Form 8868: Application for Extension of Time to File Exempt Organization Returns (2025 Tax Year)
Purpose and Overview
Form 8868 allows exempt organizations, governmental entities, and employee benefit plans to request an automatic 6-month extension for filing most tax-exempt returns. The January 2025 revision adds Return Code 15 for governmental entities filing Form 990-T, clarifies electronic payment procedures through Forms 8453-TE and 8879-TE, and confirms that Form 8870 extension requests must be filed on paper only.
Corporations filing income tax returns (including 1120-C filers), partnerships, REMICs, and trusts must use Form 7004 instead of Form 8868 for extension requests.
Step-by-Step Filing Checklist
Step 1: Determine Your Return Code
Identify the correct return code (01-15) from the form that matches your organization’s return type. Common codes include 01 (Form 990 or 990-EZ), 04 (Form 990-PF), 06 (Form 990-T for trusts), 13-14 (Form 5330), and 15 (Form 990-T for governmental entities). File a separate Form 8868 for each return requiring an extension.
Step 2: Complete Organization Identification
Enter your organization’s complete legal name, Taxpayer Identification Number (TIN), and current mailing address, including suite or room numbers. If using a P.O. box, include the box number instead of a street address. For foreign addresses, list the city, province or state, and country name without abbreviation, following that country’s postal code format.
Step 3: Indicate Foreign Status (If Applicable)
Check the designated box on the form if your organization does not have an office or place of business in the United States or its territories.
Step 4: Complete Group Return Information (If Applicable)
For group return applicants, enter your four-digit Group Exemption Number (GEN) in the space provided. Check the appropriate box to indicate whether the extension applies to all organizations in the group or only specific members. If requesting a partial-group extension, please attach a schedule that lists the name, address, and TIN of each included organization.
Step 5: Enter Tax Year Information
Confirm and enter the year-end date for calendar year filers, or specify the custom tax year beginning and ending dates in MM/DD/YYYY format. Most exempt organizations follow a calendar year ending December 31, but fiscal year filers must clearly specify their accounting period.
Step 6: Indicate Short Tax Year Reason (If Applicable)
If your tax year is less than 12 months, check the appropriate reason box: Initial return (first year of filing), Final return (organization terminating), or Change in accounting period (switching fiscal year dates).
Step 7: Complete Part II for Automatic Extensions
Most filers use Part II for automatic 6-month extensions. Enter contact information, including where books and records are maintained, telephone number, and fax number. Skip to Step 11 if filing for Form 5330.
Step 8: Enter Extended Due Date
On line 1, calculate and enter the extended due date, which cannot exceed 6 months from the original return due date. For calendar year organizations with an original deadline of May 15, the extended deadline would be November 15.
Step 9: Calculate Tax Liability (Lines 3a-3c)
Complete these lines only if filing Forms 990-PF, 990-T, 4720, or 6069. On line 3a, enter tentative tax minus any nonrefundable credits (enter -0- if no tax is due). On line 3b, enter refundable credits and estimated tax payments, including any prior year overpayments credited forward. On line 3c, calculate the balance due by subtracting line 3b from line 3a.
Step 10: Submit Payment (If Balance Due)
If line 3c shows a balance due, pay electronically using EFTPS (Electronic Federal Tax Payment System) by the original return due date to avoid interest and penalties. For direct debit payment authorization, complete the electronic funds withdrawal section following instructions on Forms 8453-TE or 8879-TE, providing your bank routing number, account number, account type, debit amount, and preferred debit date.
Step 11: Complete Part III for Form 5330 Extensions Only
Form 5330 filers must complete Part III instead of Part II. Enter the plan name, plan number, and plan year ending date at the top of the form. Use Return Code 13 if filing as an individual or Return Code 14 if filing as an entity other than an individual.
Step 12: Provide Form 5330 Extension Details
On line 1, enter your requested extension due date (up to 6 months after the normal due date). On line 1a, enter the Internal Revenue Code section(s) imposing the excise tax (such as sections 4971, 4975, 4980, or others). On line 1b, enter the payment amount and include payment with your application.
