IRS Forms Assistant
User Guide
One app, three related IRS jobs at three different stages of your nonprofit's life: apply for 501(c)(3) status (Form 1023), apply for other tax-exempt recognition such as 501(c)(4), (c)(5), (c)(6), or (c)(7) status (Form 1024), and file your annual information return every year once you are exempt (Form 990). Pick the form you need from the switcher and this guide will walk you through it.
1. About This Tool
The IRS Forms Assistant combines three related but distinct nonprofit filings into one app, because most organizations need all three over their lifetime, just not at the same time and not for the same reason. It is important to understand upfront that these are three different jobs, not one workflow:
- Form 1023 (or its shorter cousin, Form 1023-EZ) is a one-time federal application filed once, early in an organization's life, to become a 501(c)(3) public charity or private foundation.
- Form 1024 (or Form 1024-A) is a one-time federal application filed once for organizations seeking recognition as a different kind of tax-exempt entity, such as a 501(c)(4) social welfare organization, a 501(c)(5) labor or agricultural group, a 501(c)(6) business league, or a 501(c)(7) social club.
- Form 990 (in its 990-N, 990-EZ, 990, or 990-PF variants) is the annual information return every exempt organization files every year for as long as it exists, whether it was recognized under 501(c)(3) via Form 1023 or under another subsection via Form 1024.
In short: Form 1023 or Form 1024 is the application you file once to get exempt status in the first place. Form 990 is the filing you do every single year afterward to stay in good standing. Use the switcher at the top of the app to move between the three tools; each keeps its own saved answers, so switching forms never loses your work in another.
The outputs from every generator in this app are designed to be handed to your tax preparer, attorney, or board as the source material for the actual filing. Run the tools 30-60 days before the engagement begins. You'll catch missing data, identify what applies to you, and document the details that matter, all of which reduces preparer hours and back-and-forth.
2. Getting Started
Who this is for
- Founders of new nonprofits preparing to submit a federal exemption application (Form 1023 or Form 1024)
- Executive Directors who own the annual 990 process and want to provide their CPA with complete, organized source material
- Board treasurers and finance committee members overseeing the application process or 990 quality and board governance disclosures
- Internal accounting/finance staff who prepare the underlying data for an external preparer
- CPAs and nonprofit attorneys wanting a structured client-prep package (the outputs serve as workpapers)
- Nonprofit consultants guiding multiple founder clients through formation and ongoing compliance
Pick the card for the form you need on the app's main screen: Form 1023 if you are applying for 501(c)(3) status, Form 1024 if you are applying for another kind of exempt recognition, or Form 990 if you are already exempt and preparing your annual return. Each tool has its own onboarding wizard that captures the organization details specific to that filing.
None of the three tools in this app files anything with the IRS. Each produces source materials, calculations, and supporting narrative that you, your CPA, or your attorney use to complete the actual filing. Every filing in this family must be submitted electronically, Form 1023, 1023-EZ, 1024, and 1024-A at pay.gov, and Form 990 (in all its variants) through an IRS-authorized e-file provider.
3. Exporting Documents
Every generator in all three tools offers the same export options:
- Download as Word (.docx): formatted with headings, bullets, and the All In One Nonprofit document style. The default for documents going to your CPA, attorney, or board.
- Save to Library: stores the document straight into your shared Document Library.
- Download as HTML: for posting on a private intranet or sending as an email attachment.
- Copy to Clipboard: plain text with Markdown-style emphasis. Useful when pasting into a board portal, Google Docs, or a CPA's workpaper template.
- Print / PDF and plain Text: available from the same action bar on every generator.
No data leaves your device unless you choose to share the resulting document. The first Word export per session takes a couple of seconds while the document engine loads.
These outputs are designed to be reviewed and finalized by a qualified preparer. The calculators and generators throughout this app use widely-applicable rules, but edge cases (group rulings, supporting organizations, fiscal year changes, mergers, foreign affiliates, and similar situations) may produce different answers. Always confirm with a CPA or attorney before relying on outputs for filing decisions.
Applying for 501(c)(3) Status
Form 1023 (or its shorter cousin, Form 1023-EZ) is the federal application that converts a state-incorporated nonprofit into a federally tax-exempt 501(c)(3). Without an approved 1023 or 1023-EZ, your organization can incorporate, hold board meetings, and even accept donations, but those donations are not tax-deductible to donors, and the organization itself is technically a taxable entity. Federal tax exemption changes everything for fundraising and operations.
The application is complex enough that most new nonprofits hire a CPA or attorney to prepare it ($1,500-$5,000 for the full Form 1023; $500-$1,500 for Form 1023-EZ). Self-preparation is possible, and often the right choice for organizations applying for Form 1023-EZ, but the cost of getting it wrong is high: a rejected or delayed application can mean months or years of lost fundraising momentum.
This tool doesn't file the application for you. It produces the source materials, calculations, and supporting narrative that you (or your CPA/attorney) will use to complete the actual filing. Run the tools 30-60 days before you submit. The outputs should reduce your preparer's billable hours significantly and catch issues before they become IRS follow-up questions.
The Form 1023 generators are split into "Filing Determination" (used by everyone), "Documents & Worksheets" (Lite-focused, built around Form 1023-EZ), and "Full Form 1023 Tools" (for organizations that must file the longer form). The dashboard auto-detects which path applies to you based on your org profile and routes you to the right tools.
What you'll need to complete the org profile (5-10 minutes)
- Organization legal name, EIN (or "not yet obtained"), state of incorporation, fiscal year end, mission statement
- Formation status: incorporated yet? Articles include 501(c)(3) language? Bylaws drafted? Initial board meeting held?
- Financial projections: gross receipts in each of next 3 years, total assets at end of year 3, employee count in year 1
- Entity type: standard 501(c)(3) public charity, or one of the special types (church, school, hospital, supporting org, private foundation, successor to for-profit)
- Activities profile: brief description, lobbying plans, insider compensation arrangements, foreign activities, prior exempt status history
What you'll need before filing (the application itself)
- EIN from the IRS (free, ~15 min at irs.gov)
- Articles of Incorporation filed with your state, including all five required 501(c)(3) provisions (Governing Documents Checklist verifies)
- Bylaws drafted and adopted by the initial board
- Initial organizational meeting minutes showing board election, bylaws adoption, officer appointment
- Conflict of Interest Policy (recommended; sample in 1023 Appendix A)
- pay.gov account (free; the application is filed online here)
- User fee budgeted: $275 for 1023-EZ, $600 for full 1023
- For full 1023: narrative description of activities (use Narrative Builder), 3-year financial projections (use Financial Projections Worksheet), compensation arrangements documented
The Articles of Incorporation, Bylaws, Conflict of Interest Policy, and initial organizational meeting minutes required above are exactly what the Nonprofit Formation Assistant generates for you, with the 501(c)(3) provisions already built in. If you haven't formed yet or are missing any of these, run through it first (see its Documents step for what it produces), then come back here to file.
The IRS will reject any Form 1023 / 1023-EZ submitted without an EIN. You must obtain your EIN before submitting either form. The EIN online application at irs.gov is free, takes about 15 minutes, and provides your EIN immediately. Do this before starting the application process, don't wait until you're filling out the form.
