What IRS Form 990-BL Is For

IRS Form 990-BL (2024) was the annual tax return for Black Lung benefit trusts under section 501(c)(21) of the Internal Revenue Code. Funded by coal mine operators, these trusts provided medical care and income benefits to miners with black lung disease. The form reported income, expenses, and tax obligations, including excise taxes under sections 4951–4953, to verify proper fund use and preserve tax-exempt status. Under section 6033, trustees filed it annually to meet IRS reporting rules. The IRS made Form 990-BL obsolete after 2020. For 2024, trusts must file Form 990 or Form 990-N instead.

When You’d Use IRS Form 990-BL (2024)

You may still need to file IRS Form 990-BL (2024) if you submit late or amended returns for tax years 2020 or earlier. Although the form is obsolete for current filings, it remains relevant for Black Lung Benefit Trusts correcting errors or responding to IRS correspondence about past years.

Situations where Form 990-BL may still apply include:

• Correcting previous filings: Trustees may need to amend earlier returns to fix reporting errors, such as incorrect income or compensation amounts.
  
  
• Responding to IRS delinquency notices: Some trusts receive letters requesting missing or incomplete filings for older tax years.
  
  
• Claiming refunds or adjustments: Amended 990-BL returns can be used to request refunds for excise taxes or other overpaid amounts from prior filings.

Before filing, trustees should request IRS account transcripts to confirm filing history and payment status. This step helps avoid duplicate submissions, additional penalties, or unnecessary interest charges.

Key Rules and Requirements for 2024

For the 2024 tax year, the IRS no longer accepts Form 990-BL for new filings. All taxpayers operating black lung benefit trusts must now file Form 990 or Form 990-N, depending on gross receipts. This ensures that each organization meets its tax requirements and disclosure obligations under section 501(c)(21).

Filing rules and obligations:

• Form 6069 attachment: Trusts with excise tax liabilities under sections 4951–4953 must include this form when submitting returns.
  
  
• Deadlines and penalties: Annual filings are due on the 15th day of the fifth month after the trust’s fiscal year-end (often in October). If failure to file occurs, the IRS may charge penalties. If the issue continues, that penalty continues each month until corrected, up to the legal max.
  
  
• Record accuracy: Trustees should confirm all estimated tax payments, refundable credits, and amounts earned during the year to avoid discrepancies.
  
  
• Documentation: Each return must include complete information, the correct number of schedules, and any additional information the IRS requests.

Step-by-Step (High Level)

The process for filing or correcting returns for a Black Lung Benefit Trust in 2024 depends on which form applies and the accuracy of past submissions. Follow these steps to comply with IRS rules and avoid filing penalties or missed deadlines.

1. Confirm Which Form Applies

Determine whether your trust must file Form 990 or Form 990-N. The correct choice depends on gross receipts and the tax required for the year.

2. Gather Past Records and IRS Transcripts

Collect prior documents, including earlier returns, notices, and payment confirmations. This helps identify any outstanding balance or prior errors that need correction.

3. Complete the Current-Year Form 990

Be sure to follow IRS instructions and attach all required schedules carefully. Include details on income, compensation, and excise taxes.

4. Attach Form 6069 if Excise Taxes Apply

This form reports excise taxes on prohibited transactions or self-dealing under sections 4951–4953 of the Internal Revenue Code. It must be filed on the same date as your primary return, with accurate details and documentation showing how the tax was calculated.

5. File Electronically and Retain Copies

Ensure the return is submitted by the due date, or kindly request an extension if additional time is required. Failing to file on time can lead to a penalty, and if that penalty continues, the IRS will assess additional interest until it is resolved. The minimum penalty applies when returns are filed late without reasonable cause.

Common Mistakes and How to Avoid Them

Even experienced trustees can make filing errors that lead to penalties or IRS notices. Knowing what to watch for can help ensure each submission meets IRS standards and avoids costly delays.

• Filing the wrong form: Recently, some trusts have mistakenly filed Form 990-BL instead of Form 990 or 990-N, which can cause processing delays or rejection. Always confirm the correct form for your filing year before submitting it.
• Omitting Form 6069: When a trust owes excise taxes under sections 4951–4953, failing to attach Form 6069 results in an incomplete return. Review the filing instructions thoroughly to ensure all required forms and schedules are included.
• Ignoring e-filing requirements: Paper submissions without an approved exemption are often rejected. File electronically through the IRS-authorized system unless you have written permission to mail your return.
  
  
• Missing details or explanations: Late filings or incomplete sections can trigger penalties or IRS follow-ups. Provide all requested information and include a reasonable-cause statement if your filing is delayed.

What Happens After You File

After you file Form 990 or an amended Form 990-BL, the IRS reviews it for accuracy and completeness. Depending on the workload and the need for additional details, the processing typically takes several months. The IRS sends a notice requesting documents or explanations if clarification is required. 

If a balance is due, the agency issues payment instructions or allows a payment plan using Form 9465 (Installment Agreement Request). Trustees should keep copies of all filings, records, and correspondence. Unlike older Form 990-BL filings, current Form 990 returns are public, supporting transparency and compliance.

FAQs

Can I still file Form 990-BL for 2024?

No. The IRS discontinued Form 990-BL after the 2020 tax year. For 2024 filings, section 501(c)(21) Black Lung Benefit Trusts must use Form 990 or Form 990-N, depending on gross receipts.

What tax obligations apply to Black Lung Benefit Trusts in 2024?

Trusts must file Form 990 or Form 990-N each year and include Form 6069 if excise taxes apply under sections 4951–4953. This ensures compliance with federal reporting requirements for exempt organizations.

What penalties apply if I file late or make a filing error?

If you miss the deadline or fail to file accurately, the IRS may charge a filing penalty and daily interest until the issue is corrected. Larger organizations may face higher limits.

How can I request additional information or help from the IRS?

You can visit IRS.gov for instructions, prior-year forms, or filing updates. If you receive an IRS notice, follow the directions or call the number in your correspondence for assistance.

What if I need to amend or correct an older Form 990-BL?

You can file an amended Form 990-BL only for tax years 2020 and earlier. For later years, corrections must be submitted using Form 990.