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IRS announces certain tax-exempt organizations cannot e-file Form 990-T or Form 1120-POL until March 17

E-filing Forms 990-T and Forms 1120-POL with due dates from January 15 to March 15, 2024, is currently unavailable.

January 18, 2024

The IRS today announced that a “limited group” of tax-exempt organizations won’t be able to electronically file Form 990-T, Exempt Organization Business Income Tax Return, or Form 1120-POL, U.S. Income Tax Return for Certain Political Organizations, until March 17, 2024.

According to an IRS release, e-filing Forms 990-T and Forms 1120-POL (including returns on extension) with due dates from January 15, 2024, to March 15, 2024, is currently unavailable due to IRS system upgrades.

Affected taxpayers

Because organizations subject to unrelated business income tax (UBIT) are required by law to file Form 990-T electronically, an organization with a Form 990-T due (without extensions) from January 15 to March 15, 2024, needs to request an automatic six-month extension of time to file by submitting Form 8868, Application for Extension of Time To File an Exempt Organization Return, by the due date of the return. Any balance due must be submitted with Form 8868 to avoid interest and penalties.  

If an affected organization doesn’t timely submit an extension, or if the extended due date falls within the period from January 15 to March 15, 2024, and the organization consequently doesn’t timely e-file its Form 990-T, it needs to include with its late e-filed Form 990-T a request that any penalties for late filing not be imposed due to reasonable cause. The reasonable cause request should reference that e-filing was not available as of the due date of the return.

Organizations filing a Form 1120-POL that is due from January 15 to March 15, 2024, (including returns on extension) may file on paper. An organization that needs to e-file a return with an original due date during that period may request an automatic six-month extension of time to file Form 1120-POL by submitting Form 7004, Application for Automatic Extension of Time to File Certain Business Income Tax, Information, and Other Returns, and paying the full balance due with that form to avoid interest and penalties.

The IRS notes that a relatively small number of organizations are affected.

For more information, contact your usual KPMG tax professional or one of the following Washington National Tax professionals:

Ruth Madrigal | ruthmadrigal@kpmg.com

Preston Quesenberry | pquesenberry@kpmg.com

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