Using the Generators
Seven generators in three categories. The dashboard auto-detects whether you should focus on the Lite-suite tools (1023-EZ path) or use the Full-suite tools as well (1023 full path).
| Category | Generator | Typical Time | Path |
|---|---|---|---|
| Filing | Eligibility Wizard | 10-15 min | Everyone |
| Filing | Form Selector & Roadmap | 10 min | Everyone |
| Documents | Governing Documents Checklist | 15 min | Everyone |
| Documents | Form 1023-EZ Worksheet | 30-45 min | 1023-EZ filers |
| Full 1023 | Public Charity Classification Selector | 15-20 min | 1023 full filers |
| Full 1023 | Form 1023 Narrative Builder | 45-90 min | 1023 full filers |
| Full 1023 | Financial Projections Worksheet | 60-90 min | 1023 full filers |
Recommended order for 1023-EZ filers
- Eligibility Wizard: confirm you can file 1023-EZ (the most common surprise: large planned gift in year 3 makes you ineligible)
- Form Selector & Roadmap: review the pre-filing checklist; calendar your filing date
- Governing Documents Checklist: verify articles include all five required provisions; amend if needed BEFORE filing
- Form 1023-EZ Worksheet: prepare all responses BEFORE opening pay.gov (form can't save drafts)
- Open pay.gov; transfer prepared responses; pay $275; submit
Recommended order for full Form 1023 filers
- Eligibility Wizard: confirms full 1023 is required (often automatic from entity type or size)
- Form Selector & Roadmap: full 1023 timeline is 3-9+ months; plan accordingly
- Governing Documents Checklist: same verification as 1023-EZ filers; required for all 1023 applications
- Public Charity Classification Selector: pick your 509(a)(1) or 509(a)(2) classification with revenue-mix analysis
- Form 1023 Narrative Builder: structured What/Who/Where/Why/How framework; generates a draft narrative
- Financial Projections Worksheet: 3-year P&L plus balance sheet, with reasonableness checks
- Engage CPA or attorney for application review before submission (highly recommended for full 1023)
- Submit at pay.gov; pay $600; respond to any IRS additional information requests within 60 days
Form 1023 vs Form 1023-EZ
Most new 501(c)(3) applicants qualify for one or the other. The choice is largely driven by org size and entity type, not preference.
| Form 1023-EZ | Form 1023 (full) | |
|---|---|---|
| Length | 3 pages, 5 parts, ~30 fields | ~28 pages, 11 parts + schedules A–H as applicable |
| User fee | $275 | $600 |
| Filing method | Online only at pay.gov | Online at pay.gov (mandatory since 2020) |
| Typical IRS review time | 2-4 weeks | 3-9+ months |
| Required attachments | None | Articles, bylaws, narrative, financial projections, COI policy (recommended) |
| Save-and-resume | No (must complete in one session) | Yes |
| Best for | New orgs with simple operations | Larger orgs, special entity types, complex operations |
Who can use Form 1023-EZ
All four conditions must be true:
- Projected annual gross receipts ≤ $50,000 in any of the next 3 years (AND past 3 years actual receipts ≤ $50,000 each)
- Total assets ≤ $250,000
- Not a church, school, hospital, supporting organization, private foundation, or other excluded entity type
- Not seeking retroactive reinstatement after auto-revocation
Plus about 15 other operational conditions (no donor-advised funds, no foreign activities, etc.). The Eligibility Wizard walks through the most common disqualifiers.
Who must use the full Form 1023
- Organizations expecting to exceed $50,000 in gross receipts (or $250,000 in assets) in any of the next 3 years
- Churches, schools, hospitals, medical research orgs (automatic public charity status; cannot use EZ)
- Churches and the annual return: a church, an integrated auxiliary of a church, or a convention or association of churches is exempt from the annual information return under IRC 6033(a)(3)(A)(i). On the Tax-Exempt Status step of the Form 990 tool, choose the church option and the assistant will tell you that no Form 990, 990-EZ, or 990-N is due. A church may still file voluntarily, or request a determination letter, for donor and grantmaker confidence.
- Not sure you count as a church? The IRS weighs fourteen characteristics, and no single factor decides it. Take the guided 14-factor church check: it walks each characteristic, records your answers, and produces a written rationale, then connects the conclusion to what follows from it, since a church is automatically exempt and cannot use Form 1023-EZ, while a religious organization that is not a church must apply for recognition and file the 990 series every year.
- 509(a)(3) supporting organizations (all three types)
- Private foundations and private operating foundations
- Successors to for-profit entities
- Organizations seeking retroactive reinstatement after auto-revocation
- Organizations with donor-advised funds
- Foreign organizations
The "should I use EZ even if eligible" question
Some founders ask whether they should file the full Form 1023 even when eligible for the EZ, on the theory that the longer application produces a stronger determination letter or signals "real organization" to funders. Generally no. The EZ determination letter is functionally identical to the full 1023 determination letter. Funders look at the determination letter and the EIN; they don't ask which form was used. Use the EZ if you qualify, save the $325 fee difference and the months of waiting time.
When the IRS introduced Form 1023-EZ in 2014, some critics worried it would let unworthy organizations gain tax-exempt status without scrutiny. The IRS Treasury Inspector General for Tax Administration (TIGTA) has periodically reviewed EZ approvals and found error rates in the 30-40% range, meaning many EZ-approved organizations don't actually meet the substantive 501(c)(3) requirements. This doesn't mean the EZ is invalid; it means the IRS is paying more attention to post-approval compliance. File the EZ if you qualify, but make sure your operations actually conform to 501(c)(3) requirements, your organization is just as obligated as a full-1023 organization.
The Five Required Articles Provisions
Both Form 1023 and Form 1023-EZ require that your Articles of Incorporation include five specific provisions. Without them, the IRS will reject the application. The Governing Documents Checklist tool verifies each, but here's the deeper context.
1. Purpose Clause
The Articles must state that the corporation is organized exclusively for one or more 501(c)(3) exempt purposes (charitable, religious, educational, scientific, literary, public safety testing, amateur sports, or prevention of cruelty to children/animals). Vague mission language ("to make the world better") does not suffice.
IRS-suggested language: "This corporation is organized exclusively for charitable, religious, educational, and scientific purposes within the meaning of Section 501(c)(3) of the Internal Revenue Code, or corresponding section of any future federal tax code."
2. Dissolution Clause
The Articles must state that upon dissolution of the corporation, all remaining assets will be distributed to another 501(c)(3) organization or to a federal/state/local government for a public purpose. This is the most commonly missing provision, some state nonprofit corporation laws don't require it, so first-time founders skip it. The IRS requires it regardless of state law.
IRS-suggested language: "Upon the dissolution of the corporation, assets shall be distributed for one or more exempt purposes within the meaning of Section 501(c)(3) of the Internal Revenue Code, or corresponding section of any future federal tax code, or shall be distributed to the federal government, or to a state or local government, for a public purpose."
3. Inurement Prohibition
The Articles must state that no part of the net earnings will inure to the benefit of members, trustees, officers, or other private persons (except reasonable compensation for services rendered).
IRS-suggested language: "No part of the net earnings of the corporation shall inure to the benefit of, or be distributable to, its members, trustees, officers, or other private persons, except that the corporation shall be authorized and empowered to pay reasonable compensation for services rendered."
4. Political Activity Prohibition
The Articles must state that the corporation will not participate in any political campaign on behalf of (or in opposition to) any candidate for public office. This is an absolute prohibition for 501(c)(3) organizations, not even insubstantial political campaign activity is permitted. (Lobbying is a separate, more permissive rule.)
IRS-suggested language: "The corporation shall not participate in, or intervene in (including the publishing or distribution of statements) any political campaign on behalf of or in opposition to any candidate for public office."
5. Lobbying Limitation
The Articles must state that no substantial part of the activities will be carrying on propaganda or otherwise attempting to influence legislation. Some lobbying is permitted for 501(c)(3) organizations as long as it's an "insubstantial part" of activities, this provision codifies the limit.
IRS-suggested language: "No substantial part of the activities of the corporation shall be the carrying on of propaganda, or otherwise attempting to influence legislation, except as otherwise provided by Section 501(h) of the Internal Revenue Code."
You must file an amendment with your state BEFORE submitting Form 1023 or 1023-EZ. State amendment fees range from $10-$100 and processing takes 1-4 weeks. Submitting the application without first amending will result in IRS rejection, you'll then have to amend articles, refile the application, and pay the user fee again. It's much faster and cheaper to amend first.
Recommended (not required by IRS, but expected)
- Conflict of Interest Policy: Form 1023 explicitly asks whether your org has adopted one. The IRS provides a sample policy in Form 1023 Appendix A. Strongly recommend adopting before filing.
- Bylaws: Required for full 1023 filings (uploaded as part of the application). Not uploaded with 1023-EZ but should still be adopted before filing.
- Initial organizational meeting minutes: Documents that the board was duly elected, bylaws were adopted, officers were appointed.
