What IRS Form 990-BL (2018) Is For

IRS Form 990-BL (2018) is a specialized tax document designed for Black Lung Benefit Trusts and certain related persons. It functions as an information and initial excise tax return, ensuring compliance with Internal Revenue Code section 4951. The form reports the trust’s gross receipts, disbursements, and other financial activities related to supporting miners suffering from pneumoconiosis, also known as black lung disease.

This form also applies to related persons involved in transactions with these trusts that may create excise tax liabilities. It allows the Internal Revenue Service (IRS) to verify that funds are being used strictly for permitted purposes and that prohibited transactions are disclosed. 

When You’d Use IRS Form 990-BL (2018)

Organizations or trustees should file this form whenever they are responsible for maintaining a Black Lung Benefit Trust or are involved in related transactions. You’d use it when:

1. Operating a Black Lung Benefit Trust: The trust benefits miners or their dependents under section 501(c)(21) and must report all activity annually.
   
   
2. Filing the Initial Excise Tax Return: Certain related persons must report excise taxes from transactions that could disqualify the trust.
   
   
3. Correcting or Late Filing Issues: Trustees who missed their due date must file as soon as possible and may include a reasonable cause explanation if delays resulted from illness, natural disasters, or other serious issues.
   
   
4. Responding to IRS Notices: When the IRS sends a notice requesting missing returns or corrections, the trustee must comply promptly.
   
   
5. Reporting Annual Activity: Even when no excise tax or payment is due, the form ensures the trust remains in good standing with the Internal Revenue Service.

Key Rules or Details for 2018

The 2018 version of IRS Form 990-BL contained specific requirements that trustees and related persons must follow to stay compliant.

1. Filing Requirement: Every Black Lung Benefit Trust and certain related persons were required to file Form 990-BL annually, even if no gross receipts or excise taxes were due.
   
   
2. Electronic Filing: The IRS encouraged electronic filing for 2018 to reduce processing delays, although paper submission remained an acceptable option for some filers.
   
   
3. Due Date: The return was due on the 15th day of the 5th month following the close of the trust’s accounting period, which was generally May 15, 2019, for calendar-year filers.
   
   
4. Penalty Relief: Trustees who missed the filing deadline could request penalty relief by submitting written documentation that established reasonable cause, such as serious illness or natural disasters.
   
   
5. Interest and Penalties: The IRS may assess penalties and charge interest on late filings or unpaid balances unless the trustee provides a valid, reasonable cause explanation.
   
   
6. Recordkeeping: Trustees were required to retain copies of all filed forms, supporting documentation, and payment confirmations for at least three years after the return was filed.

Step-by-Step (High Level)

Trustees filing IRS Form 990-BL (2018) should follow these procedural steps to ensure accuracy and compliance with IRS requirements.

1. Gather Required Information: Before filing, collect financial statements, trust instruments, receipts, and EIN details for the trust and all related persons.
   
   
2. Review the Instructions for Form 990-BL: Read the official IRS instructions for Form 990 carefully to ensure each section is completed accurately and completely.
   
   
3. Enter Trust Information: Provide the trust’s legal name, address, EIN, accounting period, and the names and contact details of all trustees.
   
   
4. Report Financial Data: Record the trust’s total gross receipts, expenditures, and other relevant financial activity for the year with proper documentation.
   
   
5. Complete the Excise Tax Section: Accurately disclose any prohibited transactions that may create excise tax liability for the trust or related persons.
   
   
6. Attach Additional Schedules: Include all schedules, explanations, or documentation required under the IRS instructions to support the reported figures.
   
   
7. File the Return: Submit the completed return electronically or by mail by the applicable due date to avoid penalties or interest assessments.

Common Mistakes and How to Avoid Them

These are frequent filing errors that can lead to penalties, processing delays, or IRS correspondence, along with ways to prevent them.

• Incorrect EIN Entry: Enter the employer identification number exactly as issued by the IRS to ensure proper processing and avoid data mismatches.
  
  
• Missing Trustee Information: Always include trustees' full names and contact details to maintain a complete and valid return record.
  
  
• Filing After the Due Date: File the return by the applicable due date to avoid late filing penalties and interest charges assessed by the IRS.
  
  
• Incomplete Financial Data: Before submission, verify that all income, disbursements, and gross receipts are accurately reported to prevent return rejection.
  
  
• Ignoring IRS Notices: Respond promptly to any IRS notices requesting clarification, missing documentation, or corrections to avoid escalation or penalties.
  
  
• Failing to Request Penalty Relief: When delays result from serious illness, natural disasters, or other reasonable causes, submit a written request for penalty abatement with proper documentation.
  
  
• Not Keeping Copies: Retain copies of all filed returns, payment confirmations, and correspondence for at least three years in case of future audits or inquiries.

What Happens After You File

Once you file IRS Form 990-BL (2018), the Internal Revenue Service reviews the return for completeness, accuracy, and compliance with reporting requirements. Electronic submissions typically receive faster acknowledgment, while mailed forms may take several weeks to process. Trustees can check the filing status through the IRS database or contact customer service if confirmation is not received. 

If the IRS identifies errors or missing information, it will issue a notice requesting clarification or additional documents. Penalties and interest may be assessed if the filing is late or incomplete. Keep all records and proof of filing for at least three years for audit and verification purposes.

FAQs

What is the initial excise tax return under IRS Form 990-BL (2018)?

The initial excise tax return applies when a trust or related person engages in a prohibited transaction under section 4951. This filing ensures the tax return for Black Lung trusts reports any excise tax owed to the Internal Revenue Service.

Who are considered certain related persons for Form 990-BL (2018)?

Certain related persons include individuals or entities connected to the trust participating in financial transactions subject to excise tax rules. They must disclose their involvement and report activity on the same Black Lung benefit trusts tax return.

What are Black Lung Benefit Trusts, and who files this return?

Black lung benefit trusts are special entities that fund medical care and benefits for miners with black lung disease. As part of their annual tax obligation, trustees must file IRS Form 990-BL (2018) to provide accurate financial and operational details.

What is the tax obligation for trustees filing IRS Form 990-BL (2018)?

Trustees must file the form on time to meet their tax obligation and report all income, disbursements, and excise taxes. Filing late may result in penalties unless a valid reason, such as illness or natural disaster, is documented and approved by the IRS.

How can I access the return for Black Lung trusts and related forms?

You can download the official IRS Form 990-BL (2018) PDF file and related instructions directly from the IRS website. Review the information carefully before submission to ensure compliance with current Internal Revenue Service requirements.