockland, MA.  The firm serves as business advisors for today’s leading companies, non-profit organizations and government entities, working to strategically tailor and consistently deliver tested solutions for unlocking an organization’s full potential. For more information about BlumShapiro, visit


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