What IRS Form 990-BL (2025) Is For

IRS Form 990-BL (2025) was initially used by Black Lung Benefit Trusts—special tax-exempt organizations created under Section 501(c)(21) of the Internal Revenue Code. The form served as both an information return and an initial excise tax return, reporting the trust’s income, contributions, and payments made on behalf of coal miners affected by black lung disease.

Its purpose was to help the IRS monitor compliance with rules that limit how trust funds are used and ensure proper calculation of any excise tax due on prohibited transactions or self-dealing. However, Form 990-BL became obsolete after the 2020 tax year. Beginning with 2021, all 501(c)(21) trusts must file Form 990 or, if gross receipts are $50,000 or less, Form 990-N (e-Postcard) instead. This change aligns Black Lung trusts with other tax-exempt organizations' filing requirements.

When You’d Use Form 990-BL

Form 990-BL applies only to pre-2021 tax years and is no longer valid for current filings. However, some circumstances still require its use:

• A late or amended return must be filed for a tax year before 2021, when Form 990-BL remained active.
  
  
• The IRS issues a notice referencing an unfiled or missing 990-BL return from earlier years.
  
  
• A historical filing needs correction to update previously reported income, contributions, or expenditures.
  
  
• An IRS transcript request made with Form 4506-T confirms whether older returns are incomplete.
  
  
• During the transition to current filing rules, all Black Lung Benefit Trusts must use Form 990 or Form 990-N (e-Postcard) for 2025 and later to maintain compliance and prevent penalties.

Key Rules or Details for the 2025 Tax Year

For the 2025 tax year, IRS Form 990-BL is officially obsolete and cannot be used by any organization. All Black Lung Benefit Trusts must follow updated filing procedures that align with other tax-exempt organizations under Section 501(c)(21).

Filing Requirements for 2025

1. Use Form 990 for standard trusts: Organizations with annual gross receipts over $50,000 must file Form 990, which contains exempt organizations' main information and tax returns.
   
   
2. File Form 990-N (e-Postcard) for small trusts: Trusts with $50,000 or less in gross receipts can file the shorter e-Postcard version to satisfy annual reporting requirements.
   
   
3. Submit Form 6069 if excise taxes apply: This form is required when prohibited expenditures or self-dealing transactions occur, as outlined under IRS Sections 4951–4953.
   
   
4. File electronically: The IRS requires electronic filing for all Form 990 submissions, ensuring timely processing and confirmation of receipt.

These rules help trusts maintain IRS compliance, avoid unnecessary penalties and interest, and efficiently meet federal tax-exempt filing requirements.

Step-by-Step (High Level)

1. Check filing history and deadlines: Verify each date and month on IRS transcripts to learn which returns were received and which remain missing; this step is essential for every individual, business, and partnership trustee.
   
   
2. Confirm eligibility and form type: Determine whether you qualify for Form 990-N or must file Form 990; different types of trusts and corporations follow the same law but use whichever form the rules require.
   
   
3. Gather records: Collect governing documents, officers and directors listings, financial activities, and support for credits, costs, payments, and any refund you might receive.
   
   
4. Choose the correct schedules: Review the instructions and refer to the schedule list to match the types of activity; include schedule items even when the amounts are less than in prior years.
   
   
5. Prepare and e-file: Visit IRS-approved providers to file your tax return, sign electronically, and provide the required number identifiers for entities and individuals.
   
   
6. Calculate amounts due: Carefully calculate any underpayment and related charges, penalties, and interest if filing late; amounts may be multiplied when a filer fails to comply on time.
   
   
7. Address state considerations: Check whether your state also requires updates for exempt businesses or corporations following federal changes.
   
   
8. Keep proof: After filing, visit your account to confirm acceptance, save acknowledgments, and retain records; add notes (for example, “filed in August”) to honor internal controls and future reviews.

Common Mistakes and How to Avoid Them

Many errors with Form 990 filings happen because organizations overlook essential but straightforward details. Avoid these issues to keep your income tax records accurate and prevent unpaid or penalty notices.

• Missing the due date: Late filings can lead to penalties and interest, increasing the balance owed. Always note the IRS due date and file early.
  
  
• Incomplete information: Every return must include all supporting documents, such as financial statements and descriptions of significant activities for the year.
  
  
• Using the wrong form: Do not submit the obsolete short form or Schedule C for other S corporations or entities; Black Lung Benefit Trusts must use Form 990 or 990-N.
  
  
• Failing to calculate and pay estimated tax: If excise taxes apply, ensure the amounts are calculated accurately and that payment is submitted promptly to the IRS.
• Overlooking smaller entries: Even lesser figures must be reported to complete the filing and maintain accurate compliance records.

What Happens After You File

After filing Form 990 or Form 990-N, the IRS issues an electronic acknowledgment, often shown with a locked padlock icon, confirming secure submission. Depending on the organization's size and attachments, the agency usually reviews returns within a few months. If the IRS identifies errors or unpaid tax, it will send a notice explaining the essential steps to resolve the issue. Penalties and interest may apply if payment or response is delayed. Always keep copies of all filings, confirmations, and correspondence to maintain accurate records and simplify future tax return reviews or audits.

FAQs

Can I file Form 990-BL for 2025?

No, Form 990-BL is no longer accepted for 2025 or later years. Black Lung Benefit Trusts must file Form 990 or Form 990-N (e-Postcard) instead, depending on annual gross receipts.

Do I need to pay estimated tax for a Black Lung Benefit Trust?

Generally, Black Lung Benefit Trusts do not make quarterly estimated tax payments like individuals or corporations. However, if excise taxes or other liabilities apply, those amounts must be reported and paid on time to avoid penalties.

Does Schedule C apply to Form 990-BL filings?

No, Schedule C is designed to report political or lobbying activity by other organizations. Black Lung Benefit Trusts should follow the schedules listed in the instructions on Form 990 instead.

What penalties and interest apply for late or incorrect filing?

Late or inaccurate returns can trigger penalties and interest ranging from $20 to $120 per day, depending on trust size. Filing on time and correcting errors quickly helps reduce these costs.

Does Form 990-BL involve income tax reporting?

No, Form 990-BL was an information return, not an income tax return. It reported activities and compliance for Black Lung Benefit Trusts rather than general taxable income.