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Harmon Curran Nonprofit Law Blog

New Form 990-N Submission Process Effective August 1, 2022

All organizations described in section 501(c) of the Internal Revenue Code are required to file annual information returns or notices on the appropriate Form 990 series return.  Many small organizations can satisfy this annual reporting requirement by electronically filing Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required to File Form 990 or Form 990-EZ.  An organization is eligible to file Form 990-N if its annual gross receipts are normally $50,000 or less. (“Normally” is defined as an average. Specifics are on page 77 of the Form 990 Instructions.)   

The Internal Revenue Service (IRS) has changed the submission process for the Form 990-N.  As of August 2022, Form 990-N is filed through the IRS website instead of the Urban Institute website.  The new filing system can be accessed on Form 990-N information page, about halfway down the page.  When accessing the new filing system, the organization will be required to sign in by using an active IRS username or an existing ID.me account or by creating a new ID.me account.  ID.me is an identity verification platform used to access many government services and benefits.  The IRS describes ID.me as “our trusted technology provider” that “specializes in digital identity protection.”  Creating a new ID.me account will require an e-mail address and multi-factor authentication.  If the organization has an existing IRS username, the organization must use the same e-mail address when creating a new ID.me account to avoid issues.

The information required to be included on the Form 990-N has not changed.  Filing instructions for the Form 990-N can be found in Publication 5248, Form 990-N Electronic Filing System User Guide.  Form 990-N, like all other Form 990 series returns, is due the 15th day of the fifth month of the organization’s taxable year (May 15 for calendar year filers).  Organizations with taxable years other than the calendar year can use this chart to determine the initial return due dates, but note that the due date to file Form 990-N cannot be extended like it can for other Form 990 series returns.

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