Public Charity Classification
Form 1023 Part VII (and 1023-EZ Part IV) requires you to elect a foundation classification. Most new public charities choose between two options. Choosing wrong doesn't disqualify you, but it can affect future public support test calculations and operating constraints.
509(a)(1) and 170(b)(1)(A)(vi), Donative Public Charity
For organizations supported primarily by donations from the general public, foundations, and governmental units. The "1/3 public support test" requires at least 33⅓% of total support to come from public sources over a 5-year rolling window (with a 2% per-donor cap on individual contributions). Most donation-driven nonprofits choose this.
509(a)(2), Service Revenue Public Charity
For organizations supported primarily by gross receipts from exempt-purpose program services (admission fees, tuition, ticket sales, etc.). The 509(a)(2) test has two prongs: (a) more than 33⅓% from public sources + qualifying program revenue, and (b) no more than 33⅓% from investment income and unrelated business income. Most service-providing nonprofits choose this.
509(a)(3), Supporting Organization
For organizations operated exclusively for the benefit of, to perform the functions of, or to carry out the purposes of one or more 501(c)(3) public charities. Three types (Type I, II, III) with different control relationships. The IRS scrutinizes 509(a)(3) classifications carefully, this requires attorney review before electing.
Private Foundation (default)
If you don't qualify as a public charity, you're a private foundation by default. Private foundations face significantly more compliance burden: Form 990-PF annually, 5% mandatory distribution requirement, 1.39% excise tax on net investment income, self-dealing prohibitions, jeopardizing investment restrictions, excess business holdings limits. Most new nonprofits prefer to avoid this classification.
The 5-year advance ruling period
Since 2008, new public charities automatically receive a 5-year window to meet their chosen public support test. The IRS evaluates support at the end of year 5. If you don't meet the test, you can: (a) request the facts-and-circumstances test, (b) restructure operations, or (c) accept reclassification as a private foundation. The Public Charity Classification Selector tool helps you choose a classification you can defensibly meet by year 5.
The Public Charity Classification Selector analyzes your 3-year projected revenue mix and recommends a classification. Donation-heavy ⇒ 509(a)(1). Service-revenue-heavy ⇒ 509(a)(2). Borderline mixes ⇒ review with a CPA. The tool also flags donor-concentration risk (the 2% cap that can erode public support when one donor gives a very large gift).
Writing a Strong Narrative Description
Form 1023 Part IV asks for a "complete and detailed narrative description of past, present, and planned activities." This is the most important section of the application. IRS exempt organization specialists read the narrative more carefully than any other part, it's how they evaluate whether your activities actually qualify as exempt under 501(c)(3).
What makes a strong narrative
- Specific: Names places, populations, programs, methods, schedules. "Provide weekly 90-minute math tutoring to K-8 students at Lincoln Elementary" beats "Help children learn."
- Comprehensive: Covers what, who, where, when, why (exempt purpose link), and how (funded)
- Realistic: Doesn't promise more than the organization can deliver in the realistic timeframe
- Exempt-purpose-linked: Each program description explicitly ties to a 501(c)(3) exempt purpose
- Quantified where possible: Number served, hours provided, dollars granted
- Past/present/future structure: If you have any operating history, describe what you've done; describe current operations; describe planned future activities
The Narrative Builder framework
For each program/activity, the Narrative Builder walks you through:
- What you do (the specific activities, in action verbs)
- Who you serve (population, demographics, eligibility criteria)
- Where you operate (geography, specific locations)
- When (frequency, duration, schedule)
- Why this qualifies as exempt (link to exempt purpose category)
- How funded (revenue sources for the program)
AI drafter (Part IV narrative)
Once you have entered your program details, the Narrative Builder includes an AI drafter that writes a first-pass Part IV "Narrative Description of Activities" from those details. It works from what you typed (the activities, who you serve, where, when, the exempt-purpose link, and how each program is funded), assembles them into the past/present/future structure the IRS expects, and keeps the exempt-purpose connection explicit. The generated draft flows straight into your export, so you can refine it and hand it to your CPA or attorney as a starting point rather than a blank page.
Treat the draft as exactly that, a starting point. Review every line against what your organization actually does, add the specifics only you know, and have a board member or advisor read it before you file. The AI offers guidance, never a guarantee of approval, and it writes only from the details you provide (it does not invent programs, numbers, or facts). Full detail, including its guardrails, lives in the AI Automations Guide.
Common narrative mistakes
- Too vague: "Empower communities" or "create positive change" describes nothing concrete
- Marketing copy: Marketing language often sounds vague to an IRS examiner
- Burying the exempt purpose: The exempt purpose connection should be explicit in each program description, not assumed
- Aspirational without plan: Vague future plans without dates or budgets raise questions
- Forgetting fundraising disclosure: All fundraising methods must be described (events, direct mail, online, grants, etc.)
- Promising things you can't keep: The application binds you to operate as described, the IRS compares to actual 990s in future years
Length expectations
Typical narrative length: 2-5 pages double-spaced for a smaller or mid-sized organization. Less than 1 page raises questions; more than 10 pages may suggest disorganization. Focus on quality over volume.
The Narrative Builder produces a starting draft. Plan to revise 2-3 times: once for clarity, once for specificity, once for exempt-purpose linkage. Then have a board member, CPA, or attorney review before submission. The cost of a few hours of revision is much less than the cost of an IRS additional information request that delays approval by 60-180 days.
Financial Projections (Part IX)
Form 1023 Part IX requires 3 years of financial data: actual for any completed years plus projections for remaining years. The IRS uses these figures to evaluate (1) reasonable compensation, (2) program-to-administrative expense ratios, (3) public support test viability, and (4) general organizational sustainability.
Required line items
Revenue: contributions and grants, membership fees, gross investment income, net unrelated business income, gross receipts from program services, other revenue.
Expenses: compensation to officers/directors/trustees, other salaries and wages, interest, occupancy, professional fees, contributions/grants paid out, fundraising expenses, other expenses.
Balance sheet (most recent year-end): cash, accounts/pledges receivable, investments, property & equipment, other assets, total liabilities. Net assets calculated as total assets minus total liabilities.
What IRS examiners look for
- Internal consistency: Do revenue projections match the narrative? If you describe direct services, do you show program service revenue or just donations?
- Reasonable compensation: Are officer/director salaries reasonable for the role and org size?
- For new smaller orgs: often $0 (founders volunteer)
- For mid-size orgs (~$200K revenue): Executive Director comp typically $50-90K
- Above $500K revenue: more variable, but defensible to comparable salary data
- Realistic growth: Does growth match the operational plan and committed funding? Aggressive growth (25%+ YoY) requires justification.
- Public support viability: Will the revenue mix satisfy the chosen public charity classification's support test by year 5?
- Program vs admin balance: Are program expenses meaningful relative to overhead? Watchdogs use 65% program expense as a typical floor.
Reasonableness checks built into the tool
The Financial Projections Worksheet flags patterns that may invite IRS questions:
- Compensation greater than 70% of revenue (likely raises reasonable comp questions)
- Fundraising greater than 30% of revenue (high; requires explanation)
- Year-over-year growth greater than 200% (aggressive; needs justification)
- Large unexplained surpluses (may suggest insufficient program activity)
- Operating losses greater than 25% of revenue (sustainability concern)
Build projections conservatively
Many founders project aggressive growth to "look successful" on the application. This usually backfires. The IRS may grant exemption based on optimistic projections, but the projections become a comparison point for future 990 filings. If actual results substantially undershoot projections for several years, the IRS may revisit the exemption determination. Better to project realistically and overdeliver.
The IRS may follow up on financial projections with questions. Be ready with: board-approved budget, funding commitments (LOIs, signed grants, pledges), lease/sublease agreements, compensation comparables for any non-zero officer compensation, capital campaign feasibility studies if projecting growth, founder/board commitment documents for in-kind contributions.
