Good news for organizations that have lost exempt status for failure to file Form 990! The IRS has just released a new streamlined retroactive reinstatement procedure that will affect many organizations currently in the process of reinstatement and even some organizations who have already received reinstatement effective as of the date of application for reinstatement.
Organizations that qualified to file a Form 990-N or 990-EZ for the three years that caused the revocation of exempt status no longer need to prove reasonable cause for failure to file in order to receive exempt status retroactive to the date it was revoked. For organizations that have not previously had exempt status revoked, simply file Form 1023 or 1024 (the application for exempt status) within 15 months of the revocation posting date and write “Revenue Procedure 2014-11, Streamlined Retroactive Reinstatement” at the top of the form. If a Form 990-EZ was required for one of the years, file a paper copy of the form to avoid penalties. It is not necessary to file a Form 990-N if the organization qualified to file that form for any of the unfiled years. Organizations that would have qualified for this procedure, but have already received reinstatement as of the date they applied for reinstatement will receive automatic retroactive reinstatement to the date exempt status was revoked. More information is available here.