Form 8868 (Rev. January 2018)—2018 Tax Year Checklist
Purpose
Form 8868 requests an automatic 6-month extension of time to file exempt organization returns, including Forms 990, 990-EZ, 990-PF, 990-T, 4720, 5330, 6069, 1041-A, and 5227. The 2018 revision includes expanded guidance on Form 990-T filing classifications for trusts and updated instructions for address formatting and Group Return filers.
Filing Steps for 2018
Step 1: Determine Your Organization’s Tax Year and Return Code
Verify your exempt organization’s tax year-end date and identify the correct return code from the Form 8868 instructions. For Form 990-T filers, the 2018 instructions require specific trust classifications: Section 401(a) or 408(a) trusts use Return Code 05, while other trusts use Return Code 06. Corporate filers use Return Code 07, and governmental entities use Return Code 15. These distinctions became mandatory starting with the 2018 tax year.
Step 2: Confirm Valid Taxpayer Identification Number
Ensure your organization has a current and valid Employer Identification Number (EIN) or Taxpayer Identification Number (TIN) before filing. Extension applications submitted without proper taxpayer identification matching IRS records will not receive approval under the 2018 IRS verification requirements.
Step 3: Complete Part I with Required Identification Information
Enter the filer’s legal name, complete mailing address, TIN, and appropriate return code in Part I. For foreign addresses, include the full country name and use the foreign country’s postal code format if applicable. Do not use U.S. ZIP codes for foreign addresses. The 2018 instructions clarified these foreign address formatting requirements to ensure consistent international mail delivery.
Step 4: Calculate the Original Return Due Date
Determine your original return due date based on your organization’s tax year. For calendar year filers (with a year-end date of December 31, 2018), Forms 990 and 990-PF are due on May 15, 2019. For non-calendar year filers, the due date is the 15th day of the 5th month following the end of your tax year, as established under IRC Section 6072. Mark this date clearly when requesting your extension.
Step 5: Complete Part II for Automatic Extension Requests
Suppose you are requesting an automatic 6-month extension for Forms 990, 990-EZ, 990-PF, 990-T, 4720, or 6069; complete Part II of Form 8868. No signature is required for Part II automatic extension requests. The extension is granted automatically upon timely filing of a properly completed form.
Step 6: Calculate and Report Tax Liability (If Applicable)
If filing for Form 990-PF, 990-T, 4720, or 6069 that requires tax payment, complete lines 3a through 3c. Enter your tentative tax liability on line 3a, subtract any nonrefundable credits on line 3b, and calculate the balance due on line 3c. The 2018 instructions specify that estimated tax payments made during the year and any prior-year overpayments applied as credits must be used to reduce line 3a before determining the final balance due.
Step 7: Apply 2018 Corporate Tax Rate for Form 990-T
For corporate filers of Form 990-T, calculate tentative tax using the flat 21% corporate tax rate established by the Tax Cuts and Jobs Act (TCJA). This represents the first year under the new rate structure, replacing the previous graduated corporate tax rates that applied through 2017. Fiscal year corporations with tax years spanning January 1, 2018, must use a blended tax rate calculation as specified in IRS Notice 2018-38.
Step 8: Complete Group Return Information (If Applicable)
For Group Return filers, enter the four-digit Group Exemption Number (GEN) in the designated field on Form 8868. The 2018 instructions added explicit requirements for GEN entry that were not specified in prior versions. If requesting a partial-group extension, please attach a schedule that lists each subordinate organization’s name and TIN. Full-group extensions require only one checkbox indication and do not need individual member schedules.
Step 9: Complete Part III for Form 5330 Extensions Only
Suppose you are requesting an extension to file Form 5330 (Return of Excise Taxes Related to Employee Benefit Plans); complete Part III of Form 8868. Identify all applicable IRC Code sections imposing the excise tax and include full payment of the tax liability with your extension application. The extension provides up to 6 months beyond the normal Form 5330 due date, contingent upon demonstrating sufficient cause for needing additional time to file.
Step 10: Sign and Date Part III (Form 5330 Requests Only)
Part III requests for Form 5330 extensions require a signature under penalties of perjury by an authorized officer or preparer. This signature requirement applies only to Part III; Part II automatic extension requests do not require signatures. Ensure the signature is properly executed according to IRS paper-filing requirements if submitting by mail.
Step 11: Submit Payment with Extension Request (If Required)
If your extension request includes tax liability (line 3c balance due or Form 5330 tax), submit payment with Form 8868. Payment methods include check, money order, or electronic payment through the Electronic Federal Tax Payment System (EFTPS). Make checks payable to “United States Treasury” and include your EIN and “Form 8868” notation on the payment.
Step 12: File Form 8868 by the Original Due Date
Submit your completed Form 8868 on or before your organization’s original return due date to receive the 6-month extension. Electronic filing (e-file) is available for most forms and provides immediate confirmation of acceptance. Paper filers should mail Form 8868 to the Department of the Treasury, Internal Revenue Service Center, Ogden, UT 84201-0045. Retain confirmation of filing for your records.
Key 2018 Tax Year Updates
Return Code Clarification for Form 990-T Trusts
The 2018 instructions introduced a new classification system for Form 990-T filers, distinguishing between types of trusts. Trusts described in IRC Section 401(a) (qualified pension, profit-sharing, and stock bonus plans) or Section 408(a) (individual retirement accounts) must use Return Code 05. All other trusts filing Form 990-T use Return Code 06. This distinction did not exist in prior-year instructions and represents a material change for 2018 compliance.
ACA Employer Shared Responsibility Provisions Continue
Organizations filing Form 990-T remain subject to ACA employer shared responsibility taxes under IRC Section 4980H. These provisions, commonly known as the employer mandate or “pay or play” rules, continue to apply beyond 2018 for applicable large employers. The employer shared responsibility provisions should not be confused with the individual mandate penalty under IRC Section 5000A, which was reduced to zero beginning in 2019.
TCJA Corporate Tax Rate Implementation
The 2018 tax year marks the first full year under the TCJA’s flat 21% corporate tax rate for Form 990-T corporate filers. This represents a significant reduction from the previous graduated corporate tax structure, which included rates of up to 35%. Organizations must apply IRC Section 11, as amended by the TCJA, when calculating the tentative tax liability on line 3a for corporate filers.
Foreign Address Format Standardization
The 2018 instructions provide specific guidance on foreign address formatting, clarifying previous ambiguities. Organizations with foreign addresses must include the complete country name and use the appropriate foreign postal code format. U.S. ZIP codes should not be used for foreign addresses. This standardization ensures proper mail delivery and consistent IRS record-keeping for international exempt organizations.
Group Exemption Number Entry Requirements
Form 8868 instructions for 2018 added explicit requirements for Group Return filers to enter their four-digit Group Exemption Number (GEN) in a dedicated field. Earlier instruction versions lacked this level of specificity regarding the placement and documentation of GEN. This enhancement streamlines processing for central organizations filing on behalf of subordinate organizations under group exemption letters.
Important Reminders
Requesting an extension of time to file does not extend the time to pay any tax due. Organizations must estimate their tax liability and submit payment with Form 8868 to avoid penalties and interest charges. The automatic 6-month extension applies only to filing deadlines, not payment deadlines.
Organizations that fail to file required returns by the extended due date may face automatic revocation of tax-exempt status or significant penalties. Maintain careful records of extension filing confirmations and ensure timely submission of the final return within the extended period.
For organizations with unique circumstances or questions about specific extension requirements, consult IRS Publication 557 (Tax-Exempt Status for Your Organization) or contact the IRS Tax Exempt and Government Entities division for technical assistance.
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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.
