Which Return, and When

Who files what

• “Gross receipts” means everything received from all sources during the year with nothing subtracted — contributions, program revenue, investment income, gross proceeds of sales and events. [Final Q16, A; marked] Heading Item G is the sum of Part VIII lines 6b, 7b, 8b, 9b, 10b and 12. “Normally” is a three-year average for the $50,000 test.
• 990-N (the e-Postcard): gross receipts normally $50,000 or less. Eight data items and a certification; no paper version; filed on IRS.gov through Login.gov or ID.me (the course’s Urban Institute system is gone) updated 2026. A 990-N filer may always file an EZ or a 990 instead. Political organizations may not use it. There is no amended 990-N. [Final Q18, D; marked]
• 990-EZ: gross receipts under $200,000 and total assets under $500,000 at year-end. Four pages, the same Schedules A, B, C, E, G, L, N and O. Not available to DAF sponsors or hospitals. (c)(3)s complete its Part VI: line 47 lobbying and the §501(h) election, line 48 schools, lines 49a–b transactions with non-(c)(3) exempts, line 50 the five highest-paid employees over $100,000, line 51 the five highest-paid contractors over $100,000.
• 990: everyone else, and anyone who chooses it. Twelve-part core plus Schedules A–R as Part IV directs.
• 990-PF: every private foundation and every §4947(a)(1) trust treated as one, regardless of size. A non-foundation §4947(a)(1) trust files the 990 or EZ as if it were a (c)(3), and if it has no taxable income that return satisfies its Form 1041 obligation.
• Other sections: §527 political organizations file a 990/EZ if gross receipts are $25,000 or more ($100,000 for a qualified state or local political organization); §501(c)(7) clubs and (c)(15) insurers use the ordinary thresholds for whether to file but a different gross-receipts definition for whether they are exempt (Appendix C of the instructions); (c)(21) black-lung trusts file the 990 series since 2021; §501(d) religious and apostolic organizations file Form 1065; §401 plans file Form 5500. Foreign organizations file in U.S. dollars and English.
• Application pending or not yet filed: file anyway, Item B “Application pending,” all parts and schedules completed. Don’t wait for the letter — the three-year clock is running.
• Group returns: a central organization under a group exemption letter may file one 990 for subordinates that are affiliated, under its supervision, covered by the letter and on its tax year; each subordinate authorizes inclusion in writing every year; the parent files its own 990 separately and may not use an EZ for the group. The IRS stopped accepting new group exemption requests in June 2020 (Notice 2020-36) and reopened the program on January 20, 2026 under Rev. Proc. 2026-8: requests go in electronically on Form 8940 through Pay.gov, a central organization may hold only one group letter, subordinates must be under the same §501(c) paragraph, at least five are needed to start, and existing group letters have until January 22, 2027 to conform. Letter 4953 and the Form 14414 questionnaire are still not to be ignored. updated 2026

Who need not file at all

• Religious: churches, interchurch organizations, conventions or associations of churches, and integrated auxiliaries (Reg. §1.6033-2(h)) — men’s and women’s groups, religious schools, mission societies, youth groups; church-affiliated organizations that only manage funds or retirement programs (Rev. Proc. 96-10); schools below college level affiliated with a church or run by a religious order (Reg. §1.6033-2(g)(1)(vii)); mission societies more than half of whose work is abroad; the exclusively religious activities of a religious order (Rev. Proc. 91-20). These are still subject to the 990-T at $1,000 of unrelated income.
• Governmental: §115 state institutions; governmental units and affiliates under Rev. Proc. 95-48; §501(c)(1) federal instrumentalities. A governmental unit that is also a §509(a)(3) supporting organization still files.
• Political: state and local party committees, state and local candidate committees, caucuses of state and local officials, and committees that report to the FEC.
• So the Red Cross and Habitat for Humanity file; a convention of churches, a state party committee, a §115 institution, a religious-order grade school and a caucus of officials do not. [Final Q24, A; Q27, D; marked]

