Form 8868 (Rev. January 2021) — 2021 Tax Year Checklist
Purpose
Form 8868 provides an automatic 6-month extension of time to file certain tax-exempt organization returns and excise tax returns. This includes Forms 990, 990-EZ, 990-PF, 990-T, 4720, 5227, 6069, 1041-A, and 5330. Organizations must file a separate Form 8868 for each return type requiring an extension.
Step-by-Step Filing Instructions
Step 1: Confirm Filer Eligibility
Verify that your organization qualifies to use Form 8868. This form applies exclusively to tax-exempt organizations, employee benefit plans, and certain trusts. Corporations, partnerships, REMICs, and other entities must use Form 7004 instead.
Step 2: Select the Correct Return Code
Enter only one Return Code (01–15) corresponding to the specific form you need to extend. Each return type requires a separate Form 8868. You cannot request extensions for multiple return types on a single form. Refer to the form instructions to identify the correct code for your return.
Step 3: Complete Organization Identification
Enter your organization’s complete legal name, Employer Identification Number, and current mailing address. If your organization does not have a U.S. office, please check the designated box on the form to ensure proper IRS correspondence routing.
Step 4: Provide Books and Records Contact
Include the name and contact telephone or fax number of the individual who maintains custody of your organization’s books and records. This person must be available to respond to IRS inquiries during the extension period.
Step 5: Enter Group Exemption Information (If Applicable)
If requesting an extension for a group return, enter your four-digit Group Exemption Number. Check the “whole group” box if the extension covers all members, or check the “part of group” box and attach a complete list containing the names and Taxpayer Identification Numbers of each member receiving the extension.
Step 6: Calculate Tax and Payment (Forms 990-PF, 990-T, 4720, or 6069)
For these specific forms, calculate your tentative tax on line 3a and subtract any applicable nonrefundable credits. On line 3b, enter your total credits, including estimated tax payments already made and any overpayment from prior years. Calculate the balance due on line 3c. If payment is required, include it with your extension request.
Step 7: Complete Form 5330 Extension Requirements
If requesting an extension for Form 5330, identify the specific Internal Revenue Code sections imposing the excise tax you’re reporting. Include payment of any tax due and provide a written explanation in Part III stating your reason for requesting the extension.
Step 8: File Extension by Original Due Date
Submit Form 8868 by the original due date of the return you’re extending. For calendar-year filers, Form 990/990-EZ is due May 15 (or the next business day if May 15 falls on a weekend or holiday). Filing by this deadline provides an automatic 6-month extension to November 15.
Step 9: Sign and Date the Form
An authorized representative—typically an officer, manager, or authorized agent—must sign Form 8868 under penalties of perjury. Unsigned forms are considered incomplete and invalid. Electronic signatures are acceptable for e-filed returns, provided the IRS authenticates them as such.
Step 10: Choose Filing Method
Form 8868 may be filed electronically or by paper. Electronic filing is strongly encouraged for faster processing and immediate acknowledgment. If filing by paper, mail the completed form to the Department of the Treasury, Internal Revenue Service Center, Ogden, UT 84201-0045. Note that extension requests for Form 8870 cannot be e-filed and must be submitted on paper.
Key 2021 Tax Year Considerations
Due Dates for Calendar-Year Organizations
Calendar-year exempt organizations filing Form 990 or 990-EZ for the 2020 tax year (filed in 2021) must meet the May 15, 2021, deadline. Since May 15, 2021, fell on Saturday, the actual filing deadline was Monday, May 17, 2021, under standard weekend extension rules—not due to pandemic relief. The IRS did not extend Form 990 filing deadlines in 2021 as it did for individual income tax returns.
Organizations granted a 6-month extension have until November 15, 2021, to file their returns. Form 990-N (e-Postcard) filers cannot request extensions, though late filing carries no monetary penalty.
Group Exemption Filing Procedures
The 2021 instructions clarify requirements for group exemptions. If requesting an extension for only part of a group, you must attach a separate document listing each member organization’s complete legal name and Taxpayer Identification Number. Incomplete or unmarked group lists may cause processing delays or rejection.
Form 8870 Special Requirements
Form 8870 (Information Return for Transfers Associated With Personal Benefit Contracts) cannot be e-filed. Both the form itself and the extension request using Form 8868 must be submitted in paper format only. This applies even when filing extensions for other forms electronically.
Separate Forms Required
You must file a separate Form 8868 for each return type requiring an extension. For example, if your organization needs to extend both Form 990 and Form 990-T, you must submit two separate Form 8868 applications—one for each return. Each form should contain only one Return Code.
Tax Calculation Requirements
Organizations filing Forms 990-PF, 990-T, 4720, or 6069 must calculate tentative tax liability using 2021 tax law provisions. For Form 990-PF filers, apply the excise tax rules under Internal Revenue Code Section 4940. No temporary reductions or suspensions of excise taxes applied to Form 8868 filers during 2021.
Payment and Interest Rules
If you owe tax, payment is due by the original return deadline, even if you file an extension. Extensions grant additional time to file, not additional time to pay. Interest and penalties accrue on unpaid balances from the original due date. Include payment with your Form 8868 or make arrangements through the Electronic Federal Tax Payment System.
Record Retention
Maintain copies of your filed Form 8868, acknowledgment receipts (for e-filed forms), and all supporting documentation. Keep these records with your tax return files for at least three years from the filing date or as required by your organization’s document retention policy.
Common Filing Errors to Avoid
Failing to file a separate form for each return type is the most frequent error. Organizations also commonly miss the original deadline, forget to include required payment, or omit essential contact information. Ensure your Employer Identification Number matches IRS records exactly, as mismatches cause automatic rejections for electronically filed forms.
Double-check that you’ve selected the appropriate Return Code and that all required signature fields are completed. For group exemptions, verify your attachment contains complete information for all members receiving the extension.
After Filing
If you e-file Form 8868, you should receive an acknowledgment within 24–48 hours confirming IRS acceptance. Save this acknowledgment as proof of your timely request for an extension. Paper-filed forms do not receive acknowledgments, so retain evidence of timely mailing, such as certified mail receipts or delivery confirmation.
Once your extension is approved, you have until the extended due date to file your return. The extension does not excuse you from filing requirements—failure to file by the extended deadline may result in penalties and potential revocation of tax-exempt status for organizations that fail to file for three consecutive years.
If circumstances change and you are unable to file by the extended deadline, contact the IRS immediately. Additional extensions beyond the automatic 6-month period are rarely granted and require exceptional circumstances, accompanied by supporting documentation.
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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.
