What the Form Is For

Form 8868 is the IRS document that tax-exempt organizations use to request additional time to file their annual information returns. In the 2015 tax year, this form served as the application for extending the filing deadline for various exempt organization returns, including Form 990 (Return of Organization Exempt From Income Tax), Form 990-EZ (Short Form Return), Form 990-PF (Return of Private Foundation), Form 990-T (Exempt Organization Business Income Tax Return), and Form 4720 (Return of Certain Excise Taxes).

The form essentially gives organizations breathing room when they need more time to gather financial records, complete audits, or finalize their annual reporting. Unlike personal tax extensions, the extension process for exempt organizations underwent significant changes around this period, transitioning from a two-step process to a streamlined single-step automatic extension in later years.

For 2015, most exempt organizations could request an automatic 3-month extension, with the option to request an additional 3-month extension (for a total of 6 months) if they could demonstrate reasonable cause. The form also covered employee benefit plans filing excise tax returns related to their operations, making it a versatile tool for various tax-exempt entities.

It's important to understand that Form 8868 only extends the filing deadline—it does not extend the time to pay any taxes owed. Organizations still needed to estimate and pay any tax liability by the original due date to avoid interest and penalties.

IRS Form 990 Instructions 2015

When You’d Use Form 8868 (Late/Amended Filings)

When to File Form 8868

You would file Form 8868 before your organization's original return due date, which for most calendar-year filers is May 15th (the 15th day of the 5th month after the accounting period ends). The form must be submitted by the original deadline to be valid—filing it late renders it ineffective, and your main return will be considered delinquent.

Original Filing Scenarios

• Your accountant needs more time to finalize financial statements
• You're waiting for an audit report to be completed
• Key financial records are delayed or incomplete
• Complex transactions require additional review time
• Significant organizational changes occurred during the year requiring careful reporting

Important Timing Note for 2015

According to the 2015 Return Due Date Table, different tax periods had different extended deadlines. For example, a calendar year 2015 return (ending 12/31/15) had an original due date of May 16, 2016, with the automatic 3-month extension extending to August 15, 2016, and a possible additional 3-month extension to November 15, 2016.

You Cannot Use Form 8868 For

• Late filing after the deadline has passed – Once your original due date expires without filing the extension, Form 8868 cannot retroactively extend your deadline
• Amended returns – If you've already filed your Form 990 or other return and need to correct information, you file an amended return directly, not an extension
• Extending time to pay taxes – Any excise taxes or unrelated business income taxes must still be paid by the original deadline

Critical Warning

Filing an extension request late is a common mistake. The IRS states explicitly that "Form 8868 attached to a return filed after the original due date will not be effective to extend the due date." Organizations that fail to file three consecutive annual returns face automatic revocation of their tax-exempt status—a severe consequence that cannot be reversed without reapplying for exemption.

IRS Extension Information

Key Rules or Details for 2015

Extension Period Structure

For the 2015 tax year, Form 8868 followed a two-tier extension system:

• Automatic 3-month extension – No explanation needed, granted automatically upon filing
• Additional 3-month extension – Required showing "reasonable cause" for needing extra time

This differed from later years when the IRS streamlined the process to provide an automatic 6-month extension in one step. Understanding which system applied to your filing year is crucial.

Filing Methods

Organizations could file Form 8868 by:

• Electronic filing (e-filing) – The preferred and often required method for larger organizations
• Paper filing – Mailed to: Department of the Treasury, Internal Revenue Service Center, Ogden, UT 84201-0027
• Private delivery services – FedEx, UPS, and other IRS-designated carriers could deliver to 1973 Rulon White Blvd., Ogden, UT 84201

Mandatory E-Filing Rule

Organizations filing at least 250 returns of any type during the calendar year AND having total assets of $10 million or more at the end of the tax year must file Form 8868 electronically. Failure to e-file when required means the form is considered not filed at all.

