The Form 990-N is an electronic form that can be completed quickly by eligible tax-exempt organizations in lieu of the more extensive Form 990 annual information returns. Also called the e-Postcard, the Form 990-N takes just minutes to complete and doesn’t require professional tax preparation.
This article explains which exempt organizations are eligible to file Form 990-N, what information it requires, how to file, and what to expect after filing.
What information does the Form 990-N require?
The IRS Form 990-N is an annual electronic reporting for certain small, tax-exempt organizations. Instead of filing a Form 990-EZ or Form 990, eligible organizations provide the following organizational information:
1. Legal Name and mailing address;
2. Tax year;
3. Employer Identification Number (EIN);
4. Website address (if desired);
5. Name and address of the principal officer;
6. Affirmative response that gross receipts for the reporting fiscal year are normally less than $50,000 (explained in more detail below); and
7. Notice of termination (if applicable).
What organizations are eligible to file a Form 990-N?
Most tax-exempt organizations with annual gross receipts of $50,000 or less are eligible to file Form 990-N. Gross receipts include all funds received during the organization’s fiscal year from all sources, before subtracting any expenses.
The IRS considers an organization’s gross receipts to be normally $50,000 or less if the organization:
1. Has been in existence for 1 year or less and received, or donors have pledged to give, $75,000 or less during its first tax year;
2. Has been in existence between 1 and 3 years and averaged $60,000 or less in gross receipts during each of its first two tax years; or
3. Is at least 3 years old and averaged $50,000 or less in gross receipts for the last 3 tax years (including the year for which calculations are being made).
What organizations are NOT eligible to file a Form 990-N?
Some organizations are ineligible to file a Form 990-N even if their gross receipts are normally $50,000 or less. These include:
1. Private foundations,
2. § 509(a)(3) supporting organizations, and
3. § 527 political organizations.
A full list of ineligible organizations is available on the IRS website.
When is the Form 990-N due?
Form 990-N is due by the 15th day of the 5th month after the close of an organization’s tax year. For example, an organization with a tax year ending on December 31 should submit Form 990-N by May 15 of the following year. An organization may not file an extension for a 990-N.
Organizations that do not file their e-Postcard on time will receive a reminder from the IRS. Notably, no late-filing penalty will result for Form 990-N filed after the deadline. Keep in mind, however, that failing to file for three consecutive years will results in the automatic revocation of tax-exempt status. Auto-revoked organizations must affirmatively apply for reinstatement of exemption.
How does an organization file a Form 990-N?
Organizations may submit the 990-N through the IRS’s Form 990-N Electronic Filing System. The IRS publishes a user guide for the Form 990-N Electronic Filing System, available here. Note that online access to the IRS filing system requires Login.gov or ID.me sign-in, which can be established while creating an account. Information on how to file is important to maintain among organizational leaders, particularly for effective filing in subsequent years.
Can an organization file Form 990-N for a prior tax year?
Yes, organizations can file a Form 990-N for a prior tax year, but the IRS does not accept most late returns directly. Instead, organizations must use an IRS-approved third-party e-file service provider.
To build on the above example regarding timing, if an organization missed the Form 990-N deadline for tax year 2023, it cannot file a Form 990-N for that tax year in 2025. Only the Form 990-N for tax year 2024 can be filed during tax year 2025, and anytime during 2025 will be sufficient (although satisfying the deadline is a best practice). Organizations that have non-calendar fiscal years may face some additional complexity timing-wise, for which further evaluation may be appropriate.
What if an organization files 990-N but is not eligible to do so?
If an organization files Form 990-N when it is not eligible to do so—for example, because its annual gross receipts exceed the $50,000 threshold or it otherwise must file Form 990 or 990-EZ—the IRS does not treat the 990-N as a valid return. Tax-exempt organizations have a duty to file a complete and accurate return each year; submitting the wrong Form 990 version can result in the organization being considered as having failed to file altogether.
The consequences of failing to file the required return include IRS monetary penalties and, more significantly, the potential automatic revocation of tax-exempt status if the organization fails to file a correct return for three consecutive years.
Are Form 990-N returns available to the public?
Yes. Under the Taxpayer First Act, all electronically filed Form 990 returns are public. The IRS posts them on its Tax Exempt Organization Search website.
Exempt organizations must also make their Form 990-series returns available upon request for a three-year period beginning with the due date of the return.
What happens after filing a Form 990-N?
The IRS does not send a confirmation email after a Form 990-N is filed. Consequently, it can be helpful to maintain a PDF of the Form 990-N e-filing upon submission. Additionally, to verify receipt, organizational leaders can log into the Form 990-N Electronic Filing System and check their filing status there. Once submitted, Form 990-N cannot be amended. Correct information can be filed in a subsequent year’s 990 filing. In certain limited cases, such as for the organization’s address, an organization may update the information through an alternate form.
Conclusion
For eligible small nonprofits, the Form 990-N is a fast, no-cost way to fulfill the IRS’s annual filing requirement. If you have any questions or would like to verify your eligibility to file a Form 990-N, reach out to a member of our Federal Tax group.
