IRS Provides Procedures For Retroactive Reinstatement Of Section 501(C)(3) Status

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Code Section 6033(j) provides for the automatic revocation of Section 501(c)(3) status for organizations that fail to file the requisite annual returns or notices for three years. Despite IRS warnings of its intent to implement such revocations, many organizations did not get the message and have suffered such revocations.

Rev.Proc. 2014-11 now provides for mechanisms to obtain retroactive reinstatement of tax-exempt status. The procedures generally involve submitting a new Form 1023 and user fee, and filing missing returns. If the procedures are complied with, status will be restored retroactively and no penalties imposed for the late/missed annual returns. The Revenue Procedure also describes how to apply for non-retroactive reinstatement (which presumably will be undertaken mostly by those that do not otherwise qualify for retroactive reinstatement.

A mindmap that summarizes the various alternative mechanisms and other aspects of these filings is available online at this link (hint: click the icon in the upper right hand corner of the map with two arrows on it to view the map full screen).

Rev.Proc. 2014-11, 2014-3 IRB