April 2, 2025
Kentucky and West Virginia Nonprofits Get Extended Deadlines
The IRS extended filing deadlines for nonprofits in all of Kentucky (IRS notice KY-2025-02, February 2025) and Boone, Greenbrier, Lincoln, Logan, McDowell, Mercer, Mingo, Monroe, Raleigh, Summers, Wayne, and Wyoming counties in West Virginia (IRS notice WV-2025-02, February 2025) due to severe storms, winds, flooding, and landslides starting February 14 and 15, 2025.
Nonprofits with deadlines from February 14/15, 2025, to November 3, 2025, now have until November 3, 2025, to file Form 990 (normally due May 15, 2025, for calendar-year organizations), quarterly payroll/excise tax returns (due April 30, July 31, or October 31, 2025), and estimated tax payments (due April 15, June 16, or September 15, 2025).
Penalties for late deposits from February 14/15 to March 2/3, 2025, are abated if paid by March 2/3.
Use FEMA 3624-EM (Kentucky) or 3625-EM (West Virginia) for loss claims.
Read the Kentucky IRS News Release
Read the West Virginia IRS News Release
What Does This Mean For Your Charitable State Registrations?
Many states will offer a special extension to align with the additional time granted by the IRS. To receive this extension, a request should be submitted to each state, referencing the IRS announcement of the extended deadline.
Additional Context and Notes
- Scope of Relief: The IRS provides automatic filing and payment relief under Section 7508A for nonprofits with an IRS address of record in FEMA-designated disaster areas. This includes:
- Form 990 series (annual information returns for tax-exempt organizations).
- Quarterly payroll/excise tax returns (e.g., Forms 941, 720).
- Estimated tax payments for 2025.
- Other time-sensitive actions listed in Rev. Proc. 2018-58 (e.g., Form 5500 for employee benefit plans).
- Exclusions: Payments for 2023 returns with valid extensions (due October 15, 2024) are not eligible for additional time, as they were due before the disaster periods. Information returns (e.g., W-2, 1099 series) and employment/excise tax deposits are not covered unless specified.
- Loss Claims: Nonprofits with uninsured or unreimbursed disaster losses can claim them on 2024 or 2023 returns, using the appropriate FEMA declaration number. The election must be made by October 15, 2025, for individual taxpayers, per IRS Publication 547.
- State Tax Relief:
- Kentucky: The Kentucky Department of Revenue honors IRS relief for state returns, extending deadlines to November 3, 2025
- West Virginia: Check state revenue websites for specific guidance, as state relief may align with IRS extensions but varies by jurisdiction.
- Compliance Tips:
- Nonprofits should verify their IRS address of record matches the disaster area to receive automatic relief. If not (e.g., due to a recent move), contact the IRS at the number on any penalty notice to request abatement.
- File electronically at irs.gov for efficiency, and include the relevant FEMA number on loss claims.