Demystifying IRS Form 990-BL: What Nonprofits Should Know

To maintain their tax-exempt status, nonprofits are required to file a Form 990 with the IRS; however, there are different variations of Form 990, so it’s important that you choose the right one.

If you’re using federal Black Lung Program benefits, you’ll need to use the 990 BL form. In this article, we’ll discuss all you need to know about Form 990 BL, including:

• What it is, who needs to file it, and when it’s due.
• The different elements of the form and how to file it.
• Best practices and common mistakes to avoid when filing a 990 BL form.

Let’s get started!

Before we get into the details about Form 990-BL, let’s take a step back and explain what Form 990 is.

Form 990 is a public document that tax-exempt organizations, nonexempt charitable trusts, and section 527 political organizations are required to file with the IRS annually.

In general, Form 990s provide information about an organization’s finances, governance, programs, and other compliance requirements so that they can maintain their tax-exempt status.

There are five different types of Form 990s, each with different requirements and purposes:

• Form 990
• Form 990-BL
• Form 990-EZ
• Form 990-N
• Form 990-T

In this article, we’ll be focusing on Form 990-BL specifically:‍
‍

Form 990-BL is used to meet reporting requirements for Black Lung Benefit trusts and certain related persons each year.

Form 990-BL is a three-page document that asks for basic information, including:

• Name of the trust
• Name and social security number of the person filing on behalf of the trust
• Mailing address
• Role of the person filing the claim

There is also an additional Schedule A form that you may be required to file if initial taxes are imposed on the trust or related parties.

Overall, Form 990-BL helps demonstrate that you are following the regulations set forth by the IRS, so it’s critical that you fill it out accurately. We will go over the different parts in more detail below.

In 1972, the U.S. government passed the Black Lung Benefits Act, which is a federal law that offers medical benefits and more to coal miners who are impacted by pneumoconiosis, or black lung disease, as a result of working in or around coal mines.
‍

If your organization benefits from the Black Lung Benefits Revenue Act, you may need to file this form at the end of the year as part of the trust’s reporting requirements.

A trustee from your organization must file the form 990-BL if your organization:

• Has 501(c)(21) status
• Meets the reporting requirements of section 6033 of U.S. Code 26
• Has a gross receipt of more than $50,000

If your organization has gross receipts of less than $50,000, you do not need to file this form, even if you receive benefits from the Black Lung Benefits Act.

The 990 BL form due date will vary from organization to organization. You should file it based on your trust’s annual accounting period, and it should be submitted on or before the 15th day of the 5th month following the close of your tax year.

What this means is if your fiscal year ends on December 31, then you’ll need to file no later than May 15. If this falls on a weekend or holiday, you can file by the next business day.

Trusts are required to file the 990 form BL annually, and you can locate the latest version of the 990 BL form on the IRS website.

In this section, we are going to walk through the various sections of the form to help you understand the information required to file it.

1. Enter Identifying Information

‍

There is basic information that you must fill out as you start the form. This includes:

• Calendar year or the fiscal year beginning and end dates (if different)
• Name of the trust
• Employer Identification Number (EIN) of the trust
• Name and social security number of the person filing the return
• Address, including city, state, and zip code

You must also select if your application is pending and if your address has changed, as well as enter the fair market value (FMV) of the trust’s assets at the beginning of the year.

2. Fill Out Part I: Analysis of Revenue and Expenses

‍

Part I consists of an analysis of your revenue and expenses. Enter information as applicable and total both at the end of each section. Then, in line 12, you’ll want to subtract your expenses from your revenue to find your excess.

3. Fill Out Part II: Balance Sheets

‍

Part II asks you to account for your assets throughout the year, so you’ll need to enter all information from the beginning and the end of the year, including any liabilities and net assets.

You will also need to include the name, phone, and address of who handles the books. Once you are done with this section, you’ll need to sign and date the form, as well as check if the IRS can discuss the return with the preparer.