Step 13: Explain Extension Necessity for Form 5330
On line 2, provide a detailed explanation of the circumstances beyond your control that prevent timely filing. The IRS grants Form 5330 extensions on a discretionary basis, considering your efforts to fulfill filing responsibilities. File early enough for the IRS to review and act on your request before the return’s normal due date. You will receive a notice indicating approval or denial.
Step 14: Sign and Date the Application
Form 5330 filers must sign Part III under penalty of perjury, certifying their authorization to prepare the application and confirming that all statements are true, correct, and complete. The signature must be from an employer, plan sponsor, plan administrator, disqualified person, authorized attorney, certified public accountant qualified to practice before the IRS, enrolled agent, or person holding power of attorney. Part II filers are not required to sign Form 8868.
Step 15: File Electronically or By Mail
File electronically through approved IRS e-file providers for all returns except Form 8870, which requires paper filing only. If filing by paper, mail Form 8868 to: Internal Revenue Service, Mail Stop 6054, 1973 N Rulon White Blvd., Ogden, UT 84201-0045. Submit the form by the original return due date to receive the extension.
Key 2025 Updates and Clarifications
● Governmental Entity Returns: Form 8868 now explicitly includes extensions for Form 990-T filed by governmental entities (state, local, and tribal), making elective payment elections under Return Code 15.
● Electronic Payment Methods: Filers making electronic funds withdrawal (direct debit) elections must follow payment instructions on Forms 8453-TE and 8879-TE. These forms authorize ACH electronic debits and provide necessary banking information to the IRS and financial institutions.
● Form 8870 Paper Filing Requirement: Extension requests for Form 8870 (Information Return for Transfers Associated With Certain Personal Benefit Contracts) must be submitted in paper format to the Ogden address. Electronic filing is not permitted for this return type.
● Form 7004 Distinction: The 2025 revision reinforces that corporations filing income tax returns (including 1120-C), partnerships, REMICs, and trusts must use Form 7004, not Form 8868, to request extensions.
● Form 5330 Discretionary Extensions: Unlike the automatic 6-month extension granted to most exempt organizations through Part II, Form 5330 extensions require approval from the IRS. File in sufficient time for review, provide detailed justification, and expect a notice of approval or denial.
Important Reminders
● Extension Covers Filing, Not Payment: Form 8868 extends the deadline to file our return, but does not extend the deadline to pay any tax due. Pay the full balance by the original due date to avoid interest charges and late payment penalties.
● Single Extension Period: Only one 6-month extension is allowed per return type per tax year. Extensions cannot be renewed or extended further, except under extraordinary circumstances that require additional IRS approval.
● Automatic Revocation Risk: Organizations that fail to file required Form 990 series returns for three consecutive years will have their tax-exempt status automatically revoked as of the filing date for the third missed return, even during approved extension periods.
● No Extension for Form 990-N: Form 8868 cannot be used to extend the filing deadline for Form 990-N (e-Postcard for small organizations). Form 990-N must be filed by its original due date.
● Group Return Requirements: Central organizations applying for group extensions must specify whether the extension covers all member organizations or only certain members. Partial extensions require attaching a complete schedule identifying each included organization.
● Address Changes: Updating the address on Form 8868 will not automatically update IRS records. File Form 8822-B (Change of Address or Responsible Party—Business) separately to ensure proper record updates.
● Interest and Penalties: Interest accrues on unpaid taxes from the original due date until payment is received, regardless of whether an extension is approved. Late payment penalties of 0.5% per month (maximum 25%) apply unless reasonable cause is demonstrated. Late filing penalties apply if extended deadlines are not met.
This checklist provides comprehensive guidance for accurately completing Form 8868, based on the official IRS instructions effective as of January 2025. Review the complete form instructions at IRS.gov/Form8868 for additional details specific to your organization’s situation.
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.
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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.
