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June 30 Fiscal Year End Date Will Trigger Form 990 Deadline for Many Organizations

If your nonprofit's fiscal year ended June 30, it would behoove you to verify that it is compliant with IRS reporting requirements. As we've noted previously, the Pension Protection Act of 2006 requires the IRS to revoke automatically the tax-exempt status of any organization required to file an annual information return (IRS Form 990-N, 990-EZ, 990, or 990-PF) that fails to do so for three consecutive years.

The deadline for filing Form 990 and its variants is determined by the end of the filing organization's fiscal year. The filing deadline for a nonprofit whose fiscal year ended June 30, 2010, is November 15, 2010.

"The first time the revocation provision of the Pension Protection Act was put in effect was last May, when returns for organizations whose fiscal year ended December 31, 2009, were due," said Bob Ottenhoff, GuideStar's president and CEO. "We learned then that thousands of nonprofits, particularly smaller ones, did not realize they needed to file and were at risk of losing their exemptions. That's why GuideStar created a nonprofit resource center about the revocations. Nonprofits can use the resource center to stay up to date on what they must do in terms of filing an annual information return."

An organization's annual gross revenue and assets determine which version of the 990 it must file. Filing extensions are available for Forms 990-EZ, 990, and 990-PF, but not for Form 990-N [note: the filing thresholds have changed since this post was written. The new thresholds are posted on the IRS website]:

Exempt Organization Return Filing Requirements and Extensions for Tax Years Beginning in 2009
Financial Activity Form Extensions
Gross receipts normally < or = $25,000 990-N
Note: Organizations eligible to file the 990-N may choose to file a 990-EZ or 990 instead
None for the 990-N; available for the 990-EZ and 990
Gross receipts < $500,000 and
Total assets < $1.25 million
Note: Organizations eligible to file the 990-EZ may choose to file the 990 instead
Available for both the 990-EZ and 990
Gross receipts > or = $500,000, or
Total assets > or = $1.25 million
990 Available
Private foundation (regardless of financial activity) 990-PF Available

GuideStar's nonprofit resource center provides an overview of the revocations issue and several quick links, including ones to a Form 990-N filing status database, the mechanics of filing Form 990-N, filing exceptions, filing thresholds, filing deadlines and extensions, and IRS and GuideStar revocation FAQs. The resource center is updated as new developments related to the revocations occur.

"We hope every exempt organization will use these resources to ensure that they are not at risk of losing their exemptions for failure to file an annual return," Ottenhoff said. "Nonprofits play vital roles in our society, and losing tax-exempt status will hurt not only the organizations but also the causes and people they serve."

Suzanne E. Coffman, July 2010
© 2010, GuideStar USA, Inc.

Suzanne Coffman is GuideStar's director of communications and editor of the GuideStar Newsletter.

Topics: Policy