2017 Form 990-BL: IRS-Accurate Tax Year and Form-Specific Checklist
Information and Initial Excise Tax Return for Black Lung Benefit Trusts
Form 990-BL for 2017 serves exclusively section 501(c)(21) black lung benefit trusts. No other organization type may file this form. The 2017 instructions contain no redesigns, restructures, or new provisions compared to prior years, as the form remained standardized for trusts reporting under the Black Lung Benefits Revenue Act of 1977. ACA shared responsibility payment reporting does not apply to Form 990-BL.
Form 990-BL-Specific Restrictions
Only trustees of trusts that are exempt under section 501(a) and described in section 501(c)(21) are permitted to file this form. Nonexempt charitable trusts and all other entity types are prohibited from using Form 990-BL.
Schedule A (Form 990-BL) must be attached only if the trust is liable for initial taxes under sections 4951 (self-dealing) or 4952 (taxable expenditures) during the tax year. If no taxes are due under these sections, do not file Schedule A with your return.
Ten-Step Filing Checklist for Form 990-BL, Tax Year 2017
Step 1: Determine Filing Obligation
File Form 990-BL only if the trust is exempt under section 501(a) and described in section 501(c)(21). If the trust has typically gross receipts of $50,000 or less per tax year, it may file Form 990-N (Electronic Notice) instead.
However, trusts with gross receipts of $50,000 or less must still file Form 990-BL if they are liable for initial taxes under sections 4951 or 4952. The Form 990-N option is not available when excise tax liability exists.
Step 2: Establish the Tax Year Period
Use the trust’s established annual accounting period for reporting. If no accounting period has been established, use the calendar year (January 1 through December 31, 2017).
The 2017 return must report financial data for the tax year ended in 2017 or, if a fiscal year began in 2017 and ended in 2018, for the tax year ended in 2018. Clearly indicate the period covered on the return’s identification section.
Step 3: Gather Revenue and Contribution Documentation
Collect written evidence of all contributions received from the coal mine operator under section 192 for line 1. Contributions must be in the form of cash or property permitted for trust investment, such as U.S. public debt securities, state or local government obligations in good standing, and bank or credit union deposits.
Compile documentation for amounts received from other sources for line 2, amounts paid to the Federal Black Lung Disability Trust Fund for line 4, insurance premiums for line 5, and all payments to miners or beneficiaries for line 6.
Step 4: Compile Expense Documentation
Gather receipts, invoices, and records of compensation paid to all trustees (line 7), salaries and wages for all other employees (line 8), and administrative expenses, including legal, accounting, actuarial, and trustee fees (line 9).
Prepare a schedule listing by type and amount all allowable deductions not deductible elsewhere on Form 990-BL for line 10. Ensure that all expense documentation is complete and categorized adequately before proceeding to Part I.
Step 5: Calculate Balance Sheet Amounts
Complete Part II (Balance Sheets) based on the accounting method regularly used by the trust. List cash (line 13), savings and interest-bearing accounts (line 14), and all other assets at fair market value (lines 15 through 17).
Calculate total assets (line 18), total liabilities (line 19), and net assets (line 20). Verify that lines 19 and 20 sum to line 18 for both the beginning of the year and the end of the year columns. Include only actual liabilities of the trust, not contested claims or estimated future liabilities.
Step 6: Prepare Schedule A if Initial Taxes Are Due
File Schedule A (Form 990-BL) only if the trust had acts of self-dealing under section 4951 or taxable expenditures under section 4952 during the tax year.
For section 4951 self-dealing, the initial tax is 10 percent per disqualified person and 2½ percent per trustee for each year or part thereof in the taxable period. For section 4952 taxable expenditures, the initial tax is 10 percent of the expenditure amount.
Complete all required sections of Schedule A, entering the information in the proper columns. This schedule is not open to public inspection and should be clearly marked as such.
Step 7: Complete Officer, Director, and Trustee Information
List the name, address, and title of every officer, director, trustee, and person with similar responsibilities or powers in Part III. Report all forms of compensation, including salary, expense allowances, contributions to employee benefit plans, and other compensation for each person.
Show the amount for each category in the appropriate columns. If no compensation was paid to a listed person, enter zero in columns ©, (d), and (e). Provide a numerical estimate of average hours per week devoted to each position in column (b).
Step 8: Complete the Contributors Section
List the name and address of every person or entity whose contributions during the tax year totaled $5,000 or more in Part IV. In determining whether a person has contributed $5,000 or more, include only contributions of $1,000 or more from such person.
Part IV is not open to public inspection and should be clearly marked. If the trust receives excess contributions beyond what the contributor can deduct under Section 192, the contributor may be required to file Form 6069 and pay an excise tax under Section 4953.
Step 9: Sign and Date Form 990-BL
The authorized trustee or trustees must sign the return. If a paid preparer (not an employee of the trust) prepared the return, the preparer must sign in the space provided, enter the date, print the preparer’s name and address, and include the preparer’s tax identification number (PTIN).
The trustee should also select the “Paid Preparer Authorization” box to indicate whether the IRS may contact the paid preparer to discuss the return. This authorization is limited to questions about return processing and does not extend to representation before the IRS.
Step 10: File by the Deadline
File the completed Form 990-BL (and Schedule A if taxes are due) by the 15th day of the fifth month following the close of the trust’s tax year. For a calendar year trust, the due date is May 15, 2018.
If May 15 falls on a Saturday, Sunday, or federal holiday, the due date is the following business day—file Form 990-BL by paper mail to the address specified in the instructions. Electronic filing is not available for Form 990-BL.
You may request an extension of time to file by submitting Form 8868, Application for Automatic Extension of Time to File an Exempt Organization Return. Use private delivery services designated by the IRS if you wish to meet the timely mailing as a timely filing rule.
2017 Form 990-BL: Schedule and Line-Level Changes
No scheduled changes, removals, or redesigns were implemented for Form 990-BL in the 2017 tax year instructions. The form and all line items remained structurally identical to those of prior years, as codified under the Black Lung Benefits Revenue Act of 1977.
The same percentage rates, definitions, and disqualified person rules were retained for all liability calculations related to section 4951 self-dealing taxes and section 4952 taxable expenditure taxes. The instructions continued to provide the same guidance on correction requirements, taxable periods, and amounts involved.
Public Inspection Requirements
Form 990-BL must be made available for public inspection for three years beginning with the due date or actual filing date, whichever is later. However, Part IV (Statement With Respect to Contributors) and Schedule A (Form 990-BL) are not open to public inspection.
The trust must permit inspection during regular business hours at its principal office and at each regional or district office. It must also provide copies upon request, either on the same business day or within specified time frames, depending on the circumstances.
Filing Location and Methods
File Form 990-BL at Internal Revenue Service, 201 W. River Center Blvd., Stop 312, TE/GE, Covington, KY 41011. Do not send the return to any other IRS address.
Form 990-BL cannot be filed electronically for the 2017 tax year. All returns must be filed on paper. Use the U.S. Postal Service or designated private delivery services to meet the timely filing requirements.
Penalties and Compliance
Organizations that fail to file their returns in a timely, accurate, and complete manner face penalties of $20 per day for small organizations or $100 per day for large organizations (those with gross receipts exceeding $1,028,500). The maximum penalty is the smaller of $10,000 for small organizations ($51,000 for large organizations) or 5 percent of gross receipts.
Additional penalties apply for failure to comply with public inspection requirements, willful failure to file, and filing fraudulent returns. These penalties underscore the importance of meticulous preparation and timely filing of Form 990-BL, along with all required schedules.
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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.
