Federal Tax Deadlines for Exempt Organizations: Essential Compliance requirements along with their required deadlines

When it comes to federal tax filings, exempt organizations have various deadlines and requirements based on their classification and financial activities. Below is an overview of key federal tax deadlines for different entities, including necessary forms, special rules, and potential state-level filings.

Key Federal Tax Forms and Deadlines

Form 990 – Various Versions

Form 990 is required for tax-exempt organizations to report their financial details and maintain their tax-exempt status. Different versions of Form 990 have varying eligibility criteria:

• Form 990 – Standard version for larger organizations with gross receipts of $200,000 or more or total assets of $500,000 or more.
• Form 990-EZ – For organizations with gross receipts less than $200,000 and total assets less than $500,000.
• Form 990-N (e-Postcard) – For organizations with average gross receipts of $50,000 or less during the past three years.
• Form 990-PF – For private foundations. 990-PF must be filed by a private foundation regardless of revenue level or their total assets.

Deadline: The standard deadline for filing Form 990, 990-EZ, and 990-PF is the 15th day of the 5th month after the end of the organization's fiscal year (for example, a calendar year filer would have a filing deadline of May 15th. Extensions may be available by filing Form 8868. The extension will extend the deadline by six months. For example, for a calendar year filer who has an initial deadline of May 15th, the extension will extend the deadline to November 15th. No further extensions would be available after November 15th.

For 990-N filers, an extension is not required to be filed, and the e-postcard can be filed within a year after-year end. However, it is imperative to know if your organization meets the criteria to file a 990-N before the initial Form 990 filing deadline.

Form 990-T
Form 990-T is required for any tax-exempt organizations who have gross unrelated business income of greater than $1,000.

Deadline: The filing deadline is the 15th day of the 5th month after the end of the organization's fiscal year (for example, a calendar year filer would have a filing deadline of May 15th.  Extensions may be available by filing Form 8868. The extension will extend the deadline by six months. Additionally, any tax due with the 990-T filing must be paid at the time of the extension filing.

Estimated tax payments
Estimated tax payments are required to be made for any 990-T filers who expect to owe $500 or more in taxes.

Deadline: Payments must be made quarterly. In the situation of a calendar year 990-T filer, payments would be due April 15th, June 15th, September 15th, and December 15th. 

Form 1120-POL
Form 1120-POL is required for political organizations that have taxable income from non-exempt activities (e.g., investment income). Organizations that are not exempt under 501(c)(3) who incur political activities expenditures and have investment income, must file the 1120-POL.

Deadline: The filing deadline is April 15 for calendar-year organizations or the 15th day of the 4th month after the fiscal year ends. Any tax due with the return must be paid with the extension filing.

PACs (Political Action Committees)
Political Action Committees (PACs) may need to file various reports with the IRS and Federal Election Commission (FEC). The IRS tax requirement primarily applies if the PAC generates taxable income, necessitating Form 1120-POL. Additional periodic filings may be required with the FEC, depending on contributions and expenditures.

Form 1023/1024 – 27-Month Rule

• Form 1023 (Application for Recognition of Exemption under Section 501(c)(3)) and Form 1024 (for other types of exempt organizations) must be filed to obtain tax-exempt status.
• If filed within 27 months of the organization’s incorporation date, tax-exempt status may be granted retroactively to the incorporation date. Otherwise, the effective date is the filing date.

State Filings That May Be Required
While federal tax forms are essential, state-level filings may also be necessary depending on an organization’s activities and revenue sources. Some common state filing requirements include:

• State Filings for Form 990-T: If an organization files Form 990-T (Exempt Organization Business Income Tax Return) for unrelated business income, certain states may require a separate state tax return for unrelated business income. The states follow the same deadline as the federal filing.
• Charitable Registrations: Many states require nonprofits engaged in fundraising activities to register and file annual reports with state agencies, often through an attorney general’s office or department of revenue. A majority of states follow the federal deadlines, but some states have a universal deadline regardless of year-end, and some states have a deadline of six months after year-end. Please check the Secretary of State or Attorney General website for each state for precise filing deadlines as well as requirements for when it comes to extending the required filings.

Final Thoughts
Understanding and adhering to federal tax deadlines is essential for maintaining compliance and good standing, and more importantly avoiding penalties. Organizations should also be aware of potential state requirements that may apply. Consulting with a tax professional or legal advisor is highly recommended to ensure all obligations are met timely and accurately.