What IRS Form 990-BL (2020) Is For

IRS Form 990-BL (2020) is an information return required for Black Lung Benefit Trusts established under the Black Lung Benefits Act. These trusts are formed to provide medical coverage, compensation, and benefit payments to coal miners who are totally disabled or suffer from pneumoconiosis arising from coal mine employment. The form helps the Internal Revenue Service ensure compliance with federal reporting standards and verify that the trusts use their funds appropriately for their beneficiaries.

This form is also a key reporting tool under the Internal Revenue Code to maintain the transparency of benefit programs within the federal Black Lung Program. Filing IRS Form 990-BL (2020) demonstrates that the trust has met all tax filing requirements, paid excise taxes when applicable, and legally managed its receipts and benefit distributions. It ensures eligible miners and their dependents receive the financial and medical support determined under parts B and C of the federal Black Lung Benefits Program.

When You’d Use IRS Form 990-BL (2020)

You would use IRS Form 990-BL (2020) when your organization meets the IRS filing requirements for Black Lung Benefit Trusts or when the trust’s annual operations must be reported.

• Annual Reporting Obligation: Black lung benefit trusts use this form annually to disclose benefits paid, receipts, and other financial activity during the tax period.
  
  
• Late or Amended Filing: This must be filed when a previous year’s return was missed or when reasonable cause exists for requesting relief from late filing penalties.
  
  
• Reinstating Compliance: The form should be submitted in response to IRS notices or when three consecutive years of returns have not been filed.
  
  
• Trust Modifications: Filing is necessary when there are significant changes in coal mine employment activity or the structure of benefit payments and schedules.

Key Rules or Details for the 2020 Tax Year

The IRS set forth specific rules for trusts filing Form 990-BL (2020) for the 2020 tax year. These guidelines define eligibility, filing procedures, and circumstances for penalty relief.

• Eligibility Threshold: Any Black Lung Benefit Trust with gross receipts exceeding the IRS reporting limits must file Form 990-BL (2020) instead of simplified returns such as the e-Postcard.
  
  
• Filing Deadline: The due date for filing is the 15th day of the fifth month following the end of the trust’s tax year, and late filing penalties may apply if the trust fails to meet this deadline without reasonable cause.
  
  
• Electronic Filing: All Black Lung Benefit Trusts must submit Form 990-BL (2020) electronically to ensure accuracy, faster processing, and compliance with IRS standards.
  
  
• Supporting Documentation: Each submission must include supporting documentation verifying benefit payments, excise tax obligations, and all relevant financial records.
  
  
• Penalty Relief: The IRS may approve penalty relief if the trust demonstrates reasonable cause, such as delays resulting from natural disasters or other unforeseen events.

Step-by-Step (High Level)

These steps outline how to properly complete and file IRS Form 990-BL (2020) in accordance with federal Black Lung Program requirements.

1. Gather Key Details: Collect the trust’s employer identification number (EIN), legal name, mailing address, list of beneficiaries, gross receipts, and the total benefits paid during the tax year.
   
   
2. Verify Eligibility: Confirm that the trust qualifies under part B or part C of the federal Black Lung Program and that its beneficiaries are eligible miners or dependents.
   
   
3. Access the IRS Filing System: To begin the submission process, log in to the IRS electronic filing system using a valid Login.gov or ID.me account.
   
   
4. Complete All Schedules: Enter accurate information for taxes, excise tax liabilities, payments, and any other data required by IRS instructions.
   
   
5. Review for Accuracy: Carefully check all reported amounts, schedules, and supporting documentation to ensure they align with the trust’s internal accounting records.
   
   
6. Submit Electronically: File Form 990-BL (2020) online, as the IRS does not accept paper submissions for this return.
   
   
7. Save Confirmation: Retain a copy of the filing confirmation and all related documentation for future reporting or potential reasonable cause requests.

Common Mistakes and How to Avoid Them

Many organizations encounter filing issues when preparing IRS Form 990-BL (2020), but these mistakes can be avoided by following the IRS instructions carefully.

• Incorrect EIN or Trust Name: Always confirm that the trust’s employer identification number and legal name match IRS records precisely to prevent filing rejection.
  
  
• Filing After the Due Date: Submit the form by the required deadline to avoid penalties, and if delays occur, attach a statement explaining reasonable cause to request penalty relief.
  
  
• Incomplete Schedules or Documentation: Ensure that all required schedules and supporting documentation, including benefit payments and excise tax records, are accurately attached to the return.
  
  
• Wrong Form Type: Verify that the trust files Form 990-BL (2020) instead of Form 990 or the e-Postcard, as the correct form depends on the trust’s receipts and classification.
  
  
• Unverified Benefit Payments: Report only verified benefit payments made to eligible miners or beneficiaries to avoid discrepancies during IRS review.
  
  
• Ignoring IRS Notices: Respond promptly to any IRS notice or request for additional information to maintain compliance and prevent unnecessary penalties.

What Happens After You File

Once the IRS Form 990-BL (2020) is submitted through the electronic filing system, processing typically occurs within several business days. The IRS confirms through the online filing portal, and the information return becomes part of the Black Lung Benefit Trust's public record. 

Timely filing helps preserve compliance with the Black Lung Benefits Act and the Internal Revenue Code. If the IRS assesses penalties or interest, the trust may submit a written request for reasonable cause consideration or establish a payment plan to settle outstanding liabilities while maintaining its good standing.

FAQs

What is the purpose of IRS Form 990-BL (2020)?

Black lung benefit trusts use IRS Form 990-BL (2020) to report benefit payments, receipts, and excise taxes related to financial assistance for coal miners affected by black lung disease.

What happens if I miss the filing due date?

Failing to file by the due date may result in late filing penalties unless the trust provides supporting documentation that establishes reasonable cause.

Can Form 990-BL (2020) be filed on paper?

No, the IRS requires all Form 990-BL (2020) submissions to be completed through its electronic filing system.

What records should I maintain after filing?

Trusts must retain all supporting documentation for at least three years, including receipts, excise tax reports, and benefit payment records.

How do I correct an error after filing?

An amended return should be filed electronically with accurate data, and a written explanation of the changes must accompany the submission.