Form 990, 990-EZ, 990-N, or 990-PF: Which One to File

Choosing the form

Organizations with gross receipts normally of $50,000 or less can usually file the Form 990-N e-Postcard. Those with gross receipts under $200,000 and total assets under $500,000 can file Form 990-EZ. Larger organizations file the full Form 990. Private foundations file Form 990-PF regardless of size.

Churches and certain related organizations are generally not required to file.

Deadlines

Returns are due by the 15th day of the fifth month after year-end, which is May 15 for calendar-year organizations. Form 8868 gives an automatic six-month extension, although the 990-N cannot be extended.

Consequences

An organization that fails to file for three consecutive years automatically loses its exemption. Late filing penalties can also apply.

Form 990 is a public document under Section 6104. Donors, grantmakers, and journalists read it, so the program descriptions and governance answers should be accurate and clear.

How gross receipts are measured

Gross receipts are total amounts received from all sources, without subtracting costs. A fundraising event that brings in $80,000 and costs $50,000 counts as $80,000 of gross receipts. This surprises many small organizations, because their net figure looks small.

For the Form 990-N, gross receipts are normally $50,000 or less, based on a measure that generally looks at the current and prior two years. For Form 990-EZ, the test looks at the current year's gross receipts and year-end assets.

What each form asks for

Form 990-N is a short electronic notice with basic identifying details. Form 990-EZ is a shorter return covering revenue, expenses, balance sheet, program accomplishments, and compensation.

The full Form 990 is far longer. It includes a summary page, a statement of program service accomplishments, a checklist of required schedules, governance questions, a compensation section, and financial statements. Its answers trigger additional schedules. Schedule A is required for public charities, Schedule B for many contributor disclosures, and Schedule O for narrative explanations.

Form 990-PF reports private foundation investment income, grants, and compliance with minimum distribution rules.

Electronic filing and practical preparation

Returns in the Form 990 series must generally be filed electronically, so organizations need to allow time to set up accounts and obtain data. A good preparation file includes the trial balance, audited statements, board minutes, a list of officers and key employees, and any changes to governing documents.

Reasonable functional expense allocations across program, management, and fundraising should be decided before the return is drafted. Executive compensation also needs review, particularly where related organizations pay part of it.

If exemption is revoked

The IRS publishes a list of organizations that lost exemption automatically. Once revoked, an organization may owe income tax, and donors can lose deductions for later gifts. An organization usually must apply for reinstatement, generally on Form 1023 or 1024, and can ask for retroactive treatment under Revenue Procedure 2014-11 in qualifying cases.

Related filings

Form 990-T is a separate return for unrelated business income, and a Form 990 does not replace it. Many states also require charitable solicitation registration and their own annual filings, and some accept a copy of the federal return.

A group of related organizations may be able to file a group return, for which the rules on who can be included should be reviewed each year. New organizations should still file in their first year, using estimated gross receipts for the Form 990-N test.

A preparer's checklist

Confirm the organization's exemption type and public charity status from its IRS determination letter. Then calculate gross receipts and year-end assets, and record which form applies for this year, because an organization can move between forms as it grows.

Check the due date and whether Form 8868 is needed, and confirm that the organization's name, address, and tax year match IRS records. Reconcile the return to the financial statements, and answer the schedule checklist carefully, since each yes can require a schedule.

Before filing, have an officer review the program descriptions, governance answers, and compensation data. Keep a copy available for public inspection, and confirm any Form 990-T and state filing requirements.

Frequently asked questions