Timeline & What to Expect
Form 1023-EZ timeline
- Week 1: Complete pre-filing checklist; run the 1023-EZ Worksheet to prepare responses
- Week 2: Log into pay.gov, open 1023-EZ form, transfer prepared responses, pay $275 user fee, submit
- Weeks 3-6: IRS reviews; may approve, request additional information, or (rarely) issue proposed adverse determination
- After approval: File Form 990-N annually; register with state charity regulator; comply with public disclosure requirements
Form 1023 (full) timeline
- Months 1-2: Complete pre-filing checklist; draft narrative description; build financial projections; finalize public charity classification
- Month 3: Review draft application with board; engage CPA or attorney for review (strongly recommended for full 1023)
- Month 4: Submit Form 1023 via pay.gov, pay $600 user fee
- Months 5-9: IRS review. Common: IRS issues "request for additional information" letter (typically 60 days to respond)
- Months 6-12+: IRS issues Determination Letter (favorable, adverse, or proposed adverse)
- After approval: File Form 990 or 990-EZ annually; register with state charity regulator; ongoing compliance
Determination Letter outcomes
- Favorable: You're tax-exempt. Effective date is typically date of formation if filed within 27 months; otherwise date of filing.
- Request for additional information: IRS asks for clarification or additional documents. You typically have 60 days to respond, missing the deadline closes your application.
- Proposed adverse determination: IRS believes you don't qualify. You have 30 days to request a conference or submit additional information.
Expedited review
The IRS does not generally offer expedited review. Limited exceptions: grants with specific deadlines, hardship circumstances, IRS error. To request expedited handling, attach a letter to the application explaining the urgency and the specific timeline. Most requests are denied. The best strategy for fast approval is filing a complete and accurate application from the start, avoiding follow-up requests that add 60-120 days.
Common Pitfalls
Submitting without EIN
The IRS rejects any application without an EIN. Get yours BEFORE starting the application, free online at irs.gov, immediate issuance.
Articles missing required 501(c)(3) language
The single most common reason 1023 applications are rejected or delayed. State boilerplate Articles often omit some or all of the five required provisions. Amend before filing, not after.
Vague narrative description
Marketing-style language ("empowering communities", "creating change") doesn't satisfy the IRS. Use specific verbs, named populations, concrete locations, measurable activities.
Aggressive financial projections
Optimistic projections may get the application approved, but they become a comparison point against actual 990 filings. Material undershoots can trigger IRS examination of the original exemption.
Inappropriate public charity classification
Choosing 509(a)(1) when your revenue is mostly program fees, or 509(a)(2) when you're donation-driven, sets you up to fail the public support test by year 5. Choose based on actual projected revenue mix.
Filing 1023-EZ when you're not eligible
The IRS audits 1023-EZ approvals randomly. If they determine you weren't eligible (e.g., projected revenue exceeded $50K, or you fall into a disqualified entity type), they can revoke exemption and require you to refile via full 1023.
Underestimating the full 1023 effort
The full Form 1023 is genuinely complex. Self-preparation is possible but typically takes 30-50 hours of focused work. CPA or attorney engagement costs $1,500-$5,000 but reduces preparation time and improves approval odds.
Missing the 27-month retroactive window
If you file within 27 months of incorporation, tax-exempt status is retroactive to formation date. Donations during the pre-filing period are tax-deductible. File late and you may lose retroactive status, donations between formation and filing date aren't deductible, and the IRS may impose income tax on the period.
Forgetting state-level requirements
Federal 501(c)(3) status does NOT exempt you from state-level requirements. Most states require: separate state charity registration (annual), state corporate income tax exemption (separate application), state sales/use tax exemption (separate application where available). Each state has different procedures and timelines.
The 1023 is a once-in-an-organization's-lifetime application that shapes everything that follows. Treat it like a federal court filing, not an online form: prepare carefully, document everything, engage professional help for the full 1023 if you can, and file it as accurately as possible the first time. The investment in front-loaded preparation pays dividends in faster approval, fewer follow-up requests, and a stronger foundation for the organization's future.
After Approval, Ongoing Compliance
Receiving your Determination Letter is the beginning of compliance, not the end. The IRS, your state, and your funders all have ongoing expectations.
First-year actions
- Frame and display your Determination Letter prominently
- Send a copy to current donors and update fundraising materials
- Register with state charity regulator if you solicit donations (most states require this)
- Apply for state corporate income tax exemption (separate application; varies by state)
- Apply for state sales/use tax exemption if available (varies by state, some states never grant it)
- Register with property tax assessor if you own or lease property (some states grant exemption)
- Update GuideStar/Candid profile (free; affects funder discoverability)
- Consider Charity Navigator and BBB Wise Giving Alliance registration once revenue thresholds met
Annual federal compliance
- Form 990, 990-EZ, or 990-N annually (use the Form 990 tool in this app, below, when you grow into 990-EZ or full 990)
- Form 990-T if you have $1,000+ of unrelated business income
- Public disclosure: Form 990 and Form 1023 must be available for public inspection on request
Annual state compliance
- State charity registration renewal (annual in most states; some require audited financials)
- State corporate registration renewal (annual)
- Annual minutes documenting board meetings
- Conflict of Interest annual disclosures
Triggers for IRS attention after approval
- Material changes in activities from what was described in the 1023, report on Schedule O of Form 990
- Substantial growth or contraction in revenue
- Engagement in lobbying or political activity
- Material transactions with insiders (Schedule L)
- Failure to meet public support test by end of advance ruling period
- 3 consecutive years of non-filing = automatic revocation
Applying for Other Exempt Status
Form 1024 (and Form 1024-A) is the IRS application a non-charity nonprofit files to be recognized as tax-exempt. This tool walks you through it part by part, in plain English, gathers your answers, and produces a preparation packet you can copy into the official filing at pay.gov or hand to your attorney.
It is built for:
- 501(c)(4) social welfare organizations and civic leagues (these file Form 1024-A, plus a separate Form 8976 notice)
- 501(c)(5) labor, agricultural, and horticultural organizations
- 501(c)(6) business leagues, trade and professional associations, and chambers of commerce
- 501(c)(7) social and recreational clubs
If you are a 501(c)(3) charity, use the Form 1023 tool in this app instead, above. Not sure which type you are? Compare the types.
Before you start
You will move faster if you already have your EIN, your filed Articles of Incorporation, your Bylaws, and a rough budget. If you have not formed yet, use the Nonprofit Formation Assistant first; when you choose your type there, it drafts your Articles, Bylaws, and Conflict of Interest Policy with the right language for a 501(c)(6) or other type, not charity boilerplate, plus your initial board meeting minutes.
Pick your type on the Overview screen first. It drives your form, your required provisions, your schedule, and the filing fee throughout the tool.
Working Through the Parts
Use the sidebar to move through the application. Each part mirrors a part of the real Form 1024 and tells you exactly what the IRS is asking for. Your answers save automatically on your device as you type, and the Overview shows how many parts you have started so you can pick up where you left off.
- Part I, Identification: who the organization is, your EIN, address, and contact.
- Part II, Structure: what kind of legal entity you are and your founding documents.
- Part III, Required provisions: your purpose and dissolution language. A non-charity type is not required to use charitable-purpose or 501(c)(3)-dissolution language.
- Part IV, Activities narrative: the heart of the application, see below.
- Part V, People and money: who you pay and any dealings with insiders.
- Part VI, Financial data: a simple revenue and expense picture, use your budget if you are new.
- Your schedule: the questions specific to your subsection (c4, c5, c6, or c7).
The AI narrative drafter
Part IV asks for a clear description of your activities, which is the part most people find hardest. Fill in the short prompts (what you do, who, when, funding, purpose), then click "AI: draft my narrative from the answers above." The tool writes a structured, IRS-style narrative for your exact type.
Two things to know: it uses only the facts you typed and inserts a clearly [bracketed placeholder] where a detail is missing rather than inventing one, and the draft lands in an editable box that you should review and correct. This automation uses your All In One Nonprofit account, so sign in first; if you are signed out, the tool shows a sign-in link. For how it works and its guardrails, see the AI Automations Guide.
Review, Export & File
The Review & export screen gathers everything into one packet. You can Copy all, download a formatted Word (.docx) or plain text file, or print it. Hand it to your attorney, or use it to fill in the official application.
You file Form 1024 (or Form 1024-A for a c4) electronically at pay.gov with the user fee, currently $600. Processing commonly takes a few months. The Filing checklist screen has the links and the step list, including the c4 Form 8976 notice.
