IRS Form 990-BL (2025): Black Lung Trust Tax Return
What IRS Form 990-BL (2025) Is For
Form 990-BL (Information and Initial Excise Tax Return for Black Lung Benefit Trusts and Certain Related Persons) is no longer available for filing. Beginning with tax year 2021, the form became historical, and section 501(c)(21) black lung benefit trusts must now file Form 990 or Form 990-N (e-Postcard) to meet annual reporting requirements under IRC section 6033 (IRS Publication 557, 2025).
When You’d Use Form 990-BL for 2025 (Late or Amended Filing)
- Not valid for 2025 or later tax years.
- If you receive IRS notices about unfiled pre-2021 returns, file the appropriate historical version of Form 990-BL for those years.
- For 2021 and later years (including 2025), trusts must file Form 990 (or Form 990-N if gross receipts are $50,000 or less).
- Trusts with prohibited expenditures or self-dealing must also file Form 6069 for excise tax reporting.
Key Rules Specific to 2025
- Form 990-BL is discontinued. All 501(c)(21) black lung benefit trusts must use Form 990 rules.
- Form 6069 is required if taxable expenditures or acts of self-dealing occurred (excise taxes under §§ 4951, 4952, 4953).
- Form 990 must be filed electronically.
- Small trusts with ≤ $50,000 gross receipts may qualify for Form 990-N (e-Postcard) instead of the full Form 990.
Step-by-Step (High Level)
- Request IRS transcripts (Form 4506-T) to check for unfiled pre-2021 obligations.
- File Form 990 or 990-N for 2025 (not Form 990-BL).
- File Form 6069 if excise tax applies.
- Attach required schedules for Form 990. (Schedule A of Form 990-BL applies only to pre-2021 amended filings.)
- Submit electronically using an IRS-approved e-file provider.
- Retain records of all filings and supporting documentation for at least 3 years.
Common Mistakes and How to Avoid Them
- ❌ Filing Form 990-BL for 2021 or later years (obsolete).
- ❌ Forgetting to file Form 6069 when excise taxes are triggered.
- ❌ Misusing filing thresholds—Form 990-N is only for trusts with ≤ $50,000 gross receipts.
- ❌ Paper-filing Form 990 instead of filing electronically.
- ❌ Overlooking penalty deadlines—late Form 990 filings trigger $20–$120 per day penalties.
- ❌ Failing to update compliance processes from 990-BL to 990 standards.
What Happens After You File
- The IRS typically processes Form 990 filings within several months.
- You’ll receive acknowledgment of electronic filing.
- If penalties are assessed, you may receive IRS notices with payment options, including Form 9465 (Installment Agreement Request).
- For pre-2021 Form 990-BL filings, processing may take longer since these are historical returns subject to additional review.
- You have appeal rights if you disagree with penalty assessments or other determinations.
FAQs
Q: Can I file Form 990-BL for 2025?
No. Form 990-BL has been discontinued since tax year 2021. File Form 990 or Form 990-N instead.
Q: What penalties apply for late Form 990 filing?
$20/day up to $12,000 (or 5% of gross receipts) for small organizations. Large organizations face $120/day up to $60,000 (IRS Pub. 557, 2025).
Q: Do I need transcripts before filing?
Yes. Transcripts help confirm whether historical 990-BL returns are still missing and show current 990 obligations.
Q: What if I received IRS notices about Form 990-BL for 2025?
Contact the IRS. Notices likely refer to unfiled pre-2021 years. For 2021 and later, file Form 990 instead.
Q: Can penalties be abated?
Yes. Reasonable cause (illness, natural disasters, reliance on bad advice, etc.) may qualify for penalty relief.
Q: Should I amend state returns too?
Check state rules. Many states require amended returns when federal exempt filings are corrected or submitted late.
Q: Is there a refund statute of limitations?
Yes. Refund claims generally must be filed within 3 years of the return due date or 2 years from payment, whichever is later.