Payment Requirements

If your organization owed excise taxes or unrelated business income tax:

• Estimate the tax liability on Part I or Part II of Form 8868
• Pay the estimated tax by the original due date
• Include payment information on the form
• Interest accrues on unpaid amounts from the original due date, even with an extension

Separate Forms for Different Returns

Organizations must file a separate Form 8868 for each return requiring an extension. For example, if an organization needs extensions for both Form 990 and Form 990-T, two separate Form 8868 submissions are required.

Foreign Organizations

Foreign organizations and U.S. possession organizations filed to: Internal Revenue Service Center, P.O. Box 409101, Ogden, UT 84409

No Signature Required for Automatic Extension

The 2015 instructions noted that for the automatic 3-month extension, neither a signature nor an explanation was required. However, the additional 3-month extension request needed both.

IRS About Form 8868

Step-by-Step (High Level)

Step 1: Gather Organization Information

Before completing Form 8868, collect:

• Your organization's legal name (exactly as it appears on your IRS records)
• Employer Identification Number (EIN)
• Mailing address
• Tax year dates (beginning and ending)
• Type of return you're extending (990, 990-EZ, 990-PF, 990-T, etc.)

Step 2: Complete Part I (Identification)

Fill in the header section with:

• Organization name
• Number and street (or P.O. box if mail isn't delivered to street address)
• City, town, or post office
• State and ZIP code
• Your EIN in the designated boxes

Step 3: Identify the Return Type

Check the appropriate box indicating which return you're requesting an extension for:

• Form 990 or Form 990-EZ
• Form 990-BL
• Form 4720 (individual)
• Form 990-PF
• Form 990-T (corporation)
• Form 990-T (section 401(a) or 408(a) trust)
• Form 990-T (trust other than above)

Each return type has a specific return code that should be entered on the form.

Step 4: Enter the Tax Year

Specify the tax year for which you're requesting the extension by entering the beginning and ending dates (e.g., 01/01/2015 to 12/31/2015 for calendar year filers).

Step 5: Calculate Tax Liability (If Applicable)

For organizations with potential tax liability:

• Line 1: Enter the tentative tax
• Line 2: Enter total payments and credits
• Line 3: Calculate the balance due (Line 1 minus Line 2)
• Include payment if balance is owed

Step 6: Provide Reasonable Cause (For Additional Extension Only)

If requesting the additional 3-month extension beyond the automatic 3 months, attach a detailed statement explaining:

• Why additional time is needed
• Circumstances that prevented timely filing
• Good faith efforts made to file on time
• When you expect to complete the return

Step 7: Submit the Form

File Form 8868 by:

• E-filing through an IRS-approved provider (required for organizations with 250+ returns and $10M+ assets)
• Mailing to the Ogden Service Center (paper filers)
• Filing on or before the original due date of your return

Step 8: Retain Confirmation

• Keep electronic acknowledgment receipts from e-filing
• For paper filers, use certified mail and retain postal receipts
• Maintain copies with your permanent tax records

IRS Extension of Time Information

Common Mistakes and How to Avoid Them

Mistake #1: Filing After the Original Deadline

The Problem: This is the most critical error. Organizations sometimes believe they can file Form 8868 late and still receive an extension. However, the IRS is clear: "Form 8868 attached to a return filed after the original due date will not be effective to extend the due date."

How to Avoid: Mark your calendar with the original due date (typically May 15 for calendar-year filers) and file the extension request at least one week before that date. Set up automatic reminders 30 days and 14 days before the deadline.

Mistake #2: Assuming the Extension Extends Tax Payment Deadlines

The Problem: Many organizations mistakenly believe that filing Form 8868 extends their time to pay any taxes owed. In reality, it only extends the filing deadline. Interest and late-payment penalties accrue on unpaid balances from the original due date.

How to Avoid: Calculate estimated tax liability on the form and include payment with your extension request. If you can't pay the full amount, pay as much as possible to minimize interest charges.

Mistake #3: Filing One Extension for Multiple Returns

The Problem: Organizations that file multiple returns (such as both Form 990 and Form 990-T) sometimes submit only one Form 8868 thinking it covers all returns.

