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FAQ

Straight answers before you begin

Three nonprofit board members reviewing a document with a CPA

Common questions about auto-revocation, reinstatement routes, timing, fees, and working with Apex.

Questions & answers

01What is automatic revocation?

If an organization that is required to file a Form 990-series annual return or Form 990-N notice fails to file for three consecutive years, its federal tax-exempt status is automatically revoked by operation of law.

02How do I know if we’ve been revoked?

Revoked organizations appear on the public IRS Auto-Revocation List. Because that list is a historical record, an organization may remain on it even after reinstatement. The free status check reviews the revocation record, current IRS eligibility data, and any later determination activity to establish the organization’s present status.

03Can donors deduct gifts again once we’re reinstated?

If retroactive reinstatement is granted, exempt status is restored to the revocation date, generally preserving deductibility during the intervening period. Filing-date reinstatement restores status only from the application filing date and does not eliminate the prior gap.

04Will we owe income tax for the lapsed years?

That depends primarily on the effective date of reinstatement. If retroactive reinstatement is granted, federal exempt status is restored through the revocation period. If reinstatement is effective only from the application filing date, the organization may be required to file Form 1120 or Form 1041 and may owe federal income tax for the intervening period. Other taxes that can apply even to exempt organizations, including payroll, unrelated business income, excise, or state taxes, are evaluated separately.

05How long do preparation and IRS review take?

Apex generally targets two to three weeks to prepare a routine application after the complete intake and requested documents are received. IRS review is a separate phase, and processing time varies by application type, case complexity, and agency workload.

06What is the difference between retroactive and filing-date reinstatement?

Retroactive reinstatement restores exempt status to the effective date of automatic revocation. Filing-date reinstatement—called post-mark-date reinstatement in the governing IRS procedure—restores status only from the date the reinstatement application is filed, leaving an intervening gap.

07Do you prepare delinquent Form 990 returns too?

Yes, when required or advisable under the applicable reinstatement route. Prior-year filings are not required for years in which the organization was eligible to file Form 990-N. If the organization was required to file Form 990-EZ, Form 990, or Form 990-PF and seeks retroactive reinstatement, the applicable delinquent returns are evaluated and, when required, prepared in coordination with the reinstatement application.

08What is a reasonable-cause statement?

A reasonable-cause statement is a detailed explanation showing that the organization exercised ordinary business care and prudence in attempting to meet its filing obligations. Streamlined Section 4 cases generally do not require a separate reasonable-cause narrative. Section 5 cases require reasonable cause for at least one of the three missed years, while Section 6 cases require reasonable cause for all three missed years.

09Is there a deadline?

There is no absolute deadline to apply for reinstatement, but timing determines which options are available. The streamlined Section 4 and within-15-month Section 5 procedures generally require filing no later than 15 months after the later of the IRS revocation-letter date or the date the organization was posted to the Auto-Revocation List. After that period, retroactive reinstatement may still be available under Section 6, but reasonable cause must be established for all three missed years. Filing-date reinstatement remains available without a reasonable-cause showing, but it leaves a gap in exempt status.

10How much does reinstatement cost?

Fees depend on the application form, the organization’s filing history, whether delinquent returns are required, the condition of its financial records, and any state-level work. Apex provides a fixed written quote after the free status check. See the Pricing page for current ranges.

11Are IRS user fees included?

No. The IRS currently charges $275 for Form 1023-EZ and $600 for Form 1023. These government fees are paid separately at cost and are subject to change.

12Who does the work?

Each engagement is led and reviewed by a licensed CPA. Trained professional staff may assist with document collection, research, accounting work, and application preparation under CPA supervision. The written engagement letter identifies the CPA responsible for the engagement.

13Is Apex affiliated with the IRS?

No. Apex is a private CPA service. It prepares and files applications and related returns on behalf of clients but is not affiliated with or endorsed by the IRS.

14What if we also have state-level issues?

Many revoked organizations also have lapsed charitable registrations, corporate annual reports, or state tax-exemption issues. Apex can identify these matters during the federal review. Any state-level remediation is separately scoped and quoted.

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