ISSUE

For Institutions with a June 30 year end, Friday (11/15/19) is the deadline day for filing Form 990-series returns – or extensions.

 

SITUATION

Denali Christian College (DCC) is a private college exempt under Internal Revenue Code section 501(c)(3) and 170(b)(1)(A)(ii).  They are required to file Form 990 annually.

DCC has a new CFO that we enjoy working with.  He calls to ask about the Form 8868, “Application for Automatic Extension of Time To File an Exempt Organization Return” that we’ve been working on filing for Form 990 and Form 990-T for DCC’s tax year ended June 30, 2019.

“So, what form do we file to request an extension for our 990’s?”

“We will file two Form 8868’s: one for your Form 990 (with a code ‘01’) and a second one for Form 990-T (with a code ‘07’).  The ‘code’ is entered just below your name and address.”

“When is the extension due?”

“Just like the original due date of the Form 990-series returns, it is due four and a half months after your tax year end.  We’ve confirmed with your team that you do not owe any tax – even the dreaded ‘Parking Tax’ – on Form 990-T, so we do not need to make a payment with that extension.”

“Okay, do I have to sign the Form 8868?”

“No, a signature is not required.”

“Great.  Where do we file?”

“Department of the Treasury, Internal Revenue Service Center, Ogden, UT 84201-0045.”

“Make it happen!”

“Will do. Thanks!”

 

RULES

From the 2018 Form 990 instructions:

File Form 990 by the 15th day of the 5th month after the organization’s accounting period ends (May 15th for a calendar-year filer). If the due date falls on a Saturday, Sunday, or legal holiday, file on the next business day. A business day is any day that isn’t a Saturday, Sunday, or legal holiday.

From the 2018 Form 8868 instructions:

Where To File

If you do not file electronically, send the application to:

Department of the Treasury Internal Revenue Service Center Ogden, UT 84201-0045

No blanket requests. File a separate Form 8868 for each return for which you are requesting an automatic extension of time to file. This extension will apply only to the specific return checked. It does not extend the time for filing any related returns. For example, an extension of time for filing a private foundation return will not apply to the return of certain excise taxes on charities (Form 4720).

Tax Payments General rule. Except as provided in the “Special payment option for small foundations” [in instructions], each tax-exempt organization must make all federal tax deposits (including excise and income taxes) electronically. You can use the Electronic Funds Tax Payment System (EFTPS) to make federal tax deposits.

 

BOTTOM LINE

  • The Form 990-series deadline is the 15th day of the 5th month after your institution’s accounting period ends. So, if your institution’s year end is June 30, Friday 11/15/19 is your filing deadline.  An extension of time to file may be requested by filing Form 8868.
  • Some institutions are not required to file Form 990 annually, but they may still be required to file Form 990-T to report unrelated business income.
  • File a separate Form 8868 (extension) for each type of 990-series return required to be filed.
  • Remember to make a payment if you owe tax – usually on Form 990-T. This includes the “Parking Tax!”

Specific questions? Email Dave Moja

The information provided herein presents general information and should not be relied on as accounting, tax, or legal advice when analyzing and resolving a specific tax issue. If you have specific questions regarding a particular fact situation, please consult with competent accounting, tax, and/or legal counsel about the facts and laws that apply.

© 2019 Moja & Company, LLC