How to Avoid: File a separate Form 8868 for each different return type you need to extend. Each form should clearly identify which specific return it applies to.

Mistake #4: Incorrect or Mismatched Organization Information

The Problem: Using an organization name that doesn't exactly match IRS records, transposing EIN digits, or using an old address can cause the form to be rejected or improperly processed.

How to Avoid: Double-check all identification information against your prior year's return and your IRS determination letter. Verify your EIN carefully before submitting.

Mistake #5: Not E-Filing When Required

The Problem: Large organizations subject to mandatory e-filing requirements sometimes submit paper Form 8868, which the IRS treats as not filed at all.

How to Avoid: Review the mandatory e-filing requirements (250+ returns annually and $10M+ in assets). If you meet these thresholds, you must e-file. Note that "returns" includes all information returns like W-2s and 1099s, not just your Form 990.

Mistake #6: Forgetting to Request the Second Extension

The Problem: In 2015, organizations automatically received only 3 months. Those needing more time had to file a second Form 8868 request before the first extension expired.

How to Avoid: If you filed for the automatic 3-month extension but still need more time, immediately begin preparing the second request with reasonable cause documentation. Don't wait until the last minute.

Mistake #7: Inadequate Reasonable Cause Explanation

The Problem: When requesting the additional 3-month extension, organizations provide vague or insufficient explanations like "need more time" without specific details.

How to Avoid: Provide concrete reasons such as: "Our annual audit was delayed due to our auditor's illness and won't be completed until September 30," or "We experienced unexpected staff turnover in our accounting department requiring time to reconstruct certain financial records."

Mistake #8: Three Consecutive Years Without Filing

The Problem: Organizations that fail to file returns for three consecutive years automatically lose their tax-exempt status, even if they filed extension requests. Simply filing extensions without eventually filing the actual returns doesn't satisfy filing requirements.

How to Avoid: Treat extensions as exactly that—temporary postponements. Make filing your actual Form 990 the priority. If you're struggling with multiple years, file the returns even if late to avoid automatic revocation.

IRS Automatic Revocation Information

What Happens After You File

Immediate Processing (E-Filed Extensions)

When you electronically file Form 8868, you typically receive an acknowledgment within 24-48 hours. The IRS system automatically processes the extension request and provides:

• Electronic confirmation of acceptance
• New extended filing deadline
• Confirmation number for your records

Save this electronic acknowledgment—it's your proof that you filed the extension on time.

Paper Filing Processing

If you mail Form 8868, the IRS processes it within 2-3 weeks, though you won't receive a formal acknowledgment letter. The IRS considers the form filed on the postmark date (or private delivery service date). This is why certified mail with return receipt is recommended for paper filers—you need proof of the filing date.

Your New Deadline

For 2015 filers:

• With automatic 3-month extension: Your deadline moves from the 15th of the 5th month to the 15th of the 8th month (e.g., May 15 → August 15)
• With additional 3-month extension (if approved): Deadline extends to the 15th of the 11th month (e.g., May 15 → November 15)

No Approval Letter Needed

Unlike some IRS processes, you don't receive a formal "approval" for the automatic 3-month extension. Filing Form 8868 by the deadline automatically grants the extension. However, the additional 3-month extension required reasonable cause review, and in rare cases, the IRS might deny it.

Continuing Obligations

After filing Form 8868:

• Continue preparing your return – The extension buys time but doesn't eliminate the requirement
• Make estimated tax payments – If additional tax liability is discovered, make payments to minimize interest
• Track your extended deadline – Missing the extended deadline has serious consequences
• File your actual return – Complete and submit Form 990, 990-EZ, 990-PF, or other applicable return by the extended deadline

Public Disclosure Implications

Form 8868 itself is subject to public disclosure requirements. Members of the public can request copies of your extension requests, though this is less common than requests for the actual Form 990. The form becomes part of your organization's public file maintained by the IRS.

