In Notice 2012-4, the IRS extended the filing deadline for Form 990 until March 30, 2012, for many tax-exempt organizations with a filing due date during the first two months of the new year. Organizations affected by the extension normally would have a filing deadline of January 17 or February 15, 2012. The extension does not affect calendar-year exempt organizations with a May 15, 2012, filing deadline.
The automatic extension was made necessary “to facilitate systems and programming changes” to the IRS’ e-filing computer system, which will not be available for filing Forms 990, 990-EZ, 990-PF and 1120-POL from January 1, 2012, through February 29, 2012. The extension applies to these forms whether or not organizations are required to file electronically. However, filing dates for the smallest exempt organizations that file the Form 990-N e-postcard are not extended.
Affected organizations may file electronically before January 1, 2012, or between March 1 and March 30, 2012, or they may file on paper during the suspension period, even if they are otherwise required to e-file. An organization required to e-file that files on paper may receive a system-generated request for an explanation; it need only cite the notice in its response.
Organizations whose original due date or first three-month extended date falls within the suspension period need not file Form 8868, Application for Extension of Time to File an Exempt Organization Return to file by March 30. However, an organization that has obtained two three-month extensions may not receive a further extension even if it falls within the suspension period. In that instance, organizations that do not file on paper but e-file by March 30 will be granted relief from a late-filing penalty. To avoid receiving a system-generated penalty notice, organizations may attach a reasonable-cause statement to their returns, using wording specified in the notice.
Any payment of tax due is not automatically extended; organizations must make a timely estimated tax payment or remit the payment with a paper filed return (or by electronic funds transfer if required) by their normal filing date.