Most of the changes to the 2019 Forms 990-T and 990-PF were minor, including clarifications outlined in the instructions. A few of the more significant changes include:
Form 990-T
Form 990-PF
There are a few exceptions that allows an organization to paper file if:
1. Your application for exemption is pending, and the "If exemption application is pending, check here" box is checked in Item C.
2. You are a foreign organization, and you checked the box in either Item D1 or D2.
3. You are a foundation in a 60-month termination under section 507(b)(1)(B), and you checked the box in Item F.
4. Your organization’s name has changed, the new name is entered on Form 990-PF, and the "Name change" box is checked in Item G.
5. You are filing Form 990-PF for a short period because of an accounting period change. This does not apply if (a) the short period is an initial return, and the "Initial return" box is checked in Item G; or (b) the short period is for a final return, and the "Final return" box is checked in Item G.
6. You are filing Form 990-PF before the end of the tax year. This does not apply if the return is a final return, and the "Final return" box is checked in Item G.
7. You are an exempt foreign foundation and entered withholding tax in Part VI, line 6b.
8. You attempted to file Form 990-PF electronically, but the return was rejected.
The IRS Tax Exempt and Government Entities division (TE/GE) published its annual
Accomplishments Letter on March 23, 2020, which applies to ALL tax exempt organizations. Read it here: Tax Exempt and Government Entities Fiscal Year 2019 Accomplishments Letter
Highlights of the IRS’s accomplishments during FY 2019, all of which support the IRS’s Strategic Plan for 2018-2022, include:
You can also review the TE/GE Fiscal Year 2020 Program Letter, which explains the IRS’s priorities for the current fiscal year.
IRS Issues Proposed Regulations for Exempt Organizations calculate UBTI Separately for each Trade or Business
The IRS issued proposed regulations on April 23, 2020, regarding the new rule that requires tax-exempt organizations subject to tax on unrelated business taxable income (UBTI) to calculate UBTI separately with respect to each business — or to “silo” revenue and expenses for each separate business. These new rules were enacted as part of the Tax Cuts and Jobs Act and are found in Section 512(a)(6) of the Internal Revenue Code.
A more detailed discussion will be provided in our next news update. For any questions related to this article, or nonprofit tax services in general, please contact Bryan Pautsch at bpautsch@vlcpa.com or 800.887.0437.