The Taxpayer First Act, enacted July 1, 2019, requires tax-exempt organizations to electronically file information returns and related forms. The new law affects organizations with tax years beginning after July 1, 2019.

The following IRS forms are included in the mandate:

• Form 990, Return of Organization Exempt from Income Tax (For tax years ending July 31, 2020 and later)
• Form 990-PF, Return of Private Foundation or Section 4947(a)(1) Trust Treated as Private Foundation (For tax years ending July 31, 2020 and later)
• Form 1065, U.S. Return of Partnership Income (if filed by a Section 501(d) apostolic organization)
• Form 8872, Political Organization Report of Contributions and Expenditures (for periods starting on or after January 2020)

Form 990 and 990-PF e-filing

Form 990 and 990-PF filings for tax years ending on or before June 30, 2020, may still be on paper. In the case of a short tax year or certain other circumstances detailed in the 990 or 990-PF Instructions, the IRS will continue to accept paper filing as its systems are yet unable to receive these forms electronically. More information on software providers is available at IRS.gov.

Form 990-EZ transition relief 

For small exempt organizations, the legislation specifically allowed a postponement (“transitional relief”). For tax years ending on and before July 31, 2020, the IRS will accept either paper or electronic filing of Form 990-EZ, Short Form Return of Organization Exempt from Income Tax. For tax years ending Aug. 31, 2020, and later, Forms 990-EZ must be filed electronically. Generally, Form 990-EZ is for organizations with annual gross receipts less than $200,000 and total assets at tax year-end less than $500,000.

Paper Forms 990-T and 4720

In 2020, the IRS will continue to accept paper forms that are pending conversion into electronic format. These include Form 990-T, Exempt Organization Business Income Tax Return and Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code. The IRS plans to have these returns ready for e-filing in 2021 (reporting on tax year 2020).

Those who have previously filed paper forms will receive a letter from the IRS informing them of the change.

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