Form 1024 is a legal filing. This tool is a preparation aid; have a qualified attorney or accountant review your application before you submit it.
Your Annual Return
Form 990 is the public-facing annual report card for every nonprofit that files it. The IRS uses it. State charity regulators use it. GuideStar/Candid posts it. ProPublica indexes it. Donors search it. Funders require it. Watchdog groups score it. Journalists comb it for stories. Whatever your nonprofit puts on its 990 is the single most-read document the organization will ever publish.
Despite that, 990 preparation in most nonprofits is a yearly scramble. The CPA asks for data the organization hasn't been tracking. Schedules get missed. The governance section gets answered inconsistently year to year. The board "reviews" the 990 in the last 48 hours before filing. Functional expense allocations are made by intuition rather than method. And the questions the IRS scrutinizes, public support test, compensation reasonableness, related-party transactions, get answered without the underlying analysis to back them up.
This tool doesn't replace your CPA. It does the upstream work the CPA assumes you've already done: figuring out which form you file, identifying every applicable schedule, documenting your governance practices, running the math on the public support test, structuring compensation disclosures with proper rebuttable-presumption protection, and allocating functional expenses with a defensible methodology.
What you'll need to complete the org profile (5-10 minutes)
- Organization legal name, EIN, state, fiscal year end, year founded
- Mission statement (verbatim from governing documents preferred)
- Tax-exempt status type (501(c)(3) public charity, 501(c)(3) private foundation, 501(c)(4), 501(c)(6), other)
- Public charity sub-classification for 501(c)(3) public charities (170(b)(1)(A)(vi), 509(a)(2), 509(a)(1) church/school/hospital, supporting organization, other)
- Most recent fiscal year totals: gross receipts, total assets (EOY), total expenses, net assets (EOY)
- Activity flags: large contributors, lobbying, grants over $5K, non-cash gifts over $25K, fundraising events over $15K, foreign activities, UBI over $1K
- Operations: employee count, contractors paid over $100K, high-comp staff over $150K, related organizations, school/hospital status, termination/dissolution status
What you'll need for the full generator suite
Different generators need different inputs. The most data-heavy generators are:
- Public Support Test Calculator: 5 years of detailed support data (contributions by source, investment income, UBTI, other) plus identification of largest individual donors. Pull from prior 990s or accounting records.
- Compensation Disclosure Worksheet: for each officer/director/key employee/highest-paid: W-2 box 1 (or 1099 amounts), retirement contributions, other benefits, related-org compensation, hours per week.
- Functional Expense Allocator: total expenses by Part IX line item, plus your allocation percentages (typically pulled from your accounting system if functional accounting is in place, or built from a time study and other allocation bases).
Using the Generators
Eight generators across the Dashboard: Filing Determination (START HERE), Governance & Policies (Part VI), Financial Reporting (Parts VII–IX), and Program Service Accomplishments (Part III). Each follows the same click-path: open the Dashboard section, click the generator card, click Start →, read the blue tip, fill in fields on the left, watch the Live Preview on the right, click ✓ Mark Complete, then export from the action bar.
| Category | Generator | Typical Time | When to Run |
|---|---|---|---|
| Filing | Filing Form Selector | 5 min | First, confirms 990, 990-EZ, 990-N, or 990-PF. |
| Filing | Schedule Identifier | 10 min | Right after Filing Form Selector. |
| Governance | Governance Policies Checklist | 15 min | Anytime, produces Part VI inventory. |
| Governance | Board Review Process | 15 min | 30-60 days before filing. |
| Financial | Public Support Test Calculator | 30-45 min | For 170(b)(1)(A)(vi) charities, annually. |
| Financial | Compensation Disclosure Worksheet | 30-60 min | Once compensation data finalized. |
| Financial | Functional Expense Allocator | 30-60 min | After year-end close. |
| Programs | Program Service Accomplishments | 20-40 min | For Part III, once your programs are listed. |
Recommended order for a first-time user
- Filing Form Selector: confirms which form variant, identifies due dates, surfaces e-filing requirements
- Schedule Identifier: walks A–R and flags every required, conditional, and not-applicable schedule
- Governance Policies Checklist: inventories Part VI policies; identifies gaps to fix before filing
- Board Review Process: produces the Schedule O narrative for Part VI Q11b plus standing process document
- Public Support Test Calculator: only for 170(b)(1)(A)(vi) donative public charities; runs the math on 5-year support
- Compensation Disclosure Worksheet: per-person Part VII Section A and contractor Section B with Schedule J trigger detection
- Functional Expense Allocator: documents Part IX methodology with reasonableness checks against watchdog thresholds
Update your org profile once; every generator picks up the latest data. The Schedule Identifier respects your activity flags. The Filing Form Selector uses your financial size. The Public Support Test uses your tax-exempt sub-classification. Keep the profile current by reopening Organization Settings from the top header.
Program Service Accomplishments (Part III)
Part III asks for narrative descriptions of the organization's program service accomplishments, including for the three largest programs by expense. This is the section donors, funders, and watchdog sites actually read, yet many filers write two or three thin sentences and miss the chance to communicate impact. The Program Service Accomplishments tool gives you a place to list each program (with its expenses, grants, and revenue) and build a proper Part III narrative for each one.
Enter your programs the same way you use the other generators: open the tool, fill the Customize form, watch the Live Preview, mark complete, and export. For each program, capture what it does, who it serves, where, and the outcomes you can quantify (people served, units delivered, hours provided). Lead with outcomes, not activities.
The tool includes an AI drafter that writes the program-accomplishments narrative from the programs you enter. It works only from the details you provide, turning your inputs into clear Part III prose, and the draft flows into your export so you can refine it before handing it to your CPA or board. Treat the output as a first draft to edit, not a finished filing: review every figure, add the specifics only you know, and never rely on it as a guarantee. For how it works and its guardrails, see the AI Automations Guide.
The 990 Form Family
There are five 990-series filings. Most nonprofits file one of them annually. Some file two.
Form 990-N (e-Postcard)
The shortest filing in the family, 8 fields, no attachments, no schedules, electronic only. For organizations with gross receipts $50,000 or less. Cannot be extended. Cannot use the e-Postcard if you're a private foundation, a 509(a)(3) Type III supporting organization, or part of a group ruling (the parent files for you). Three consecutive missed 990-Ns = automatic revocation of tax-exempt status with no warning.
Form 990-EZ
The 4-page short form, for organizations with gross receipts under $200,000 AND total assets under $500,000. Both conditions must be met. Schedules A, B, C, E, G, L, N, and O may still apply. Mandatory e-filing since 2020.
Form 990
The full form, 12 pages plus any applicable Schedules A–R. Required when gross receipts are $200,000+ OR total assets are $500,000+. The full 990 includes deeper reporting on programs (Part III), governance (Part VI), compensation (Part VII), and financial position (Parts VIII–XI).
Form 990-PF
The private foundation form, required for all 501(c)(3) private foundations regardless of size. Distinct structure from the 990. Includes investment income reporting, mandatory 5% qualifying distribution calculation, excise taxes under IRC 4940-4945, jeopardizing investment rules, self-dealing prohibitions, and a public list of all grants. Private foundations have substantially more compliance complexity than public charities, which is why the operational decision to be classified as a public charity (when eligible) matters so much.
Form 990-T
The unrelated business income (UBI) form. Required IN ADDITION TO the main 990 if you have $1,000+ of unrelated business gross income. Common UBI sources for nonprofits: advertising revenue, rental of debt-financed property, sale of merchandise not related to mission, parking lot fees from non-affiliated users. Tax is owed at corporate rates on UBI after a $1,000 specific deduction. Net Operating Losses can carry forward in some cases.
If your organization is part of a group ruling (subordinate of a central organization), the central organization may file a group return on your behalf. Some subordinates still must file their own. If you're unsure whether you're covered by a group return, check with the central organization, this is a question that should be answered before any of the tools in this app are useful.
