The Taxpayer First Act signed by President Trump, and enacted on July 1, 2019, institutes a new e-file mandate for tax-exempt organizations.
This new mandate will potentially have a large impact on those organizations that have preferred to paper file their returns in the past. In addition, the mandate will likely cause many organizations who prepare their returns in-house, to either upgrade their tax software or hire an outside tax preparer in order to comply with the new e-filing requirements.
This e-file mandate takes effect for tax-exempt organizations that file Form 990 or Form 990-PF with tax years beginning after July 1, 2019. The chart below summarizes Form 990 and Form 990PF due dates based on the organization’s tax year.
| Tax Year Beginning / Tax Year Ending | Due Date | Extended Due Date |
| August 1, 2019 – July 31, 2020 | December 15, 2020 | June 15, 2021 |
| September 1, 2019 – August 31, 2020 | January 15, 2021 | July 15, 2021 |
| October 1, 2019 – September 30, 2020 | February 15, 2021 | August 15, 2021 |
| November 1, 2019 – October 31, 2020 | March 15, 2021 | September 15, 2021 |
| December 1, 2019 – November 30, 2020 | April 15, 2021 | October 15, 2021 |
| January 1, 2020 – December 31, 2020 | May 15, 2021 | November 15, 2021 |
| February 1, 2020 – January 31, 2021 | June 15, 2021 | December 15, 2021 |
| March 1, 2020 – February 28, 2021 | July 15, 2021 | January 15, 2022 |
| April 1, 2020 – March 31, 2021 | August 15, 2021 | February 15, 2022 |
| May 1, 2020 – April 30, 2021 | September 15, 2021 | March 15, 2022 |
| June 1, 2020 – May 31, 2021 | October 15, 2021 | April 15, 2022 |
| July 1, 2020 – June 30, 2021 | November 15, 2021 | May 15, 2022 |
In addition, it should be noted that the Form 990-EZ e-file requirements have been postponed until tax years beginning after July 1, 2020.
Form 990-T will also be required to be e-filed for the tax year 2020 (reporting in 2021) once the IRS updates their system. A specific start date for the 990-T e-file mandate has not yet been announced as to this article’s date.
If you have any questions regarding the new e-file mandate for tax-exempt organizations, please reach out to either Eric Beining or CaLandra James.