4. Fill out Part III: Questionnaire

‍

You need to check yes or no to answer Part III’s questionnaire. This helps the IRS understand if there were organizational changes made throughout the year and determine if you need to fill out the Schedule A form.

You must also add the names, information, and salaries of your trust’s employees and total them up.

5. Part IV: Statement With Respect to Contributors

‍

While section IV will not be available for public inspection, you must disclose any contributions of more than $5,000 per taxable year. Select if you received contributions in excess of the maximum allowable deduction.

6. Fill out Schedule A (If Applicable)

‍

If excise taxes were imposed on any black lung benefit trusts, trustees, or disqualified persons under sections 4951 and 4952, you will need to file a Schedule A with your 990 BL form. This will help determine how much tax is due.

If you do not owe any taxes, you will not need to file a Schedule A.

The Form 990 BL must be filed via mail by sending it to the address below. At this time, it cannot be submitted electronically.

Department of the Treasury
Internal Revenue Service Center
Kansas City, MO 64999

You can get proof of the mailing date at the post office or through private delivery services.

Eligibility to File 990-BL Form

Organizations who gross more than $50,000 and receive benefits as part of the Black Lung Trust Act should file the 990-BL form. Additionally, the trusts must:

• Have 501(c)(21) status
• Meet the reporting requirements of section 6033

If you have a gross receipt of less than $50,000, you can file the Form 990.

Online Filing of 990-BL Form

Unfortunately, at this time, you are not able to file the form 990 BL online. You need to download the document from the IRS website here and file it via mail.

Deadline for Filing 990-BL Form

The deadline for filing the 990-BL form will depend on what your organization’s tax year is. It should be filed no later than the 15th day of the 5th month after the close of your fiscal year. You can file an extension if you need additional time to file your 990 BL form.

Consequences of Failing to File 990-BL Form

If you don’t file your 990-BL form, you will be subject to a fee of $20 to $105 per day depending on the size of your organization. The maximum penalty you can pay is $10,500 for small organizations, $53,000 for large organizations, or 5 percent of the gross receipts. You will pay whichever is the smaller amount.

Correction of Errors on the 990-BL Form

You could be subject to fines if you do not file correctly, so it’s critical that you file accurately.

Here are some best practices to keep in mind when filing the 990-BL.

Preparing the Necessary Information

Gather all your necessary documentation together, including your receipts, expenditures, revenue, and more. You also want to make sure you have your organization’s EIN, the filer’s SSN, and more. Having everything available will make it easier to fill out the 990-BL form.

Checking for Accuracy

Before you mail your filing, make sure to check that all the details are accurate. If it’s not, you may have to pay fines.

Additionally, parts of the form 990-BL will be publicly available. Others can see how the trust is allocating funds.

Ensuring Timely Submission

Make sure that you file well in advance of the deadline. Remember, the 15th day of the 5th month after your fiscal year ends. Failure to file in a timely manner could result in costly fines.

Keeping a Copy for Record-keeping

You’ll want to keep a file for your record, as well as proof of mailing. This can help if your submission gets lost in the mail.

Here are some common mistakes to avoid when you’re filing your Form 990-BL.

Filing With Incorrect Information

Take your time when filling out the form to ensure all information is accurate. You could accidentally have incorrect information on your form that could lead to fines if you’re not careful.

Late Filing

Filing late could cost you up to $53,000. If you need to, file an extension to avoid costly fees.

Not Filing at All

You are required to file this form as part of your reporting requirements, and if you do not, you will be fined and could lose your status or access to funds.

Incorrect Calculation of Gross Receipts

Because the type of form you file depends on your gross receipts, it’s critical that you have the right calculations. If you don’t, you could end up filing the wrong form and getting a follow-up from the IRS.

The 990 BL form is a critical tax document that’s required of organizations that receive funding as part of the Black Lung Act and gross more than $50,000 a year.

For more insight into Form 990s and their uses, check out this helpful guide.