Automatic Exemption Revocation for Non-Filing: Organization Must File Annual Returns While Reinstatement Pending
My organization has applied for reinstatement of its tax-exempt status. Am I required to start filing annual returns?
An organization that is eligible to submit an annual electronic notice (Form 990-N) because its annual receipts are normally $50,000 or less is not required to submit Form 990-N until after its application for reinstatement of tax-exempt status has been approved. An organization seeking reinstatement of its tax-exempt status that has a filing requirement and is not eligible to file a Form 990-N must file an annual information return (Form 990, Form 990-EZ or Form 990-PF) for each taxable year that ends while the application for reinstatement is pending. The organization should check the “application pending” block on the top of page 1 of the return. For more information about filing requirements while an application for exemption is pending, see Publication 557, Tax-Exempt Status for Your Organization.
Certain larger organizations seeking retroactive reinstatement must submit with their applications for reinstatement all delinquent annual information returns beginning with the first year of the three-year period for which they were automatically revoked. For more information, see Notice 2011-44.
For a limited time, small organizations are eligible for transition relief to satisfy the standard for reasonable cause if they meet the criteria in Notice 2011-43.
