In an effort to provide relief in response to the COVID-19 Crisis, the IRS, NYS Charities Bureau and various other federal, state and private agencies announced filing deadline extensions for exempt organizations.
990 Extensions
The IRS and NYS Charities Bureau announced that all exempt organizations required to file Forms 990, 990-PF, 990-EZ, 990-N and 990-T on or after April 1 are extended until July 15, 2020. The extension is automatic and no action is required. If additional time is needed past July 15, 2020, an extension Form 8868 must be filed by July 15, 2020. The NYS Charities Bureau has also granted a six-month extension to file the CHAR500 report and related documents in addition to the previous six month extension granted. For example, an organization with a filing deadline of May 15, 2020 would be automatically extended to November 15, 2020 and with the additional extension, the filing is automatically extended to May 15, 2021.
Single Audit Extension
The U.S. Office of Management and Budget (OMB) issued a memorandum, Administrative Relief for Recipients and Applicants of Federal Financial Assistance Directly Impacted by the Novel Coronavirus (COVID-19). The memo provides a 6-month extension for companies that have a fiscal year end through June 30, 2020. No action is required for the 6-month extension to become effective.
Here is a link to a table for a summary of the GAQC deadline extensions by Federal Agency type.
Consolidated Fiscal Report Extensions
The following New York State Agencies have extended the due date of the January 1, 2019- December 31, 2019 Consolidated Fiscal Report from May 31, 2020 to August 1, 2020:
- Office for People with Developmental Disabilities (OPWDD)
- Office of Mental Health (OMH)
- Office of Alcoholism and Substance Abuse Services (OASAS)
- State Education Department (SED)
Fiscal year filers (July 1-June 30) are required to submit their CFR on or before December 1 of the same year.
Accounting Standards Extensions
FASB proposes to defer the effective date of ASU 2016-02, Leases. The proposed new effective date would be for fiscal years beginning after December 15, 2021 (December 31, 2022 and June 30, 2023 year ends).
Auditing Standards Extensions
The AICPA Auditing Standard’s Board decided to defer the effective dates of seven of its recently issued Statements on Auditing Standards because of the novel coronavirus.
The standards affected are:
SAS 134, Auditor Reporting and Amendments, Including Amendments Addressing Disclosures in the Audit of Financial Statements, as amended;
SAS 135, Omnibus Statement on Auditing Standards—2019;
SAS 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, as amended;
SAS 137, The Auditor’s Responsibilities Relating to Other Information Included in Annual Reports;
SAS 138, Amendments to the Description of the Concept of Materiality;
SAS 139, Amendments to AU-C Sections 800, 805, and 810 to Incorporate Auditor Reporting Changes From SAS No. 134; and
SAS 140, Amendments to AU-C Sections 725, 730, 930, 935, and 940 to Incorporate Auditor Reporting Changes From SAS Nos. 134 and 137.
The effective dates of the standards were for audits of private company financial statements for periods ending on or after December 15, 2020. The deferral means that effective dates now apply for periods ending on or after December 15, 2021.
For guidance relating to not-for-profit tax preparation, filing dates and extensions, contact Linda Gabor, CPA, CFE at 315.701.7933 or [email protected]. Visit our COVID-19 Website Page for additional updates and guidance on the coronavirus (COVID-19).
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