Which Form 990 do we file? A quick decision aid

This page is for the treasurer or founder who needs a fast answer to one question: which IRS annual return does our charity file this year? Work through the questions below in order and stop at the first one that fits. After reading, you'll know your form, its due date, how to get more time, and what happens if nobody files.

For a walk-through of actually filing, see filing your first Form 990. This page is the decision; that one is the how-to.

Before you start: two numbers

You need two figures for the tax year you're filing for:

• Gross receipts: everything that came in from all sources during the year, with no costs subtracted. The IRS defines it as "the total amounts the organization received from all sources." Ticket sales count in full, not just the profit.
• Total assets at year end: everything the charity owns on the last day of its tax year, including cash.

If you aren't sure when your tax year ends, check your exemption letter or your last return, and see choosing a fiscal year.

The decision, step by step

1. Are you a private foundation? Then you file Form 990-PF, whatever your size. The IRS table says simply "Private foundation - regardless of financial status." Some charitable trusts treated as private foundations file it too. If you aren't sure whether you're a private foundation or a public charity, your IRS determination letter says which.
2. Are you a church, or an interchurch organization of local units of a church? The Form 990 instructions list these among organizations not required to file. The same list covers some other church-related groups, but not every religious charity, so read it in the instructions before relying on it.
3. Are you a sponsoring organization of a donor-advised fund, or do you operate a hospital facility? The 990-EZ instructions say these must file the full Form 990, even if they're small.
4. Are your gross receipts $200,000 or more, or your total assets $500,000 or more? File Form 990.
5. Are your gross receipts normally $50,000 or less? You can file the online Form 990-N (e-Postcard), unless you're on the IRS list of organizations that can't (below).
6. Everyone else (gross receipts under $200,000 and total assets under $500,000) files Form 990-EZ, or may choose the full Form 990.

You can always file a bigger form than you need. The IRS says organizations eligible for the e-Postcard "may choose to file a full return."

What "normally $50,000 or less" means

The 990-N test looks at more than one year, and depends on your age. Per the IRS 990-N page, your gross receipts are normally $50,000 or less if your organization:

• has existed 1 year or less and received, or was pledged, $75,000 or less
• is between 1 and 3 years old and averaged $60,000 or less in each of its first two tax years
• is at least 3 years old and averaged $50,000 or less over the immediately preceding 3 tax years

So a charity that had one big year can still be "normally" under $50,000 if its three-year average is. The opposite is true too.

Who can't use the 990-N, even when small

The IRS lists these as not permitted to file the e-Postcard:

• private foundations (they file Form 990-PF)
• most supporting organizations, described in section 509(a)(3), which file Form 990 or 990-EZ (small ones supporting certain religious organizations are the exception)
• section 527 political organizations that must file an annual return
• several less common types, including section 501(c)(1), 501(c)(20), 501(c)(23), 501(c)(24), 501(d), 529, 4947(a)(1) and 4947(a)(2) organizations

If you're a chapter in a group

If your charity is part of a group exemption (for example, a local chapter of a national body), the parent may file one group return that covers you. Ask the parent in writing whether you're included. If you aren't, you file your own return.

Due dates and extensions

Every form in this family, including the 990-N and the 990-PF, is due by the 15th day of the 5th month after your tax year ends. For a calendar year, that's May 15. If the date falls on a weekend or legal holiday, the IRS instructions move it to the next business day. You can't file a 990-N until the tax year has ended.

Form 8868 gives an automatic 6-month extension for the 990, 990-EZ and 990-PF if you file it by the original due date. The Form 8868 instructions say you can't use it for the 990-N.

The 990, 990-EZ and 990-PF must be filed electronically for 2025 returns, according to each form's instructions. The 990-N is online only.

Penalties for late returns

• Form 990-N: the IRS says "There is no penalty for late submissions." File anyway, because missed years still count toward revocation.
• Forms 990, 990-EZ and 990-PF: the 2025 instructions set a penalty of $25 a day, up to the lesser of $13,000 or 5% of gross receipts, unless you show reasonable cause. Organizations with gross receipts over $1,309,500 pay $130 a day, up to $65,000.
• Returns due in 2027: Revenue Procedure 2025-32 raises the large-organization line to gross receipts over $1,339,500, with a maximum of $66,500. The $25 a day and $13,000 figures stay the same.
• Private foundations: the 990-PF instructions add a penalty on the responsible person, after a written IRS demand, of $10 a day up to $6,500 per return.

The 990-EZ instructions also say the penalty can be charged if the organization files an incomplete return. Answer every question and attach every required schedule.

Three years of not filing

This is the big one. The IRS says organizations "that do not file for three consecutive years automatically lose their tax-exempt status." The revocation takes effect on the original due date of the third missed return or notice. The IRS can't undo a proper revocation, and there's no appeal. After it:

• you're no longer exempt from federal income tax and may have to file a corporate or trust income tax return
• donations made after your name appears on the IRS revocation list aren't tax-deductible
• your state exemption and registrations may be affected too

Missed 990-N years count the same as missed 990 years. If it has already happened, read getting your tax-exempt status back.

A quick example

Here's a hypothetical case. A three-year-old after-school program had gross receipts of $40,000, $52,000 and $61,000 in its last three tax years, and $20,000 in the bank. The average is $51,000, which is over $50,000, so it can't use the 990-N. Its receipts are under $200,000 and its assets under $500,000, so it files the Form 990-EZ (or may file the full 990). With a December year end, the return is due May 15, or November 15 with a Form 8868 extension filed by May 15.

Your decision checklist

• We know our tax year end and our due date
• We've worked out gross receipts for each of the last three years
• We know our total assets at year end
• We've checked we're not a private foundation, supporting organization or other type that can't use the 990-N
• If we're in a group exemption, the parent confirmed in writing whether its group return covers us
• One named person files, and a second person checks it was filed
• If we need more time for a 990, 990-EZ or 990-PF, Form 8868 goes in by the due date
• We've checked what our state wants, since state thresholds can differ from the IRS's