Filing Calendar & Deadlines
The Form 990 (and EZ, N, PF) is due the 15th day of the 5th month after the close of your fiscal year. For calendar-year filers (the most common), that's May 15.
| Fiscal Year End | Original Due Date | Extended Due Date (Form 8868) |
|---|---|---|
| December 31 | May 15 | November 15 |
| March 31 | August 15 | February 15 |
| June 30 | November 15 | May 15 |
| September 30 | February 15 | August 15 |
Extensions
Form 8868 grants an automatic 6-month extension for Form 990, 990-EZ, and 990-PF. File before the original due date. Form 990-N (e-Postcard) cannot be extended. If you miss the original due date for a 990-N, the only option is to file late (no penalty for late filing of 990-N, but it counts against the three-consecutive-year revocation rule).
Late filing penalties
For organizations with gross receipts under $1.13M: $20 per day late, capped at $10,500 or 5% of gross receipts (whichever is less). For organizations with gross receipts over $1.13M: $110 per day, capped at $56,000 or 5%. Additional penalties apply for late filing of certain schedules. Reasonable cause relief is available but must be requested in writing with detailed explanation.
Automatic revocation
Three consecutive years of non-filing (any combination of 990, 990-EZ, 990-N) results in automatic revocation of tax-exempt status. No warning, no notice, no remedy other than reapplying for tax exemption (Form 1023 or 1024) and paying the user fee. The IRS publishes the auto-revocation list publicly, revocation appears on GuideStar, Charity Navigator, and other public databases. Donations made during the revoked period are not tax-deductible to donors.
90 days before deadline: Confirm CPA engagement and timeline. Run the tools in this app to organize source material. 60 days before: Provide complete materials to CPA. Draft begins. 30 days before: Draft delivered to board for review (use the Board Review Process generator). Filing deadline: File electronically. Cushion of 5-7 days for unexpected issues.
Schedules A–R, The Full Map
Most filers complete only a few schedules. Some complete more than half. Knowing which ones apply, and which ones are commonly missed, prevents the most common 990 errors.
| Schedule | Topic | Triggers |
|---|---|---|
| A | Public Charity Status & Public Support | All 501(c)(3) public charities, required every year |
| B | Schedule of Contributors | Any contributor of $5,000+ (special 2% rule for 170(b)(1)(A)(vi) public charities) |
| C | Political Campaign & Lobbying Activities | Any lobbying or political activity (501(c)(3) cannot do political campaign activity) |
| D | Supplemental Financial Statements | Donor-advised funds, conservation easements, art/historical collections, escrow accounts, endowments, certain liabilities |
| E | Schools | Private schools, race nondiscrimination certification |
| F | Activities Outside the U.S. | $10,000+ foreign program activity OR $5,000+ in grants outside U.S. |
| G | Fundraising/Gaming Activities | Fundraising event gross receipts > $15,000 OR any gaming |
| H | Hospitals | Hospital organizations, community benefit reporting |
| I | Grants in the U.S. | Grants greater than $5,000 to organizations, governments, or individuals |
| J | Compensation Information | Anyone with combined compensation greater than $150,000 OR other triggers |
| K | Tax-Exempt Bonds | Tax-exempt bonds outstanding |
| L | Transactions with Interested Persons | Loans, grants, business transactions, excess benefit with officers/directors/key employees |
| M | Noncash Contributions | $25,000+ in non-cash contributions OR any art, historical, qualified conservation contribution |
| N | Liquidation, Termination, Dissolution | Org terminated, liquidated, or substantially contracted |
| O | Supplemental Narrative | Used by nearly every full-990 filer for Part VI narrative responses |
| R | Related Organizations | Parent, subsidiary, brother/sister, supporting organization, or unrelated partnerships |
The four most commonly missed schedules
- Schedule L: transactions with interested persons. Any loan to or from an officer/director, any grant to a board member or family member, any business transaction over thresholds. Triggers far more often than organizations realize.
- Schedule M: non-cash contributions. The $25,000 aggregate threshold is reached faster than expected when in-kind donations of supplies, equipment, professional services, or facility use are counted.
- Schedule R: related organizations. Often missed when a "fiscal sponsor," "affiliated foundation," or "supporting organization" relationship exists informally.
- Schedule O: supplemental narrative. Not so much "missed" as "minimal." Many filers use Schedule O only for Part VI Q11b; in practice it should contain narratives for many Part VI governance questions, program accomplishments details (Part III), and any "Yes" answer that benefits from explanation.
Part VI Governance Deep Dive
Part VI of Form 990 ("Governance, Management, and Disclosure") asks a series of questions about governance practices. None of these governance policies are legally required for federal tax exemption. But the IRS asks about them in every 990, every answer becomes public, and most funders/accreditors/watchdogs treat them as expected practice.
The Part VI questions worth most of the attention
Section A: Governing Body and Management
- Q1a-b: Number of voting members of the governing body; how many are independent. "Independent" has a specific definition (no compensation from the org or related orgs, no family/business ties to officers/directors). Organizations with very few independent directors get attention.
- Q3: Did any officer, director, or key employee have a family or business relationship with another? "Yes" answers require explanation in Schedule O and may trigger Schedule L.
- Q4: Did the org delegate management duties to a management company? Common with smaller orgs using fiscal sponsors or backbone organizations.
- Q7a-b: Does the governing body have authority to designate or change members of the governing body? And to designate one or more members of the governing body? These reveal self-perpetuating boards vs. member-elected boards.
Section B: Policies
- Q11a-b: Process used to review the Form 990 before filing. Use the Board Review Process generator to document this properly.
- Q12a-c: Conflict of interest policy: written, distributed, annually signed. All three required for "yes" to all three questions.
- Q13: Whistleblower policy.
- Q14: Document retention and destruction policy. The Document Retention & Security Policy Generator produces this.
- Q15a-b: Process used to determine compensation of CEO/Executive Director (Q15a) and other key employees (Q15b). The "rebuttable presumption" 3-prong test is what the IRS expects here.
- Q16a-b: Joint venture policy with for-profit entities.
A note on the audit questions: they live in Part XII, not Part VI
A common mix-up: Part VI Line 12 is the conflict-of-interest policy, not anything about audits. The audit questions sit in Part XII, Financial Statements and Reporting: Line 2a (were the financials compiled or reviewed by an independent accountant), Line 2b (were they audited), Line 2c (does an audit or finance committee assume responsibility for oversight of the audit and selection of the accountant), and Line 3 (the federal Single Audit, required when the organization spends $1,000,000 or more in federal awards in a year). The Governance Policies Checklist generator now labels this row correctly as Part XII.
Section C: Disclosure
- Q17-18: State filing requirements; how Form 990, 990-T, and exempt application are made available to the public.
- Q19-20: Governing documents, conflict of interest policy, and financial statements made available to the public; books and records location.
Why the IRS cares
Part VI doesn't determine your tax-exempt status. It does determine your visibility to IRS Examination Division. The IRS uses Part VI responses as a "soft" enforcement screen, organizations reporting weak governance practices are statistically more likely to have other compliance issues, so they attract examination attention. Investing in adopting the recommended governance policies isn't just good practice, it lowers your audit profile.
Document Retention & Security Policy Generator, produces the document retention policy for Q14. Nonprofit HR Management Policy Generator, produces the whistleblower policy for Q13. Board Review Process tool (this app): produces the Q11a-b documentation. Compensation Disclosure Worksheet (this app): supports the Q15 rebuttable presumption documentation. Risk Management & Insurance Audit, the Risk Committee Charter supports the broader governance oversight structure that makes Part VI responses defensible.
Public Support Tests Deep Dive
For 501(c)(3) public charities classified under 170(b)(1)(A)(vi) or 509(a)(2), passing the public support test annually is the price of admission to public charity status. Failing it leads to reclassification as a private foundation, with substantially higher tax, distribution, and compliance burdens.
