What IRS Form 990-BL (2015) Is For

IRS Form 990-BL (2015) serves as the official information and initial excise tax return for Black Lung Benefit Trusts and certain related persons established under section 501(c)(21) of the Internal Revenue Code. The form helps these trusts fulfill their annual filing obligations and report any excise taxes imposed under sections 4951 and 4952. These excise taxes apply to self-dealing transactions and taxable expenditures made by the trust or individuals related to it. 

These trusts were created under the Black Lung Benefits Act to provide medical benefits and workers' compensation to coal miners who are totally disabled due to pneumoconiosis arising from coal mine employment, commonly known as black lung disease. The federal black lung program oversees and enforces these benefit provisions in coordination with the Social Security Administration.  

When You’d Use IRS Form 990-BL (2015)

You should file or amend IRS Form 990-BL (2015) when specific reporting or compliance obligations apply to a Black Lung Benefit Trust.

1. Late Return: You must file a late return if the trust missed its original filing deadline due to trustee changes, administrative errors, or unawareness of the filing requirements.
   
   
2. Amended Filing: An amended return is required when additional transactions are discovered, such as previously unreported excise taxes or self-dealing activities that affect the accuracy of prior filings.
   
   
3. Penalty Notice Response: You should file the return if you receive IRS notices or penalty assessments under section 6652(c) for non-filing or incomplete information.
   
   
4. Compliance Update: The return is also required when the IRS requests clarification or updated financial information to verify continued qualification under section 501(c)(21).

Key Rules or Details for 2015

The 2015 version of IRS Form 990-BL (2015) followed specific IRS rules and requirements that applied to all Black Lung Benefit Trusts for that tax year.

1. Filing Deadline: For calendar-year filers, the return was due on the 15th day of the fifth month after the end of the fiscal year, which was May 15, 2016.
   
   
2. Gross Receipts Threshold: Trusts with gross receipts exceeding $50,000 were required to file Form 990-BL, while those below this threshold could file Form 990-N instead.
   
   
3. Penalty Structure: The IRS imposed daily penalties of $20 for most organizations and $105 for large organizations with receipts above $1,067,000, with a maximum of $10,500 or $53,000, or five percent of gross receipts, whichever was smaller.
   
   
4. Electronic Filing Requirement: For trusts that filed 250 or more returns annually or held assets exceeding $10 million, electronic filing was mandatory.
   
   
5. Schedule A Requirement: When excise taxes were applied under sections 4951 or 4952, the trust had to include Schedule A to report and document such transactions accurately.

These rules ensured compliance with IRS regulations and helped trustees avoid penalties, maintain transparency, and uphold their tax-exempt status under the Internal Revenue Code.

Step-by-Step (High Level)

The following steps outline how trustees should properly prepare and file IRS Form 990-BL (2015) to meet federal reporting obligations under the Black Lung Benefits Act.

1. Confirm Filing Records: Trustees should request IRS account transcripts for 2015 to verify whether previous filings were received and to determine any penalties or interest currently owed.
   
   
2. Prepare the Correct Form Version: The December 2013 revision of Form 990-BL must be used for 2015 filings to ensure that all data aligns with the tax year’s reporting structure.
   
   
3. Attach Schedules and Statements: Trustees should attach Schedule A if excise taxes apply and include detailed reasonable cause explanations when filing late returns or penalty abatement requests.
   
   
4. Submit Filing to the IRS: The completed Form 990-BL (2015) must be mailed to the Ogden, Utah, Service Center or filed electronically through an approved IRS e-filing service.
   
   
5. Retain Supporting Documentation: Trustees must keep copies of the tax return, payment confirmations, and all supporting documentation in case the IRS requests proof of compliance or additional information.

Common Mistakes and How to Avoid Them

Many trustees encounter errors when filing IRS Form 990-BL (2015) that can result in unnecessary penalties or processing delays. Below are the most common issues and how to prevent them.

• Using the Wrong Form Version: Always use the correct year’s form and verify the revision date to prevent rejection or inaccurate reporting of the trust’s tax obligations.
  
  
• Incomplete Identification Information: Double-check that the EIN, trust name, and filing year are entered correctly. Incomplete details can cause IRS correspondence delays.
  
  
• Omitting Schedule A: If the trust engaged in self-dealing transactions or incurred excise taxes, ensure Schedule A is attached to document these activities accurately.
  
  
• Vague Explanations for Late Filing: Provide detailed, reasonable cause statements supported by records or evidence, such as documentation of a serious illness or proof that the trustee could not file on time.
  
  
• Incorrect Public Disclosure: Review what must be made available to the public and what remains confidential; contributor details and Schedule A are exempt from public disclosure requirements.

Avoiding these mistakes helps maintain compliance, prevents unnecessary penalty assessments, and demonstrates diligence in fulfilling the trust’s responsibilities under federal Black Lung Program regulations.

What Happens After You File

After submitting IRS Form 990-BL (2015), the IRS reviews and processes the return within six to eight weeks. If the filing was late, the process may take longer, and you might receive notices assessing penalties or interest. Trustees can request penalty abatement by submitting written, reasonable cause explanations supported by proper documentation. 

When taxes or penalties remain unpaid, Form 9465 can be used to request a payment arrangement. The IRS may also request additional information to verify the trust’s ongoing qualification under section 501(c)(21). 

FAQs

What is an initial excise tax return under IRS Form 990-BL (2015)?

The initial excise tax return reports self-dealing transactions or taxable expenditures by a Black Lung Benefit Trust under sections 4951 and 4952. It ensures compliance within the Black Lung Benefits Program and helps the IRS verify proper use of funds for eligible miners and their dependents.

Who are certain persons considered to be related to this filing?

Certain related persons include trustees, contributors, or organizations with financial control or influence over a Black Lung Benefit Trust. These individuals or entities are responsible for accurate reporting to avoid violations that could result in interest or IRS penalties.

What are Black Lung Benefit Trusts, and who do they serve?

Black lung benefit trusts are tax-exempt entities established by coal operators to provide medical coverage and support for eligible miners who are totally disabled by black lung disease. They also help cover medical treatment and other benefits required under the Black Lung Benefits Program.

What does information and initial excise mean in IRS Form 990-BL (2015)?

The phrase refers to the dual purpose of the form: collecting annual information about the trust’s operations and reporting any initial excise taxes due on transactions involving certain related persons. It maintains transparency in the Black Lung Benefits Program and compliance with federal tax law.