A Plain-English Guide to Getting More Time to File Your Tax-Exempt Organization’s Returns

What the Form Is For

Form 8868 is your lifeline when your tax-exempt organization needs extra time to file its annual returns with the IRS. Think of it as a “get out of jail free” card that gives you breathing room to gather documents, finalize numbers, and complete your paperwork without facing harsh penalties.

In 2011, this form served two distinct purposes. First, it provided an automatic 3-month extension for most exempt organization returns (or a full 6 months for corporations filing Form 990-T). “Automatic” means exactly that—you file the form with payment of any taxes owed, and you’re granted the extension without explanation. Second, if three months wasn’t enough, you could request an additional 3-month (non-automatic) extension, giving you up to six months total to file most returns.

The form covered a wide range of returns in 2011, including Form 990, 990-EZ, 990-PF, 990-T, 4720, and several other specialized returns related to exempt organizations and employee benefit plans.

Important: Form 8868 does not extend the time to pay any taxes you owe. You must estimate and pay that amount by the original due date to avoid interest and penalties. (IRS.gov)

When You’d Use It (Late Filing / Amended Returns)

Typical Situations for Using Form 8868

For calendar-year organizations in 2011, Form 990 series returns were due May 15, 2012.
If you couldn’t meet that deadline, you needed to file Form 8868 by May 15 to get an automatic extension until August 15, 2012.
If August still wasn’t enough, you could file a second Form 8868 requesting an additional extension until November 15, 2012.

You might need this extension if:

• Accounting records weren’t finalized
• Key financial documents were missing
• Your accountant had a scheduling conflict
• You experienced major organizational changes
• You needed more time to ensure accuracy and completeness

Important Timing Rules

Form 8868 must be filed by the original due date of the return you’re extending.
Filing it late doesn’t work—a late Form 8868 won’t extend your due date, and you’ll face late-filing penalties.
If you’ve already missed the deadline, file your return as soon as possible and include a reasonable-cause explanation directly with the return (not with Form 8868).

Regarding Amended Returns

Form 8868 cannot extend the time for filing an amended return.
If you discover errors after filing, submit an amended Form 990 marked “Amended” as soon as possible.

Special Note About Form 990-N

Form 8868 could not extend the electronic postcard (Form 990-N).
Small organizations required to file the 990-N had to meet their deadline without extension. (IRS.gov)

Key Rules for 2011

The Two-Part Extension System

• Part I – Automatic Extension:
  Check the correct box, enter your organization’s details, and specify which return you’re extending.
  Grants 3 months (6 months for corporate 990-T).
  No explanation required.
• Part II – Additional Extension:
  May be filed only after obtaining the automatic extension.
  Requires a detailed written explanation of why you need more time.
  Vague statements like “illness” or “practitioner too busy” won’t suffice.

Payment Requirements

Organizations had to estimate and pay at least 90% of total tax due by the original deadline to avoid late-payment penalties.
This primarily affected filers of Forms 990-PF, 990-T, 4720, etc.

Electronic Filing Option

Starting January 2011, both Parts I and II could be filed electronically.
However, Form 8870 still required paper filing mailed to the IRS in Ogden, Utah.

Interest and Penalties

• Interest: charged on unpaid tax from the original due date.
• Late Payment Penalty: 1% per month (up to 25%).
• Late Filing Penalty: 5% per month (up to 25%).
• Over 60 Days Late: minimum penalty of $100 or balance due.
  (IRS.gov)

Step-by-Step Guide (High Level)

For the Automatic 3-Month Extension (Part I)

Step 1: Determine Your Return Code

Each return type had a code (e.g., 01 for Form 990, 02 for 990-BL, 03 for 990-EZ, 04 for 990-PF, etc.).

Step 2: Complete Organization Information

Include name, EIN, address, contact, and custodian of books.

Step 3: Enter Tax Year and Extension Date

Specify the tax year and the extension end date (3 months or 6 months for corporate 990-T).

Step 4: Calculate Payment Due (if applicable)

Compute tentative tax (Line 3a), credits (Line 3b), and balance due (Line 3c).
Payments made via EFTPS.

Step 5: File by the Deadline

File electronically or mail to:
Department of the Treasury, IRS Center, Ogden, UT 84201-0045
Must be received by the original due date.

For the Additional 3-Month Extension (Part II)

Available only if Part I was already filed.
Complete organizational info, state the new extension date, and provide a detailed explanation (Line 7).
Calculate payment in Lines 8a-c and sign the form.
File by the Part I extended deadline. (IRS.gov)

Common Mistakes and How to Avoid Them

Mistake #1: Filing Form 8868 After the Original Due Date

File early to ensure it counts.

Mistake #2: Not Paying Estimated Taxes

Extension ≠ extra time to pay.
Pay at least 90% by the due date to avoid penalties.

Mistake #3: Vague Explanation for Part II

Be specific when explaining why you need extra time.

Mistake #4: Filing One Form for Multiple Returns

File a separate Form 8868 for each return type.

Mistake #5: Confusing Form 8868 with Form 4868

Form 4868 = individuals; Form 8868 = exempt organizations.

Mistake #6: Assuming Form 990-N Can Be Extended

It cannot. File on time or risk status issues.

Mistake #7: Not Updating Address Changes

Use Form 8822 to update address separately. (IRS.gov)

What Happens After You File

For Automatic Extensions (Part I)

If you file correctly and pay on time, the extension is automatically granted.
Keep proof of filing (e.g., confirmation or certified mail receipt).
Interest still accrues on any tax due.
Do not attach Form 8868 to your return.

For Additional Extensions (Part II)

These require IRS review.
File early within your first extension window to avoid denial delays.
If approved → 6 months total; if denied → file by Part I deadline.

If You Miss the Extended Deadline

Penalties apply as if no extension was filed:

• 5% late filing per month (up to 25%)
• 1% late payment per month (up to 25%)
  Total potential ≈ 47.5% over time.
  You can request penalty relief for reasonable cause (e.g., disaster, illness, loss of records).

Subsequent Filing

When you do file, include all required schedules and attachments.
If you owed additional tax, expect an IRS notice for interest and penalties. (IRS.gov)

FAQs

Q1: Can I file Form 8868 electronically?

Yes. Both parts could be e-filed starting in 2011 (except Form 8870).
E-filing is recommended for confirmation and speed. (IRS.gov)

Q2: What if I can’t accurately estimate my tax liability?

Make your best estimate from available data.
Over-estimating is safer than under-estimating.

Q3: Do we need two extensions for Forms 990 and 990-T?

Yes. Each return requires its own Form 8868 and Return Code. (IRS.gov)

Q4: How does Form 8868 work for group returns?

A central organization may file one Form 8868 for a group return, listing subordinates and Group Exemption Number (GEN). (IRS.gov)

Q5: What if my Part II explanation is false or misleading?

The IRS can void the extension entirely, triggering penalties from the original due date. (IRS.gov)

Q6: Can I withdraw an extension request?

No need to. Simply file your return early if ready; there’s no penalty.

Q7: Are there special rules for private foundations (Form 990-PF)?

Yes. Use Return Code 04 and pay excise tax on net investment income with the extension. Private foundations receive the same 3- + 3-month extension option. (IRS.gov)

Additional Resources

• About Form 8868 (IRS.gov)
• Extension of Time to File Exempt Organization Returns (IRS.gov)
• Form 8868 (Rev. January 2011) – PDF

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