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For nonprofit organizations that report on a calendar-year basis, the May 17, 2021, deadline to file Form 990 and Form 990-T electronically is quickly approaching. Nonprofits should take time to review the recently released revised Form 990-T and its accompanying instructions before preparing and electronically filing their 2020 returns.
Additionally, nonprofits should consider the final regulations issued in November 2020 under Internal Revenue Code section 512(a)(6) regarding the unrelated business income tax imposed on exempt organizations with more than one unrelated trade or business. These final rules addressed many concerns raised about the 2017 Tax Act changes, IRS Notice 2018-67 and the proposed regulations. Because Form 990-T and its accompanying revised Schedule A include significant changes to reflect these new rules, nonprofit organizations may also need to make changes to their internal record-keeping procedures, among other things, to properly address their annual tax filing obligations for 2020 and going forward.