COVID-19: IRS Extends Due Dates For Exempt Organization Filings

In our prior nonprofit alert, issued March 31, 2020, we reported that the Internal Revenue Service (the "IRS") had not extended most federal tax payment and filing deadlines for exempt organizations. The IRS notices issued up to that point (Notice 2020-18 and Notice 2020-20) postponed the due date for filing federal income tax and certain other returns and making federal income and certain other tax payments to July 15, 2020. Although the postponement applied to IRS Forms 990-T (Exempt Organization Business Income Tax Return) due to be filed on April 15, 2020, the relief did not apply to Forms 990-T due to be filed on May 15, 2020 or to Forms 990, 990-EZ or 990-PF.

On April 9, 2020, the IRS issued Notice 2020-23 (the "Notice"), which extends the tax payment and tax return filing deadline to July 15, 2020 for Forms 990, 990-EZ, 990-PF and 990-T not covered by the previous IRS notices. The Notice provides that any person with a specified federal tax payment obligation