Form 8868: When does six-month extension apply? | KPMG | US
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Form 8868: When does automatic six-month extension apply?

Form 8868: When does six-month extension apply?

The IRS recently released a revised Form 8868 reflecting an automatic six-month extension of time to file as required by “Highway Bill” of 2015.


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Read Form 8868 (rev. January 2017), Application for Extension of Time to File an Exempt Organization Return.

Previously, exempt organizations qualified for an automatic three-month extension and could request an additional three-month extension, granted at the IRS’s discretion. This was revised by a provision of the Surface Transportation and Veterans Health Care Choice Improvement Act of 2015 (the “Highway Bill”). 

The new automatic six-month extension affects taxpayers filing the following returns for tax years beginning after December 31, 2015:

  • Form 990
  • Form 990-EZ
  • Form 990-PF
  • Form 990-T
  • Form 990-BL
  • Form 4720
  • Form 1041-A
  • Form 5227
  • Form 6069
  • Form 8870

KPMG observation

This recent form release may create uncertainty as to whether taxpayers may use the recently revised Form 8868 for tax years beginning before January 1, 2016. However, in informal conversations with KPMG tax professionals, IRS officials have suggested that taxpayers need to continue to use the prior Form 8868 (rev. January 2014) for such tax years. 

Filing guidance for tax years beginning before January 1, 2016

In requesting an extension of time to file an exempt organization return for a tax year beginning before January 1, 2016, taxpayers are to follow the procedures previously in place and request an automatic three-month extension on the prior version of Form 8868 (rev. January 2014). Taxpayer that need additional time may request an additional three-month extension.


For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Greg Goller | +1 703 286 8391 |

Alexandra Mitchell | +1 202 533 6078 |

Randall Thomas | +1 202 533 3786 |

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