SECTION 1. PURPOSE

This revenue procedure grants certain applicable entities under section 6417(d) (1)(A) of the Internal Revenue Code (Code) ¹ an automatic six-month extension of time to file an original or superseding Form 990-T, Exempt Organization Busi- ness Income Tax Return (and proxy tax under section 6033(e) of the Code), with any other relevant schedules and forms (such as Form 3800, General Business Credit, and any relevant source credit forms), to make an elective payment election as provided under section 6417(d)(3) and §1.6417-2(b) (elective payment election). This automatic six-month extension,

described in section 3 of this revenue procedure, means that certain applicable entities that did not timely file an extension on Form 8868, Application for Extension of Time To File an Exempt Organization Return, will nevertheless be granted an automatic six-month extension of time to file a Form 990-T for purposes of making an elective payment election. Taxpayers are not required to file a Form 8868 to receive the extension provided in this guidance.

Section 4 of this revenue procedure allows applicable entities to make the elective payment election on a paper-filed Form 990-T if they follow the procedural requirements of section 4.03 of this revenue procedure. The IRS strongly encourages electronic filing of returns to ensure more efficient processing of elective payment elections.

Section 5 of this revenue procedure provides procedures allowing for assistance on processing an elective payment election for applicable entities that are otherwise eligible for the relief in section 3 but receive a notice from the Internal Revenue Service (IRS) that their elective payment election was ineffective because the return on which it was made was filed after the due date of the return.

This relief is being granted for certain applicable entities making elective payment elections in the first year such elections are available because the Department of the Treasury (Treasury Department) and the IRS are aware that many applicable entities were unfamiliar with the filing and extension process with respect to Form 990-T. Further, many applicable entities have been unable to make an elective payment election on a timely, electronically-filed Form 990-T because of limitations in electronic filing capabilities of third-party return preparers.