Due dates, extensions, e-filing, amended and final returns

• Due the 15th day of the 5th month after the accounting period ends; next business day for a weekend or holiday; same rule measured from the date of liquidation or dissolution for a final return. [Final Q19, B; marked]
• Form 8868: automatic six-month extension for the 990, 990-EZ, 990-PF, 990-T (corporate filers; three months for trusts) and 4720. The 990-N has no extension because it has no penalty — but it counts toward the three strikes.
• Mandatory e-filing for every 990-series return and the 990-T under the Taxpayer First Act (990 and 990-PF for years ending after July 30, 2020; 990-EZ a year later; 990-T from 2021; 4720 from 2022). Only the current year and the two prior years can be e-filed; an older original or amended return is paper. A short-period return other than an initial or final return cannot be e-filed. [Final Q21, D; marked]
• The accounting method is the book method, except where a part of the return prescribes its own (compensation on a calendar-year W-2 basis in Part VII). A change of method is Form 3115 (automatic consent under Rev. Proc. 2015-13 for listed changes), except a change to conform to ASC 958 (Notice 96-30). A state that requires accrual may be given the accrual return, and the same accrual return may go to the IRS so long as it does not conflict with a specific instruction; keep the book-to-return reconciliation on Schedule D, Parts XI–XII if the financials are audited.
• A change of accounting period: a short-period 990 marked “Change of Accounting Period”; Form 1128 if the period was changed within the last ten years and a 990 was filed in that time (Rev. Proc. 85-58).
• Amended: a complete new return with everything, “Amended return” checked in Item B, and Schedule O listing the parts, lines and schedules changed. Check whether the state wants it too. [Final Q25, C; marked] Final: “Terminated” in Item B, Schedule N, and a certified copy of the articles of dissolution or the board resolution.

Penalties

• §6652(c)(1)(A), late or incomplete return, 2026 amounts (Rev. Proc. 2025-32): $25 a day up to the lesser of $13,000 or 5% of gross receipts; for organizations with gross receipts over $1,339,500, $130 a day up to $66,500. For 2025 returns: $25 / $12,500 and $130 / $65,000 over $1,309,500. The course and the exam had $20 / $10,500 and $105 / $54,500 over $1,094,500. [Final Q17, B; marked; figures updated] updated 2026
• Responsible person (§6652(c)(1)(B)): after a written IRS demand with a deadline, $10 a day up to $6,500 per return on all persons together for 2026 returns (the statute says $5,000; it is indexed under §6652(c)(7)); willful failure brings more. updated 2026 §6685: $5,000 per document for willfully refusing public inspection, on top of the daily penalty.
• Abatement: a signed statement under penalties of perjury attached to the return explaining why late or incomplete, why no extension was requested, how ordinary business care was exercised, and what stops it happening again. First-time abatement is available if there were no penalties for the three prior years, all returns are filed or extended, and any tax is paid or arranged. Most small-charity penalties are abated on a decent first-time request; ask.
• Incomplete is late: a return missing a required schedule, or with “see attached” where an answer belongs, draws the same daily penalty until completed.

Automatic revocation

• §6033(j): fail to file the required 990, 990-EZ, 990-PF or 990-N for three consecutive years and exemption is revoked by operation of law on the due date of the third return. No notice is required first; the organization gets a CP120A letter afterward and goes on the Auto-Revocation List in TEOS. It is taxable from the revocation date, contributions stop being deductible from the date of the public listing, and Colorado will eventually follow. [Final Q13, C; marked]
• Churches are the only large class this cannot happen to, because they have no filing requirement. Everyone else — including (c)(4)s, (c)(6)s and (c)(7)s that never applied — is on the clock from the day they are formed.
• The remedy is a new application (1023, 1023-EZ, 1024 or 1024-A) with the user fee, choosing one of the four routes of Rev. Proc. 2014-11 on Schedule E of the 1023 (Part V of the EZ, Part VI of the 1024-A). The practical first question: was the organization eligible for the 990-EZ or 990-N for all three missed years, and are we within 15 months of the later of the CP120A or the list date?

The four ways back (Rev. Proc. 2014-11)

