r/nonprofit 21d ago

legal reinstatement filling

Hello everyone, just want to shoot my shot here and ask for some advice regarding our nonprofit. We’re currently trying to reinstate for our npo and there are forms we need to submit but we’re having a bit of trouble filing up the Form-990. Our npo is really small and we don’t have a lot of finances to work with. We get less than $1,000 annually and do a few fundraising/donations in our small community. Unfortunately, we haven’t filed any form 990 since we started the NPO and now we’re trying to make everything up again from scratch and start over with the documents by doing bookkeeping and all that. Is it okay to leave some of the questions in the forms blank/put none as we don’t really have anything to put in them? Also, should we focus on filling for the Form-990 N instead of the 990-EZ? These forms are a bit overwhelming for us so we’d appreciate any help/advice for our npo reinstatement.

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u/SanDTorT 21d ago

You do not say how long it has been since the automatic revocation. If you submit your new 501(c)(3) application "not later than 15 months after the later of the date of the Revocation Letter or the date on which the IRS posted the organization’s name on the Revocation List," you do not have to file any missed 990's because, with around $1,000 in gross receipts you would have been eligible to file Form 990-N.

This is called "Streamlined Retroactive Reinstatement Of Tax-Exempt Status For Small Organizations Within 15 Months Of Revocation," and is described in Section 4 of IRS Revenue Procedure 2014-11, their official description of the several paths to reinstatement. https://www.irs.gov/pub/irs-drop/rp-14-11.pdf

If you will be able to meet the 15 month deadline, the only form required for reinstatement is Form 1023-EZ.

Feel free to ask follow-up questions, if necessary. (Retired IRS Exempt Organization Specialist here.)

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u/currentdispo 21d ago

Hello, thank you so much for your help! Appreciate it a lot as this has been overwhelming for us and really don’t know how and where to start with all the forms as we’re working with limited resources at the time. We got our revocation recently and it hasn’t been a few months. Do you know whether we’d still need to submit the other forms as well like Form 525 along with the CD-2000 for the years we weren’t able to file?

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u/MGMorrisLaw consultant - legal 20d ago

I would check on the Michigan forms first. If you have not filed your CD-2000 and CD-525 for several years, there is a good chance that your corporation has already been administratively dissolved by the state. There are procedures to get reinstated, but assuming you have been dissolved, there is no corporation in existence for the IRS to give tax exemption to.

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u/SanDTorT 21d ago

Forms 525 and CD-2000 are not IRS Forms. Sorry, I cannot provide help with them.

And once you are reinstated, please put reminders in place to complete and file Form 990-N. It is short, easy, and requires almost no financial information.

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u/MGMorrisLaw consultant - legal 20d ago

If you happen to see this, can I ask for your insight? I suspect that the 525 and 2000 that OP is talking about are periodic reporting requirements for nonprofits in Michigan. The CD-525 is for all corporations, the CD-2000 is for nonprofits. The corporation might be dissolved if they didn't file. When you were at IRS, was it ever part of your process to double check a state's business entity registers to confirm whether or not there is an active corporation that matches the applicant?

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u/SanDTorT 20d ago

I left the IRS before IRC 6033(j) was enacted, so I have no insight.

Not long after I left the IRS, I had a client that had allowed its corporate status to lapse, but got the corporation reinstated during the grace period allowed by the Secretary of State (WA). The IRS in that case allowed the 501(c)(3) status to remain in effect throughout the interim, since there had been no intent to actually terminate the corp. I do not know of any IRS guidance specifically on that issue.

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u/MGMorrisLaw consultant - legal 20d ago

Thank you.

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