What IRS Form 990-BL (2022) Is For

IRS Form 990-BL (2022) was used by Section 501(c)(21) black lung benefit trusts to report annual activities, benefits paid, and excise taxes owed under IRC Sections 4951–4953. These trusts supported the Federal Black Lung Program, which helps coal miners and eligible survivors receive medical treatment and compensation for pneumoconiosis arising from coal mine employment. 

The form allowed the IRS to confirm that each tax-exempt trust followed the Black Lung Benefits Act and used its funds only for approved expenses. Although the form became obsolete after 2020, older filings may still need to be amended or reviewed to ensure accurate reporting and continued compliance with IRS and program requirements.

When You’d Use Form 990-BL (Late or Amended Filing)

You can’t use IRS Form 990-BL (2022) because it was discontinued after 2020. However, if your Black Lung Benefit Trust needs to correct or update a prior filing, you can file an amended return using the correct version of Form 990-BL for that tax year. Check “Amended return” at the top of the form. If the IRS mistakenly requests Form 990-BL for 2022, contact the agency to confirm that Form 990 is the proper filing. For current years, Section 501(c)(21) trusts must follow general exempt organization rules using Form 990 and Form 6069 for excise taxes.

Key Rules and Filing Details for 2022

For the tax year 2022, Section 501(c)(21) Black Lung Benefit Trusts must follow these updated IRS filing requirements:

• Form Used: Trusts must file Form 990 instead of Form 990-BL, since the older form is no longer valid for 2022 filings.
  
  
• Filing Method: All returns must be submitted electronically through an IRS-authorized e-file provider because paper filings are no longer accepted.
  
  
• Excise Taxes: Required excise taxes under IRC Sections 4951–4953 must be reported on Form 6069 to comply with IRS regulations.
  
  
• Recordkeeping: Trusts must keep financial, benefit, and medical coverage records for at least three years after submission.
  
  
• Penalties: The IRS may impose daily fines or revoke tax-exempt status if returns are filed late or remain unfiled.
  
  
• Compliance Standards: The IRS now holds Black Lung Benefit Trusts to the same reporting and review standards as other tax-exempt organizations.

Step-by-Step (High Level)

Follow these steps to ensure your 2022 filing meets all IRS and program requirements:

1. Identify eligible miners and covered individuals: Ensure all benefits recipients meet the Federal Black Lung Program qualifications. Eligibility applies to miners with black lung disease or another occupational disease that caused total or partial disability.
   
   
2. Gather accurate financial and employment records: Collect documentation of benefit payments, employer contributions, transportation reimbursements, and other expenses attributable to medical care or survivor claims.
   
   
3. Review IRS and Social Security Administration guidance: Consult the relevant IRS publication and SSA materials to align reporting standards and ensure each claim and payment is classified correctly.
   
   
4. Complete and e-file the return: Fill out Form 990 and Form 6069 if excise taxes apply, then file electronically. Note any determination or exception related to deaths, refunds, or amended returns.
   
   
5. Retain supporting documentation: Keep records of extraction and processing activities, filings, and correspondence for at least three years to support IRS review or refund efforts.

Common Mistakes and How to Avoid Them

Even experienced trustees can make filing errors when transitioning from Form 990-BL to Form 990. The points below explain how to avoid common issues.

• Using the wrong form: Some operators still submit Form 990-BL instead of Form 990, which has been obsolete since January 2021.
  
  
• Missing deadlines: Returns are generally due in April, though an IRS office extension may be requested.
  
  
• Forgetting excise tax reporting: Always complete Form 6069 when required under Part B or Part C of the program.
  
  
• Omitting details: Include additional information that helps the IRS determine eligibility for deductions or grants.
  
  
• Overlooking help: Customers and trustees are entitled to IRS assistance, which can provide support and clarification for complex filings.

What Happens After You File

After you file Form 990, the IRS reviews the return and confirms receipt electronically. The agency generally processes e-filed submissions within six to eight weeks from the filing date. Each trust should keep its acknowledgment notice as proof that the filing was successfully operated through the e-file system. If the IRS requests additional information on any subject related to benefits or taxes, respond promptly to prevent delays. Trustees may also seek workers' compensation guidance if benefits overlap with trust payments to totally disabled miners. Contact the IRS or a qualified tax professional if you require further clarification.

Frequently Asked Questions (FAQs)

How does the Federal Black Lung Program affect current filings?

The Federal Black Lung Program requires all Section 501(c)(21) trusts to file Form 990, not 990-BL. This ensures accurate reporting of medical benefits, excise taxes, and trust activity related to coal-related diseases.

Who must file as part of Black Lung Benefit Trusts?

Only registered Black Lung Benefit Trusts that provide assistance or compensation for miners and survivors affected by coal dust exposure must file under these IRS requirements.

How is workers' compensation different from trust payments?

Workers' compensation provides coverage for job-related injuries or illnesses through state programs. In contrast, Black Lung benefit payments come from federally regulated trusts that specifically assist miners diagnosed with pneumoconiosis. The two systems operate separately but may sometimes coordinate benefit eligibility.

Are these trusts considered tax-exempt?

Black Lung trusts that meet Section 501(c)(21) requirements are recognized as tax-exempt organizations under the Internal Revenue Code. They must still file Form 990 annually to report income, benefit distributions, and excise tax obligations.

Where can I find additional information?

For additional information, visit the IRS official website and review IRS Publication 557 for detailed compliance guidance. You can also contact the IRS TE/GE division to clarify filing requirements or obtain support with electronic submissions.