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Moreover, an organization seeking retroactive reinstatement must demonstrate that it had reasonable cause for failing to file a return or notice not only for each of the three years but also over the entire three-year period. An organization may establish reasonable cause by providing facts and circumstances showing it exercised ordinary business care and prudence in determining and attempting to comply with its reporting requirements for each of the three years and over the entire three-year period, but was nonetheless unable to file the required returns or notices for three consecutive years. The IRS will consider a request for retroactive reinstatement from an organization other than a small organization only if the organization submits a request for reinstatement with a properly completed and executed application for reinstatement within 15 months of the later of the date of the IRS revocation letter or the date the IRS posted the organization’s name on its revocation list available on the IRS website. The IRS recently launched an online search tool where users can check if an organization has had its federal tax exemption automatically revoked under the law for not filing a Form 990-series return or notice for three consecutive years (see “IRS Launches Online Search Tool for Tax-Exempts”).
Moreover, an organization seeking retroactive reinstatement must demonstrate that it had reasonable cause for failing to file a return or notice not only for each of the three years but also over the entire three-year period. An organization may establish reasonable cause by providing facts and circumstances showing it exercised ordinary business care and prudence in determining and attempting to comply with its reporting requirements for each of the three years and over the entire three-year period, but was nonetheless unable to file the required returns or notices for three consecutive years.
The IRS will consider a request for retroactive reinstatement from an organization other than a small organization only if the organization submits a request for reinstatement with a properly completed and executed application for reinstatement within 15 months of the later of the date of the IRS revocation letter or the date the IRS posted the organization’s name on its revocation list available on the IRS website.
Rebecca Mooreeditors@plansponsor.com