Form 990-BL Checklist for Tax Year 2020
Information and Initial Excise Tax Return for Black Lung Benefit Trusts
Form 990-BL remained the required reporting vehicle for Section 501(c)(21) black lung benefit trusts in 2020. No stimulus reconciliation, shared responsibility payments, or Tax Cuts and Jobs Act modifications apply to this form type for the 2020 tax year. The 2020 instructions maintain unchanged filing deadlines, penalty structures, and asset-reporting thresholds from prior years, with no redesigned sections affecting line-item calculations.
Form Type Governance
Section 501(c)(21) trusts are restricted from filing Form 990-EZ. Form 990-BL is the exclusive reporting form for annual information return requirements under section 6033. Trusts typically have gross receipts of $50,000 or less and may file Form 990-N (electronic notice) instead of Form 990-BL, unless they are liable for initial taxes under sections 4951 or 4952.
Disqualified persons as defined in section 4951(e)(4) for black lung benefit trusts include contributors to the trust; trustees; owners of more than 10 percent of voting power or profits or beneficial interest in a contributor entity; officers or directors or employees of contributors; family members, including spouses, ancestors, lineal descendants, and their spouses; and controlled entities with more than 35 percent ownership. These individuals remain subject to excise tax reporting on Schedule A if they engage in self-dealing or incur taxable expenditures.
No alternative credits, deductions, or IRC section 4960 compensation excise taxes apply to black lung benefit trusts under this form.
2020 Line-Item Clarifications from Prior Years
The 2020 instructions clarified several reporting areas without substantive changes to form structure. The Identification Area now explicitly instructs filers to indicate beginning and ending dates when filing for a short period rather than a full tax year.
Part I, Line 1 instructions provide detailed clarification that contributions must be in cash or property of specific types permitted under section 501(c)(21)(D)(ii), including public debt securities of the United States, obligations of state or local governments not in default as to principal or interest, and time or demand deposits in banks or insured credit unions.
Part II balance sheet requirements emphasize the reconciliation requirement for Line 21 total liabilities and net assets. Line 21 must equal the Line 18 total assets for both the beginning and end of the year. This mathematical verification is essential for return acceptance.
Part III questionnaire instructions clarify notification requirements. If Line 23 indicates self-dealing occurred (answering Yes to any of items 23a(1) through 23a(5)) and correction did not happen (answering No to 23b), the trust must notify each self-dealer and trustee of their requirement to file returns and pay applicable taxes. The trust must also complete Part I, Section B of Schedule A, omitting only column (h).
Ten Mandatory Steps for 2020 Form 990-BL Completion
Step 1: Establish Accounting Period and Filing Deadline
Determine whether the trust operates on a calendar year or a fiscal year basis. Enter the beginning and ending dates in the Identification Area of Form 990-BL. If filing for a short period, clearly indicate the specific dates of the period.
The filing deadline is the 15th day of the 5th month following the close of the tax year. For calendar-year trusts, this means the deadline is May 15 of the year following the tax year. Suppose the date falls on a Saturday, Sunday, or a legal holiday; file on the next business day. You may request an extension by filing Form 8868.
Step 2: Verify Trust Qualifies as Section 501(c)(21) Entity
Confirm that the trust is organized in the United States under a written instrument. Oral trusts are insufficient even if valid under state law. The trust instrument must contain no provision for the reversion of assets to the coal mine operator, except for the equitable recovery of excess contributions.
Asset terms must restrict use to purposes specified in IRC Section 501(c)(3)(B). The trust must be established exclusively to provide black lung benefits required under federal or state law, as well as related medical benefits, insurance premiums, administrative costs, and litigation expenses.
Step 3: Complete the Identification Area and Signature Block
Enter the black lung benefit trust name, address, and employer identification number. Identify the filer type by checking the appropriate box: Trust if filing as an information return, Trustee if liable for section 4951 or 4952 tax, or Disqualified person if liable only for section 4951 tax.
The authorized trustee or trustees must sign the return. If a paid preparer completed the return, that preparer must also sign, enter their tax identification number, and provide a copy to the organization.
Step 4: Gather and Record Part I Revenue and Expense Data
Document Line 1 contributions from the coal mine operator under section 192. These contributions must be made in cash or eligible property, including public debt securities, state or local government obligations that are not in default, or time- and demand-deposits in insured institutions.
