Country / Language

IRS Announces Two-Month Suspension of IRS Modernized e-File Operations for 990 Filers


The Internal Revenue Service ("IRS") has notified tax-exempt organizations that the IRS Modernized e-file ("MeF") system will not be available from January 1, 2012 through February 29, 2012 for electronic filing of Forms 990, 990-EZ, 990-PF, and 1120-POL information returns. It is therefore suspending the availability of the system to implement changes to IRS programs and systems for the 2011 tax year. The 990-N e-postcard filing system will not be affected by the MeF system's temporary suspension which is taking place in order to facilitate systems and programming changes.

To minimize the impact on affected organizations, the IRS will grant an extension of time to file to March 30, 2012 to organizations whose due date or first extended due date for returns is January 17, 2012 or February 15, 2012. Affected organizations required to file electronically may file electronically prior to January 1, 2012 or between March 1, 2012 and March 30, 2012. Organizations that are not required to file electronically may do the same and, alternatively, may file a paper return at any time before March 30, 2012. In addition, certain affected organizations normally required to file electronically will have the option to file a paper return during the suspension period.

An affected organization that has not previously received an extension and wishes to extend its filing due date until after March 30, 2012 may request an automatic three-month extension by filing Form 8868, Extension of Time to File an Exempt Organization Return, by its original due date. If an affected organization has already obtained an automatic three-month extension, the IRS will grant the organization an additional three-month extension if the organization properly completes and files Form 8868 by its first extended due date. Organizations that have already been granted two extensions for a total of six months may not request a further extension.

Note that an extension of the time to file, including the automatic extension to March 30, 2012 provided in the IRS's recent announcement, is not an extension of time to pay any tax liabilities that may be due for the year.

Organizations with a filing due date (or first extended due date) between January 1, 2012 and February 29, 2012 that file their returns by March 30, 2012 will be considered to have timely filed. In the case of an organization with a second extended due date that falls during the suspension period, the organization will have reasonable cause for late filing and will not be subject to the late filing penalties if it files by March 30, 2012. The organization should attach a Reasonable Cause Statement to its return, referencing Notice 2012-4, in order to avoid receiving a system-generated penalty notice for late filing. Some organizations generally required to file electronically that have already obtained two three-month filing extensions may be uncomfortable with taking advantage of the late filing penalty relief described in this alert. In that circumstance, the organization may file its return on paper during the suspension.

Read the full announcement from the IRS here. For information on how this announcement may impact your not-for-profit organization, please contact Thomas Lanning, CPA, partner and member of the Firm's Not-for-Profit Industry Practice, at tlanning@jhcohn.com or 646-834-4108 or your J.H. Cohn engagement partner at 877-704-3500.

Circular 230 Notice: In compliance with U.S. Treasury Regulations, the information included herein (or in any attachment) is not intended or written to be used, and it cannot be used, by any taxpayer for the purpose of i) avoiding penalties the IRS and others may impose on the taxpayer or ii) promoting, marketing, or recommending to another party any tax related matters.

This has been prepared for information purposes and general guidance only and does not constitute professional advice. You should not act upon the information contained in this publication without obtaining specific professional advice. No representation or warranty (express or implied) is made as to the accuracy or completeness of the information contained in this publication, and J.H. Cohn LLP, its members, employees and agents accept no liability, and disclaim all responsibility, for the consequences of you or anyone else acting, or refraining to act, in reliance on the information contained in this publication or for any decision based on it.

Published date: 12/21/2011

Search Our People

Search Our People

Look ahead. Gain insight. Imagine more. Is your business ready to break through?

View our new TV commercial..

Industry Outlooks

Industry Outlooks

Gain insight into what is ahead for the Commercial Real Estate, Technology and Middle Market Private Equity industries.

READ MORE

Learn about our upcoming events.

READ MORE

Working With Us

Working With Us

What makes CohnReznick different from others in our profession? And what should our clients come to expect when working with us? The answer is The CohnReznick Advantage. Contact us to learn how we can out the CohnReznick Advantage to work for your business.


People

The value of an organization is determined by the skills and qualities of its leaders. With more than 280 partners serving clients nationwide, CohnReznick is renowned for the diverse experiences, knowledge and backgrounds of its leadership.

Learn More

Services

We align our services in three segments: Accounting and Assurance, Tax, and Advisory. This approach allows us to provide holistic solutions to complex business problems and to seize upon opportunities requiring an integrated approach.

Learn More

Industries

Accounting and tax issues different significantly based on an organization's industry. We provide clients with expertise in nearly two dozen industries – we know the opportunities, the obstacles, the competitive landscape.

Learn more

Insights

CohnReznick professionals are thought leaders in their industries. Clients benefit from relevant and timely economic, legislative and industry insights that can keep them a step ahead of competition.

Learn More

Global Reach

Our involvement in the Nexia International network of firms enables us assist our clients wherever they do business-providing local expertise and connections wherever they needed. Nexia is comprised of 20,000 professionals operating in over 100 countries.

Learn More