Form 8868 (Rev. January 2020) Checklist
Purpose and 2020 Updates
Form 8868 requests an automatic 6-month extension of time to file exempt organization returns.
The 2020 revision introduced significant changes to streamline the filing process. The form transitioned from a two-step process (initial 3-month automatic extension plus optional 3-month additional request) to a single unified 6-month automatic extension.
This eliminates the need for organizations to file twice to obtain the full extension period. Organizations now receive a complete 6-month extension upon proper completion, timely filing, and payment of any outstanding balance—no separate subsequent request is required.
Step-by-Step Completion Guide
Step 1: Select the Correct Return Code
Enter the Return Code matching your entity type in the designated box. Each form covers only one return type—file separate forms for multiple returns. Use Return Code 05 if your filing deadline is the 15th day of the 4th month (April 15 for the calendar year). Use Return Code 06 if your filing deadline is the 15th day of the 5th month (May 15 for the calendar year). This distinction prevents mismatches in trust classification.
Step 2: Enter Organization Name and Taxpayer Identification Number
Provide your complete legal name and TIN exactly as they appear on previous filings. All filers—exempt organizations, corporations, and individuals—must provide their taxpayer identification number without exception. Missing or incorrect TINs will delay processing.
Step 3: Provide Complete Mailing Address
Include suite, room, or unit numbers after the street address. If the Post Office does not deliver to your street address, provide your P.O. box number. If your address has changed since filing your last return, you must file Form 8822 (Change of Address) separately. Simply showing a new address on Form 8868 will not update your IRS records.
Step 4: Confirm One Return Code Per Form
File a separate Form 8868 for each return type requiring an extension. The form does not permit blanket multi-return requests. Each entity owing tax must file its own Form 886; do not combine multiple organizations on a single form.
Step 5: Enter the Extended Due Date on Line 1
Calculate your extended due date, which cannot exceed 6 months from the original filing deadline. Enter this date on Line 1 along with your tax year information.
Example: If your original due date is May 15, your extended due date is November 15. Organizations are entitled to only one 6-month extension per tax year.
Step 6: Complete Line 2 If Applicable
Check the appropriate box if filing an initial return, final return, or requesting a change in accounting period.
Change in Accounting Period: If you check this box, you must have filed Form 1128 or meet specified conditions under IRS regulations. Refer to Publication 538 (Accounting Periods and Methods) for tax year change approval requirements.
Step 7: Calculate Tentative Tax on Line 3a
Enter your tentative tax liability, reduced by nonrefundable credits only. Do not deduct refundable credits on this line—they belong on Line 3b.
If you expect no tax liability, enter “-0-” on Line 3a. All filers, including tax-exempt organizations, must complete this line, as they are expected to have zero liability.
Step 8: Enter Refundable Credits and Payments on Line 3b
Report all refundable credits and estimated tax payments made during the year. Include any prior year overpayment you elected to apply as a credit to the current year.
Important Distinction: Nonrefundable credits reduce Line 3a. Refundable credits appear on Line 3b.
Step 9: Compute Balance Due on Line 3c
Subtract Line 3b from Line 3a to determine your balance due. If Line 3b exceeds Line 3a, enter zero. The extension grants additional time to file your return, not extra time to pay taxes owed.
You must pay the full balance due by the original return deadline to avoid interest and penalties, even if you have an approved extension.
Step 10: Arrange Payment Through EFTPS or Authorized Third Party
All tax-exempt organizations are required to make federal tax deposits electronically, with limited exceptions.
Electronic Payment Methods:
- Electronic Federal Tax Payment System (EFTPS) – free IRS service
- ACH Credit through your financial institution
- Electronic Funds Withdrawal when e-filing
- Authorized tax professional, payroll service, or third party
Small Foundation Exception: Private foundations may submit payment by check or money order only if they meet all three conditions: (1) the section 4940 tax on Form 990-PF Part VI line 5 is less than $500, (2) the Form 8868 Line 3a amount is less than $500, and (3) the payment represents the full balance due.
Step 11: File by the Return Due Date
Submit Form 8868 on or before your return’s original due date. Late extension requests are not processed.
Filing Options:
- Electronic filing (e-file) through IRS-approved providers
- Paper filing mailed to: Department of the Treasury, Internal Revenue Service Center, Ogden, UT 84201-0045
Paper Filing Note: Submit only the original form—copies are not required.