• 1. Streamlined retroactive (Schedule E, Section 4): eligible for the EZ or N for all three years, never previously auto-revoked, application postmarked within 15 months of the later of the CP120A date or the list date. Reinstated to the revocation date; no reasonable-cause statement; no §6652(c) penalty for the three years if 990-EZs marked “Retroactive Reinstatement” are filed for any year the organization was not 990-N-eligible (paper, to Ogden). For a 990-N-size organization nothing at all is owed for the missed years. This is the route for almost every booster club, PTO and little church auxiliary that walks in.
• 2. Retroactive within 15 months (Section 5): required to file a 990 or 990-PF for any of the three years, or revoked before. Application within 15 months; a reasonable-cause statement for at least one of the three years; a statement that all required returns for the three years and any later years are filed; the back returns on paper marked “Retroactive Reinstatement.” No penalty for the three years.
• 3. Retroactive after 15 months (Section 6): same, but the reasonable-cause statement must cover all three years.
• 4. Post-mark date (Section 7): exempt again from the postmark date of the new application; nothing else required. The gap years are taxable (Form 1120 or 1041) check, and contributions in the gap were not deductible.
• Reasonable cause (Rev. Proc. 2014-11 §8): that the organization exercised ordinary business care and prudence in determining and attempting to comply — the facts of why it failed, how it discovered the failure, and what it has done to prevent a recurrence. Reliance on a volunteer treasurer who left, a change of officers with no handoff, and ignorance of the 990-N requirement by a tiny organization have all worked in practice; a statement that just says “we didn’t know” is weaker than one that shows the new procedure (calendar reminder, named officer, preparer engaged).
• Paper 1024s (where still allowed) go to IRS, TE/GE Stop 31A Team 105, P.O. Box 12192, Covington, KY 41012-0192; back returns marked “Retroactive Reinstatement” go to IRS, Ogden, UT 84201-0027.

Public inspection and disclosure

• The exemption application (1023/1024 and everything filed with it, and the IRS correspondence), the last three annual returns (with schedules, except Schedule B donor names and addresses), and a (c)(3)’s Forms 990-T filed after August 17, 2006 must be open to inspection at the principal office during business hours and copies provided on request (same day in person, 30 days by mail, reasonable copying charge). Posting the documents on the organization’s own site or on a database site (Candid/GuideStar, ProPublica) in the exact form filed satisfies the copy requirement (Reg. §301.6104(d)-4(b)(2)) but not the inspection requirement; the 2025 instructions say keep physical copies at the office anyway. Applications filed before July 15, 1987 are exempt unless the organization still had a copy. [Final Q56, D; marked] updated 2026
• Redact before posting: Social Security numbers (the IRS says never put them on the 990 at all), and Schedule B names. The IRS itself publishes every e-filed 990 as machine-readable data, so assume everything but Schedule B is already public.
• Schedule B: all filers complete it (or certify “No” on Part IV line 2). Only §501(c)(3) and §527 organizations report names and addresses (T.D. 9898, Reg. §1.6033-2(a)(2)(iii)(D), replacing the course’s Rev. Proc. 2018-38); everyone reports amounts and noncash descriptions. Private foundations’ Schedule B is fully public. States may not demand it as a condition of registering — Americans for Prosperity Foundation v. Bonta, 594 U.S. 595 (2021), 6–3, struck California’s blanket Schedule B requirement under the First Amendment right of association. Colorado has never asked for it. [Final Q34, D; corrected to D in blue] updated 2026

Study questions 7–13

• Many of the Form 990 governance questions ask about practices not required by federal tax law; the IRS calls them best practices and hopes the organization adopts them. All organizations answer every Part VI question. [SQ 7, A; derived]
• A donor-advised-fund sponsor that must file files the full Form 990, never the EZ or N. [SQ 8, C; derived]
• Part III describes the three largest program services by expense. [SQ 9, B; derived]
• For Part III, charitable contributions are not revenue; fees, sales of related goods and exploited-function UBI are. [SQ 10, D; derived]
• The 990-EZ may not be filed by every exempt organization: under $200,000 of receipts and $500,000 of assets, and never by DAF sponsors or hospitals; it has up to eight schedules; an eligible filer may still file the 990; the five-highest-paid threshold is $100,000. [SQ 11, C; derived]
• The 990 does not require a whistleblower policy; it asks whether one exists. [SQ 12, D; derived]
• Filing the 990-N is not voluntary; three missed years ends the exemption. It is electronic only, carries basic data only, and does not substitute for an EZ or 990 when those thresholds are met. [SQ 13, C; derived]

Private reference, not client advice. Notes taken from a continuing-education course, Form 990: A Practical Guide (Thomson Reuters Checkpoint Learning, 12 hours, 2022 edition written on 2021 law and the 2021 forms). Figures and rules brought current to 2026 in October 2026 (P.L. 119-21, Rev. Proc. 2025-32, T.D. 9933, T.D. 9898, the 2025 form instructions). Items tagged check are to be confirmed against primary sources before they are relied on.