The 170(b)(1)(A)(vi) "donative" public charity test (1/3 test)
For organizations that receive substantial support from gifts, grants, and contributions from the public. The test averages 5 years of support:
- Numerator (public support) = total contributions, minus the portion of any single non-PC donor's 5-year cumulative giving that exceeds 2% of 5-year total support
- Denominator (total support) = all contributions + investment income + UBTI + other income
- Pass threshold = 33⅓% (one-third)
The 2% cap explained
The math behind the 2% cap is the most-misunderstood part of the test. The rule: for individuals and non-public-charity entities, contributions counted toward "public support" are capped at 2% of the org's 5-year total support. Contributions from governmental units and other public charities are NOT subject to this cap (they're counted fully in public support).
Why this matters: a single $500,000 gift from one individual donor to a $400,000-revenue org will mostly NOT count as public support, because 2% of 5-year total support might only be $40,000, so $460,000 of the gift is excluded from the numerator. This is the mechanism that prevents very large individual gifts from undermining the "publicly supported" rationale for public charity status.
The facts and circumstances test (between 10% and 33%)
If public support falls below 33⅓% but is at least 10%, the org may still qualify via the "facts and circumstances" test under Treasury Reg 1.170A-9(f)(3). This requires demonstrating ALL FIVE of:
- Continuous active program of fundraising from the general public, governmental units, or other public charities
- Representative governing body (not dominated by donors or insiders)
- Services or facilities available to the general public
- Participation in programs by representative members of the public
- Other facts (such as nature of activities, sources of support, etc.)
The facts and circumstances test is judgment-based and requires careful documentation. Working with a CPA experienced in public charity classification is strongly recommended if you find yourself in this zone.
The consequences of failure
Public support below 10% for the test period: cannot use facts and circumstances. Test failed entirely.
Public support below 33⅓% for two consecutive years (with the second year also below 10% in some interpretations): organization is reclassified as a private foundation for the third year forward. Reclassification brings:
- 1.39% excise tax on net investment income
- Mandatory annual distribution of 5% of investment assets (qualifying distributions)
- Jeopardizing investment restrictions (4944)
- Self-dealing prohibitions (4941), very strict
- Excess business holdings limits (4943)
- Public disclosure of every grant on Form 990-PF
- Loss of deduction percentage advantages (50% AGI cap for public charities vs 30% for private foundations)
- Substantially higher compliance complexity and cost
The 509(a)(2) "service revenue" public charity test
For organizations whose support is primarily from gross receipts from program activities (service fees, ticket sales, tuition, related revenue) rather than from contributions. The 509(a)(2) test has two prongs:
- Support prong: more than 33⅓% of support from gifts/grants/contributions/membership fees PLUS gross receipts from exempt-purpose activities (with per-payer/2% limits)
- Investment limit prong: no more than 33⅓% of support from investment income and UBTI combined
The Public Support Test Calculator currently supports only the 170(b)(1)(A)(vi) test. For 509(a)(2) calculations, work directly with your CPA using Schedule A Part III worksheets.
If you're approaching the 33% line in either direction: (1) Diversify funding, broader donor base reduces the impact of any single donor's 2% cap; (2) Convert large gifts to multi-year pledges, smooths timing across the 5-year test period; (3) Pursue grants from other public charities and foundations, these are NOT subject to the 2% cap; (4) Cultivate corporate giving programs (which are typically not 2%-capped if the corporation is itself a public charity-equivalent); (5) Apply for support from governmental units, which is fully counted in public support.
Compensation Reporting Deep Dive
Part VII is the most scrutinized public-disclosure section of the 990. Journalists, donors, and watchdogs pull executive compensation from Part VII for compensation studies, news stories, and donor stewardship.
Who is reportable
- All current officers, directors, and trustees: regardless of compensation. Even unpaid board members.
- Key employees: persons receiving greater than $150,000 reportable compensation who also (a) have organization-wide responsibilities, (b) manage a discrete segment representing 10%+ of assets/revenue/expenses, OR (c) have authority over 10%+ of activities. Key employees are limited to the top 20 meeting these tests.
- 5 highest-compensated employees: the 5 highest-paid employees with reportable compensation ≥ $100,000 who are NOT already listed as officer, director, key employee, or trustee.
- Former officers/directors/key employees/highest-paid: persons who held one of these positions in any of the 5 prior years and received greater than $10,000 in the current year. Includes consulting payments, deferred comp, severance, supplemental retirement.
What "compensation" means
Compensation in Part VII includes:
- Reportable compensation (Box 1 of W-2 or Box 7 of 1099-NEC): wages, salary, taxable benefits
- Retirement and other deferred compensation: employer contributions to qualified retirement plans, 457(b), 457(f), supplemental retirement
- Nontaxable benefits: employer-paid health insurance premiums, dependent care, tuition, etc.
Compensation from related organizations is reported separately. The IRS aggregates compensation across all related organizations for purposes of Schedule J trigger ($150K) and reasonableness analysis.
Schedule J triggers
Schedule J is required if ANY individual listed in Part VII Section A received total reportable + deferred + nontaxable + related-org compensation greater than $150,000. Schedule J requires disclosure of:
- Severance and change-of-control payments
- Supplemental retirement (SERP) details
- Contingent and equity-based compensation
- Deferred compensation balances
- First-class or charter travel
- Travel for companions (spouse, family)
- Tax indemnification or gross-up payments
- Discretionary spending account
- Housing allowance or personal use of org-provided residence
- Payments for business use of personal residence
- Health or social club dues
- Personal services (e.g., chef, chauffeur, maid)
The "Rebuttable Presumption of Reasonableness" (4958)
IRC 4958 and Treas. Reg. 53.4958-6 establish a process by which the IRS will rebuttably presume executive compensation is reasonable. Meeting all three criteria provides strong protection against intermediate-sanction penalties:
- Approved by an independent body: the board, a board committee, or an officer/director without a conflict of interest. The "disqualified person" (the executive whose comp is being set) cannot participate in or be present during the decision.
- Appropriate comparable data: salary surveys, GuideStar/Candid nonprofit comp reports, ERI data, or comparable 990 research. Comparables should be for organizations of similar size, geography, and mission.
- Contemporaneous documentation: minutes or written record made at the time of the decision (not after) that document the comparables used, the discussion, and the basis for concluding compensation is reasonable.
What happens if compensation is found unreasonable
If compensation is found "excessive" (unreasonable), 4958 imposes intermediate sanctions:
- The disqualified person (executive) owes 25% excise tax on the excess plus must return the excess to the org
- If not corrected, an additional 200% tax applies
- Organization managers who knowingly participated in the excess benefit transaction face their own 10% tax (capped at $20,000 per transaction per manager)
- The organization may face loss of tax-exempt status in extreme cases
Run an annual compensation review for the Executive Director/CEO. Use comparable data from at least two sources. Convene a Compensation Committee (or Executive Committee, or full board minus the Executive Director). Discuss comparables openly. Document the discussion and the vote in minutes BEFORE the next paycheck reflecting any change. Use the Compensation Disclosure Worksheet generator to structure this annually.
Functional Expense Allocation Deep Dive
Part IX requires every expense to be allocated across three columns: (B) Program services, (C) Management and general, (D) Fundraising. Column (A) is the unallocated total. Getting this right matters more than most filers realize.
Why functional expense allocation matters
- Donor scrutiny: the "program expense ratio" (Column B as % of Column A) is the single most-quoted metric in donor decisions and watchdog ratings
- Charity Navigator: uses program expense ratio in its Financial Health score; below 65% is concerning
- BBB Wise Giving Alliance: 65% program minimum + 35% fundraising maximum thresholds
- Funder grant scrutiny: major institutional funders examine the allocation for reasonableness and consistency
- IRS examination risk: aggressively under-allocating to management/fundraising is a red flag
- State charity regulators: some states (notably California, New York, Florida, Pennsylvania) examine allocation methodology in registration renewals
The four allocation approaches
- Direct identification: the expense is identifiable as supporting a single function. Best methodology where it applies. (Example: program director salary ⇒ 100% program; auditor fees ⇒ 100% M&G; capital campaign consultant ⇒ 100% fundraising.)
- Time studies: for salaries and time-based costs. Sample 1-2 weeks per quarter; staff record what they're working on in 15-minute increments. Aggregate to produce annual allocation percentages. Most defensible methodology for salary allocation.
- Square footage: for occupancy costs (rent, utilities, repairs). Measure or estimate program space vs admin space vs fundraising space; allocate proportionally.