Step 12: Keep Form 8868 Separate from Your Return
Do not attach Form 8868 to your exempt organization return when you file it later. The extension application is processed separately and should not be included with the actual return.
Important 2020 Form Changes
Single 6-Month Automatic Extension
The most significant change eliminates the previous two-step process. Organizations had previously filed for an initial 3-month extension and then submitted a second request for an additional 3 months. Now, properly completed forms automatically grant the full 6-month extension in one submission.
No Signature Required
Form 8868 does not require a signature, streamlining the filing process. This distinguishes it from the actual tax return, which must be signed and submitted. Simply complete the form accurately and submit it by the deadline.
Electronic Filing Encouraged
Electronic filing remains available for all returns listed on Form 8868 except Form 8870. E-filing provides immediate confirmation, faster processing, and reduces errors through built-in validation checks.
Form 8870 Exception
Applications for extension of time to file Form 8870 (Information Return for Transfers Associated With Certain Personal Benefit Contracts) must be submitted in paper format. Electronic filing is not available for this particular form.
Group Return Partial Extension Requirements
Central organizations filing group returns may request extensions for all group members or select members only. Attach a schedule listing the name, complete address, and taxpayer identification number of each organization included in the extension request if extending for a partial group only.
Payment Options Clarified
The 2020 instructions emphasize electronic payment requirements for tax-exempt organizations while clearly defining the narrow exception for small private foundations with investment income tax under $500. Organizations not qualifying for the small foundation exception cannot submit check or money order payments—they must use electronic deposit methods.
Critical Warnings and Reminders
Automatic Revocation of Tax-Exempt Status
Organizations failing to file required returns for three consecutive years automatically lose their tax-exempt status. The revocation becomes effective as of the original filing due date of the third missed return.
- Example: If an organization fails to file for tax years 2020, 2021, and 2022, and the 2022 return deadline (including any extension) passes, tax-exempt status is revoked effective on the original 2022 filing deadline.
- Reinstatement: The IRS cannot undo a proper automatic revocation. Organizations must reapply for tax-exempt status even if they were not originally required to file an exemption application. Visit the IRS website for detailed reinstatement procedures.
Extension Does Not Extend Time to Pay
Requesting and receiving a filing extension does not postpone your tax payment deadline. Interest accrues on unpaid balances from the original due date until the balance is paid in full.
Late payment penalties may also apply. To avoid penalties: Ensure Line 3a (tentative tax) is at least 90% of the final tax shown on your return, and pay any remaining balance by the extended due date.
Interest and Penalties Apply to Late Payments
Interest charges begin on any unpaid tax from the return’s original due date, regardless of approved extensions or reasonable cause claims.
- Late payment penalty: Generally 0.5% of the unpaid tax per month or partial month, up to 25% maximum. The penalty can be waived only if you demonstrate reasonable cause for late payment.
- Late filing penalty: Separate penalties apply for filing returns after the extended deadline. Penalty amounts vary by return type—consult specific form instructions for details.
Mandatory Electronic Deposits
The electronic deposit requirement applies to all tax-exempt organizations except qualifying small foundations. Failure to deposit electronically may result in penalties even if you pay the correct amount. If you prefer not to use EFTPS directly, arrange for your financial institution, tax professional, or payroll service to make electronic deposits on your behalf.
Best Practices for Compliance
- Plan: Submit extension requests well in advance of deadlines to address potential issues. Electronic filing provides instant confirmation that your extension was received.
- Maintain accurate records: Document all payments made, including those with extension requests. Retain confirmation numbers from electronic payment systems.
- Monitor tax liability: Regularly assess your tentative tax to ensure accurate Line 3a calculations. Underpayment may still trigger penalties even with an approved extension.
- Update addresses promptly: File Form 8822 as soon as you have an address change. Relying solely on Form 8868 to communicate address updates will result in correspondence being sent to outdated addresses.
- Verify Return Codes: Double-check that your Return Code matches your specific return type. Incorrect codes delay processing and may invalidate your extension request.
- Coordinate with tax professionals: If using preparers or advisors, confirm they understand the single 6-month extension structure and electronic payment requirements introduced in 2020.
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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.