If You Miss the Extended Deadline

Failing to file by the extended deadline triggers:

• Penalty of $20 per day (up to $10,000 or 5% of gross receipts, whichever is less) for smaller organizations
• Penalty of $100 per day (up to $50,500) for organizations with gross receipts exceeding $1,015,500
• Penalties for responsible persons – Individual officers can face personal penalties of $10 per day after IRS notification
• Automatic revocation risk – Each missed year counts toward the three-year automatic revocation threshold

State Filing Considerations

Many states require nonprofits to file copies of their federal returns as part of state charitable solicitation registration. Some states automatically grant extensions when you file federal Form 8868, while others require separate state extension requests. Check your state's specific requirements.

After Filing Your Actual Return

Once you file your Form 990 or other return within the extended deadline:

• The IRS processes it normally
• Any remaining tax balance is due with the return
• Interest continues to accrue from the original due date on unpaid amounts
• Late payment penalties may apply if the full liability wasn't paid by the original due date

IRS Publication 557 (2015)

FAQs

Q1: Does Form 8868 require a signature in 2015?

For the automatic 3-month extension, Form 8868 did not require a signature or explanation in 2015. However, for the additional 3-month extension request, the form required both a signature and a detailed statement explaining reasonable cause for needing the extra time. This asymmetry confused many filers. The key distinction was that the automatic extension was truly automatic—no justification needed—while the discretionary extension required IRS review and approval.

Q2: Can I file Form 8868 electronically for free?

Yes, the IRS encourages electronic filing and maintains a list of authorized e-file providers on IRS.gov. For organizations required to e-file (those with 250+ returns and $10M+ in assets), electronic filing is mandatory, not optional.

Q3: What counts as "reasonable cause" for the additional 3-month extension?

Reasonable cause means circumstances beyond your organization's control that prevented timely filing. Acceptable examples include:

• Death, serious illness, or unavoidable absence of key personnel responsible for tax filing
• Destruction of records due to fire, natural disaster, or other casualty
• Inability to obtain necessary information despite reasonable efforts
• Delays in receiving audited financial statements from independent auditors

NOT accepted as reasonable cause:

• General statements like "we need more time"
• Pressure of business or workload
• Lack of organizational funding
• Turnover of volunteer board members (unless extreme circumstances)

Q4: If I file Form 8868, do I still need to file my Form 990?

Absolutely yes. Form 8868 only extends your filing deadline—it doesn't eliminate the requirement to file your annual return. This is a common misconception that leads to organizations losing their tax-exempt status. Even with an approved extension, you must file the actual Form 990, 990-EZ, 990-PF, or other applicable return by the extended deadline. Three consecutive years of failing to file the actual returns (even with extensions filed) triggers automatic revocation of exempt status.

Q5: Can I file Form 8868 if I've already filed Form 990 for the year?

No. Once you've filed your actual return (Form 990, 990-EZ, 990-PF, etc.), you cannot file an extension for that same return. Form 8868 must be filed before the original due date and before filing the actual return. If you discover errors after filing your return, you would file an amended return, not an extension. This is why organizations should carefully consider whether they truly need more time before filing their return—once filed, you can't retroactively extend the deadline.

Q6: Does filing an extension affect my organization's tax-exempt status?

Filing Form 8868 properly and on time does not negatively affect your tax-exempt status. The IRS recognizes that organizations legitimately need additional time. However, repeatedly requesting extensions year after year might attract IRS attention during an examination, as it could suggest organizational management issues. The real danger comes from not filing the actual return even after receiving an extension. Three consecutive years without filing triggers automatic revocation.

Q7: What happens if I accidentally file Form 8868 after the original deadline?

Unfortunately, if you file Form 8868 after your return's original due date, it's ineffective—it doesn't extend your deadline. Your eventual Form 990 filing will be considered late, subjecting your organization to late-filing penalties ($20-$100 per day depending on organization size). Your best course of action is to file the actual return immediately and include an explanation of reasonable cause for the late filing to potentially reduce or eliminate penalties. In some cases, reasonable cause (like a natural disaster or serious illness) might excuse both the late extension request and late return filing.

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