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Thursday, July 9, 2020   (0 Comments)
Posted by: Sabrina Hidalgo
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Reminder: July 15, 2020 IRS Filing Deadline
Religious institutes and their sponsored works are reminded that certain forms which may be filed with the IRS are due on July 15, 2020. For religious institutes and sponsored works that operate on a calendar-year basis, this includes the 2019 Form 990 that would have normally been filed on May 15, 2020. The upcoming July 15, 2020 deadline applies to many forms that were originally due May 15, 2020 including:
  • Form 990-series annual information returns (Forms 990, 990-EZ, inter alia)
  • Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required to File Form 990 or Form 990-EZ
  • Form 990-T, Exempt Organization Business Income Tax Return
A religious institute or sponsored work that needs additional time to file beyond the July 15, 2020 deadline can request an automatic extension by filing Form 8868, Application for Extension of Time to File an Exempt Organization Return. An organization will be allowed a six-month extension beyond the original due date. For a calendar-year 2019 return, this means the extended deadline would be November 15, 2020. In situations where tax is due, extending the time for filing a return does not extend the time for paying tax.
The exclusively religious activities of a religious institute are exempt from filing a Form 990 EZ/N report, as spelled out in the IRS regulations. At the same time, there is no automatic exemption from the Form 990/EZ/N requirement simply because an organization is included in the Group Ruling or listed in the Official Catholic Directory. Organizations should exercise caution if they choose not to file a Form 990/EZ/N because they believe they are not required to do so.  For more information, see USCCB Group Ruling Memorandum dated October 10, 2019, especially number 8 at page 5.
The IRS urges all organizations to take advantage of the speed and convenience of filing their returns electronically when possible.
Navigating the Covered Period of the Paycheck Protection Program (“PPP”)
As religious institutes are reviewing their application for loan forgiveness under the PPP program of the CARES Act, as well as the Paycheck Protection Program Flexibility Act (“Flexibility Act”) of June 5, 2020, numerous questions have been received related to the Covered Period. The Covered Period is the original 8-week period created by the CARES Act, or the 24-week period or December 31, 2020 deadline created by the Flexibility Act.
Specifically, questions have been received regarding allowable payroll and non-payroll costs that must be expended within the Covered Period. When are payroll costs considered incurred? When are payroll costs considered paid? When does the Covered Period begin? What is the Alternative Payroll Covered Period? When and how are non-payroll costs (mortgage interest, rent, and utilities) considered incurred or paid, especially those costs which either pre-date or post-date the Covered Period?
While too expansive to address here, members are encouraged to contact RCRI with your questions related to navigating the Covered Period of the PPP.

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