What IRS Form 990-BL (2023) Is For

IRS Form 990-BL (2023) was historically used by Black Lung Benefit Trusts under section 501(c)(21) to report income, expenses, and related excise tax return details. It was the initial excise tax return for organizations managing Black Lung compensation funds. Beginning in 2021, the IRS discontinued Form 990-BL, requiring these trusts to file Form 990 or Form 990-N instead. Excise taxes once reported on Form 990-BL are now filed using Form 6069. For the most current filing instructions and updates, visit the IRS website to check official guidance.

When You’d Use Form 990-BL for 2023

IRS Form 990-BL (2023) applies only to late or amended filings for tax years 2020 or earlier. This means the form should not be used for current filings. However, some organizations may still need to submit or correct it if they discover past filing issues or receive an IRS notice.

You may need to file Form 990-BL for one of the following reasons:

• IRS delinquency or correction notices: The IRS may notify your organization that a previous excise tax return or income tax report was not filed or contained errors.
  
  
• Audit findings: An IRS audit may reveal missing or inaccurate tax returns from earlier years that require correction.
  
  
• Unfiled prior-year returns: A Black Lung Benefit Trust may determine that older returns were never submitted or were filed incorrectly and need to be amended.

All section 501(c)(21) organizations must now file Form 990 or Form 990-N for tax years 2021 and beyond. Following the latest IRS instructions ensures compliance and reduces the risk of penalties.

Key Rules and Details for Tax Year 2023

For tax year 2023, IRS Form 990-BL is no longer valid for filing. Section 501(c)(21): Black Lung Benefit Trusts must now submit Form 990, or Form 990-N, to meet annual reporting obligations. Using the outdated form may delay processing or cause penalties.

Key rules and details include:

• Form 990-BL is obsolete and may only be used for late or amended filings for 2020 or earlier tax years.
  
  
• Excise taxes under sections 4951–4953 must now be reported on Form 6069 instead of Form 990-BL.
  
  
• Section 501(c)(21) organizations must use Form 990 or Form 990-N for the 2021 through 2023 tax years.
  
  
• Failure to file for three consecutive years can lead to automatic loss of exempt status.
  
  
• Reviewing their IRS account can help filers verify prior returns, confirm their information, and seek clarification from the IRS if necessary.

Step-by-Step (High Level)

The steps below outline how to correctly file or amend IRS Form 990-BL for older tax years. Follow each one carefully to ensure accuracy and compliance.

1. Confirm the correct year: Verify whether your filing applies to 2020 or an earlier year. Use the correct version of Form 990-BL for older filings and Form 990 or Form 990-N for current years.
   
   
2. Verify prior filings: Review your IRS account transcripts to see what returns are on file and whether any penalties or missing items appear.
   
   
3. Gather records: Collect trust documents, financial statements, trustee details, and excise tax data needed for Schedule A.
   
   
4. Complete the correct form version: Ensure you accurately complete the appropriate Form 990-BL and Schedule A, verifying all entries for consistency.
   
   
5. Review current IRS guidance: Visit IRS.gov to confirm the latest filing instructions and submission details before mailing.
   
   
6. Submit and retain copies: Mail your signed form to the IRS Service Center in Kansas City, MO 64999, and keep copies of all records for compliance and public inspection.

Common Mistakes and How to Avoid Them

Even minor oversights can cause significant problems when filing older versions of IRS Form 990-BL. Taking a few extra minutes to review details and IRS instructions can save time, money, and frustration later.

• Using the wrong form: Some organizations still file Form 990-BL instead of Form 990 or 990-N for newer tax years. Always double-check which version applies before you submit.
  
  
• Forgetting attachments: Schedule A is often missed when excise taxes apply, leaving the return incomplete. Ensure you review all the required schedules listed in the instructions on the forms.
  
  
• Leaving blanks or errors: Missing trustee names or details of disqualified individuals can lead to rejection. Go line by line to make sure nothing is overlooked.
  
  
• Skipping the signature: An unsigned return isn’t valid. Be sure an authorized officer signs and dates the form.
  
  
• Not keeping records: You’re required to keep copies for public inspection. Store your filed forms and backup documents safely.

Before submitting, visit IRS.gov to confirm the latest form version and ensure the secure site connection (look for the padlock icon).

What Happens After You File

After submitting IRS Form 990-BL, the IRS reviews your return for accuracy and completeness. Processing can take time, especially for older filings. The agency will send a notice explaining the necessary corrections and potential penalties if it discovers missing details or errors. Late submissions may lead to daily charges under section 6652(c)—$20 per day for smaller organizations and $105 for larger ones, with maximum penalties ranging from $10,500 to $53,000.

Once your return is accepted, it becomes part of the public record. You can access it on the IRS website using any operating device. To prepare for future filings, review your financial records, track money used for trust operations, and click to confirm the page's last reviewed date on the Form 990-BL page to ensure you follow the most current filing instructions.

Frequently Asked Questions (FAQs)

What is the tax deadline for filing an excise tax return with IRS Form 990-BL?

The IRS discontinued Form 990-BL after 2020, so no current tax deadline applies. It may only be used for late or amended filings from earlier years.

What penalties apply for missing the tax deadline for an excise tax return?

Late filings can result in daily penalties under section 6652(c). The IRS charges $20 per day for smaller trusts and $105 for larger ones, with maximum penalties between $10,500 and $53,000.

How does income tax reporting affect Black Lung Benefit Trust filings?

Trust administrators should review IRS transcripts to confirm earlier submissions and ensure proper income tax reporting. This prevents duplicate filings and keeps all records consistent.

Can I e-file a refund request for an overpaid excise tax return?

Yes, refunds for overpaid excise taxes can be claimed within the statute of limitations. Filers may submit Form 843 electronically or by mail, including all supporting documentation.

Where can I verify the IRS’s latest update on Form 990-BL guidance?

Visit the IRS website and check the “last reviewed” date at the bottom of the Form 990-BL page for the most recent update.