When “Filing on Time” Is Actually Filing Late
While the IRS provides extended deadlines for filing Form 990, nonprofits seeking grant funding should prioritize early filing to ensure their tax-exempt status is updated in Publication 78, a critical resource for funders.
Key Ideas and Facts:
  1. Publication 78 Delay: The IRS typically takes 3-5 months to update Publication 78 after receiving a Form 990. Filing close to the extended deadline (November 15) can result in delayed visibility until the next year.
  2. "Waiting until the November deadline can delay your visibility in Publication 78 until next year—potentially putting grant eligibility at risk."
  3. Funder Reliance on Publication 78: Many grantmakers rely on Publication 78 to verify an organization's tax-exempt status before awarding funds. An outdated status jeopardizes grant eligibility.
  4. "Funders rely on the IRS's Publication 78 to verify your tax-exempt status..."
  5. Benefits of Early Filing: Filing Form 990 early ensures visibility and eligibility for funding opportunities throughout the year.
  6. "Staying ahead of this timeline can keep you visible and competitive in grant cycles"
  7. Proactive Communication: If there are delays in Publication 78 updates, nonprofits should proactively communicate with funders and confirm their active tax-exempt status using their determination letter.
  8. Impact on Reputation: Some funders may perceive delayed filings negatively, impacting an organization's reputation for transparency and efficiency.
  9. "Some funders view delayed filings as a lack of transparency, which can impact your organization’s reputation."
Recommendations:
  • File Early: Submit Form 990 as soon as possible after the fiscal year ends.
  • Prepare Ahead: Gather all necessary documents before the fiscal year-end to avoid delays.
  • Communicate with Funders: If Publication 78 updates are delayed, proactively communicate with funders about active tax-exempt status.
  • Utilize Tools for Tracking: Leverage tools like the IRS Tax-Exempt Organization Search (TEOS) or Guidestar to track your nonprofit's status in Publication 78.
Conclusion:
"On-time" for the IRS is not necessarily "on-time" for grant funders. Nonprofits must proactively prioritize early filing and stay ahead of the Publication 78 update timeline to maintain visibility and competitiveness in securing grant funding.
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3 comments
Gerrit Disbergen
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When “Filing on Time” Is Actually Filing Late
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