Reinstating 501(c)(3) Status
A. Streamlined Retroactive
Reinstatement Process
(Within 15 months)
Reinstatement Process
(Within 15 months)
Who is eligible?
Eligible to file either Form 990-EZ or Form 990-N
Not previously had tax-exempt status automatically revoked
Submits application within 15 months of later of:
date of revocation letter
date IRS posts name on revocation list
Process
Submit new Form 1023
Submits user fee
Effect
Retroactive reinstatement
Deemed reasonable cause for failure to file annual returns
No failure to file penalty if late Forms 990-EZ file (or no filing
required if organization was eligible for Form 990-N filings)
required if organization was eligible for Form 990-N filings)
C. Retroactive Reinstatement Process
(Beyond 15 months)
(Beyond 15 months)
Who is eligible?
Submitting application more than 15 after revocation
Process
Submit new Form 1023
Submits user fee
Submits reasonable cause statement establishing failure to file for all three nonfiling years
Submits late paper annual returns for the missed years in the three year consecutive year period, and
statement that such returns were submitted
statement that such returns were submitted
Effect
Retroactive reinstatement
Deemed reasonable cause for failure to file annual returns
No failure to file penalty if late Forms 990-EZ file (or no filing
required if organization was eligible for Form 990-N filings)
required if organization was eligible for Form 990-N filings)
B. Retroactive Reinstatement Process
(Within 15 months)
(Within 15 months)
Who is eligible?
Not eligible for A. process
Submits application within 15 months of later of:
date of revocation letter
date IRS posts name on revocation list
Process
Submit new Form 1023
Submits user fee
Submits reasonable cause statement establishing failure to file for at least one of the three nonfiling years
Submits late paper annual returns for the missed years in the three year consecutive year period, and
statement that such returns were submitted
statement that such returns were submitted
Effect
Retroactive reinstatement
Deemed reasonable cause for failure to file annual returns
No failure to file penalty if late Forms 990-EZ file (or no filing
required if organization was eligible for Form 990-N filings)
required if organization was eligible for Form 990-N filings)
D. Nonretroactive Reinstatement Process
Organization can apply for reinstatement effective upon the submission date by filing an application and user fee
Misc.
Source: Rev.Proc. 2014-11
Author: Charles (Chuck) Rubin, Esq.
crubin@floridatax.com
rubinontax.blogspot.com
www.floridatax.com
crubin@floridatax.com
rubinontax.blogspot.com
www.floridatax.com