Record Lines 2a through 2d for investment income, including interest on government securities and insured deposits, dividends, and net gains or losses from asset sales. Document Line 4 amounts contributed to the Federal Black Lung Disability Trust Fund, Line 5 insurance payments covering specified liabilities, and Line 6 payments to miners or beneficiaries.
Complete Lines 7 through 9 for expenses, including trustee compensation, employee wages and salaries, and administrative costs such as legal, accounting, and actuarial fees.
Step 5: Complete Part II Balance Sheet
Complete all asset lines for cash, savings, receivables, loans, investments in publicly traded and other securities, land and buildings, equipment, and other assets. Calculate total assets on Line 18 for both the beginning and the end of the year.
Complete all liability lines, including accounts payable, accrued expenses, grants payable, deferred revenue, and other liabilities. Enter only actual liabilities as of the first and last days of the tax year. Do not include contested black lung claims, present value of future approved claims, or estimated liability for future claims.
Line 21 must show total liabilities and net assets equal to Line 18 total assets for both the beginning and the end of the year. This reconciliation is mandatory for return acceptance.
Step 6: Answer Part III Questionnaire on Self-Dealing and Taxable Expenditures
Answer Line 23 questions about whether the trust directly or indirectly engages in the sale, exchange, or leasing of property with disqualified persons, lending of money or credit extension, furnishing of goods or services or facilities, payment of compensation or expense reimbursement, or transfers or use of trust income or assets for the benefit of disqualified persons.
If any of items 23a(1) through 23a(5) is answered Yes and item 23b is answered No, indicating the act was not corrected, notify each self-dealer and trustee of their filing and tax payment obligations. Complete Schedule A Part I Section B, omitting only column (h), and Schedule A Part II.
Step 7: Prepare Schedule A if Initial Taxes Are Imposed
If Line 23 or Line 24 indicates self-dealing or taxable expenditures occurred, attach completed Schedule A. Part I, Section A, lists acts of self-dealing with dates, descriptions, disqualified person names, trustee names, amounts involved, and initial tax calculations.
The initial tax is 10 percent on each disqualified person and 2.5 percent on each trustee per section 4951 for each year or part of a year in the taxable period. Part I, Section B, lists taxable expenditures with amount, date paid or incurred, recipient information, description, and purposes. The initial tax is 10 percent on the trust’s value under section 4952, and 2.5 percent on trustees who knowingly agree to the expenditure.
Step 8: Calculate and Report Excise Taxes in Schedule A Part II
Summarize the section 4951 tax on disqualified individuals on Line 1 and the section 4951 tax on trustees on Line 2. Summarize the section 4952 tax on the trust on Line 3 and the section 4952 tax on trustees on Line 4. Enter total tax due on Line 5.
If no tax is due under section 4951 or 4952, do not file Schedule A. Multiple liable individuals may prorate the tax among themselves. The IRS may assess a deficiency against any liable person if the total payment is insufficient.
Step 9: Complete Part IV Contributors Section
For returns filed for tax years ending on or after December 31, 2018, Form 990-BL filers are no longer required to report names and addresses of individuals who contributed $5,000 or more during the tax year. Enter “N/A” on line 1 of Part IV for each such contribution.
Organizations must continue to collect the names and addresses of contributors, maintain this information in their records and books, and make it available to the IRS upon request. Part IV is not open for public inspection.
Step 10: Sign, Verify Assembly, and File the Return
Ensure that Form 990-BL is signed by the authorized trustee and the paid preparer, if applicable. Verify that all required line items, including Parts I, II, and III, are completed at a minimum. Schedule A should be attached only if tax is due.
Confirm that all monetary amounts reflect only liabilities due or accrued as of year-end, excluding contested or future estimated claims. File the paper return by the 15th day of the 5th month following the close of the tax year. Mail to Internal Revenue Service Center, Kansas City, MO 64999. Electronic filing is not available for Form 990-BL.
Penalties and Compliance
Organizations that fail to file returns in a timely, accurate, and complete manner face penalties of $20 per day for small organizations or $105 per day for large organizations with gross receipts exceeding $1,067,000. The maximum penalty is the smaller of $10,500 for small organizations or $53,000 for large organizations, or 5 percent of gross receipts.
Additional penalties apply for failure to comply with public inspection requirements and willful failure to file. These amounts are subject to annual inflation adjustments.
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 are not open to public inspection and should be clearly marked as such.
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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.