- Proportional methods: allocating shared costs proportionally to direct costs, headcount, or other rational basis.
SOP 98-2 Joint Cost Allocation
Statement of Position 98-2 governs allocation of "joint costs" between program and fundraising. A joint cost is one that supports both a program purpose and a fundraising appeal (most commonly: an educational direct-mail piece that also asks for donations). SOP 98-2 requires ALL THREE tests to be met before any portion can be allocated away from fundraising:
- Purpose Test: the activity must have a bona fide program purpose, separate from fundraising. A "general awareness" mailing usually fails this test.
- Audience Test: the audience must be selected based on need or ability to take a specific program action, not based on capacity or likelihood to contribute. Mailing to past donors usually fails.
- Content Test: the materials must call for specific action by the recipient that helps accomplish the org's mission. Generic "support our cause" appeals fail; "smoke detectors save lives, check yours today" succeeds.
Failure of any test means 100% of joint costs are classified as fundraising. Document each test in writing for every joint activity. This is one of the most-examined areas when the IRS does scrutinize functional expense allocations.
Reasonableness benchmarks
| Ratio | Typical Range | Concerning |
|---|---|---|
| Program services / Total | 65-85% | Below 65% OR above 95% |
| Management & general / Total | 5-15% | Above 20% or near 0% |
| Fundraising / Total | 5-20% | Above 25% (without capital campaign rationale) or 0% on a meaningful budget |
These are typical ranges, not rules. Legitimate variations exist: new organizations, organizations conducting capital campaigns, advocacy-heavy nonprofits, grant-making foundations, and organizations with significant in-kind program services may legitimately fall outside these ranges. The key is documenting the methodology that produces your allocation, not chasing a benchmark number.
The temptation to "make the program ratio look good" by aggressively allocating shared costs to program is real and dangerous. Aggressive over-allocation is the single most common form of 990 dishonesty, and the IRS, watchdogs, and journalists all know to look for it. Adopt a documented methodology, apply it consistently, and let the numbers be what they are.
Common 990 Pitfalls and How to Avoid Them
The Form 990 has hundreds of fields, dozens of schedules, and decades of accumulated reporting rules. These are the issues that come up most often in real nonprofit filings.
Schedule L: the most commonly missed schedule
Schedule L reports transactions with "interested persons", officers, directors, key employees, family members, and entities they control. Common Schedule L triggers that get missed:
- Loans to or from the organization (including informal advances)
- Grants to a board member's family member
- Business transactions with a board member's company over thresholds
- "Excess benefit" transactions under 4958
- Rent paid to a board member for facility use
- Professional services from a board member (auditor, lawyer, consultant) over thresholds
Run a Schedule L screen annually: ask every officer/director/key employee to disclose any transactions during the year. The Conflict of Interest annual disclosure (Q12) is the upstream mechanism.
Part III: program service accomplishments, written too briefly
Part III asks for narrative descriptions of the organization's program service accomplishments, including for the three largest programs (by expense). This is the section donors actually read. Many filers write 2-3 sentences and miss the opportunity to communicate impact. Use Schedule O if more space is needed. Lead with outcomes, not activities. Quantify (people served, units delivered, hours provided) where possible. The Program Service Accomplishments generator, with its AI drafter, helps you build out a fuller Part III narrative from your program details.
Part VI Q11a-b: "yes" without process
Answering "yes" to "Did the organization provide a complete copy of this Form 990 to all members of its governing body before filing?" requires actual process. Email-blasting the draft 48 hours before filing doesn't constitute meaningful review. Use the Board Review Process generator to document a defensible process, and start it 2-4 weeks before filing.
Compensation Q15 without rebuttable presumption documentation
Q15a-b asks whether the process used to set CEO/Executive Director and other key employee compensation included: (1) review and approval by independent persons, (2) comparability data, AND (3) contemporaneous substantiation. All three are required for "yes" to qualify for IRS rebuttable presumption. Many filers say "yes" without all three; if examined, the protection collapses.
Volunteer hours reported as expenses
Volunteer time is NOT a reportable expense on the 990. Even though many nonprofits track and value volunteer hours for grant reporting, GAAP recognition, or insurance purposes, none of that goes on Form 990. The 990 reports only actual cash and in-kind contributions. (Donated professional services that meet GAAP recognition criteria CAN be reported, but only with proper valuation.)
Aggregating with related organizations: missed
Compensation reporting requires aggregating across related organizations. A $100K salary from the filer plus $80K from a related foundation = $180K combined, which triggers Schedule J. Schedule R relationships often expose related-org compensation that wasn't being aggregated.
"Other Expenses" line: too much in the catch-all
Part IX line 24 ("Other expenses") is meant for items not fitting in other categories. If "Other" is the biggest expense category, the 990 raises questions. Discipline expense categorization at the bookkeeping level so other-expenses stays small.
Year-over-year inconsistency without explanation
Material changes from prior year, in revenue mix, expense categories, governance answers, functional allocation percentages, even mission statement, should be explained in Schedule O. Unexplained year-over-year changes are an examination red flag.
State filings forgotten
The federal Form 990 is one filing. Most states require their own annual charity registration renewal, which may require attaching the 990 plus state-specific schedules. States vary widely: some require audited financials, some require specific narrative disclosures, some require notarization. Check your state attorney general's charitable registration unit.
The 990 is filed annually for a reason: it's a continuous public record. Every year's filing is compared to prior years. Every governance answer is scrutinized by potential funders. Every compensation number can become news. Treat the 990 as the most important external communication of the year, not a compliance afterthought. Run the seven generators 60-90 days before filing, document everything, and let the numbers tell a defensible story.
🎨 Document Branding
Brand the documents this tool generates, across all three forms. Your organization identity, branding (letterhead, footer, and signature), language, and connections are all set once on the My Organization page and carry across every app. You can even customize your organization's language there, renaming platform terms like donation or donor to the words your organization uses. What you can set:
- Letterhead: upload your organization's letterhead image; it appears at the top of every Word document.
- Footer: your org name, address, and EIN (from your profile) print at the bottom, along with any phone, email, and website you add here, plus optional page numbers.
Set it up once and it's applied automatically to your exports, in the 1023 tool, the 1024 tool, and the 990 tool alike.
Signature details. Beyond the signature image, you can also save a default closing (for example, "Sincerely,"), your name, and your title. These are added with your signature when you export a document, so letters sign off correctly without retyping them each time.
Snippets and stats. Your settings also include a Stats & Snippets panel. Save reusable blocks of text you use often (your mission statement, standard boilerplate, a recurring call to action) and copy any of them into a document you are drafting, so you never rewrite the same wording twice.
↑ Back to topAdministrator Access
This app supports a separate Administrator role with elevated permissions. The administrator can view all user accounts, reset application data, and perform setup tasks.
First-Time Setup
From the sign-in screen, click Administrator Access in the side links below the Sign In button. On first use, you will be asked to set a password (enter once, confirm once). This password is stored as a hash in your browser's local storage, the actual password is never stored in cleartext.
Subsequent Sign-In
After setup, the Administrator Access link prompts only for the password. Successful sign-in lands you on the dashboard with administrative privileges enabled (synthetic user admin@local, isSuperAdmin: true).
Forgot the Admin Password?
The password is stored locally in your browser and cannot be recovered. To reset, sign in as any regular user, open the Admin Settings page if you have admin privileges, and use Reset All Data. This clears all application data including the admin password hash, allowing you to set a new one. Be aware that this also clears all generated documents and user accounts, export anything you want to keep first.
Because the app runs entirely in your browser with no server-side accounts, the administrator role is browser-specific. If you sign in from a different browser or device, you will need to complete first-time setup again on that device.
Contact & Support
The IRS Forms Assistant, covering Form 1023, Form 1024, and Form 990, is part of All In One Nonprofit, a growing library of self-service tools and learning content for nonprofit organizations. We are nonprofit board members ourselves, building the tools we wished existed when we started.
Looking for help beyond the platform? See our Helpful Resources page for vetted external resources on legal and tax filing, funder research, governance training, insurance, technology discounts, and more.
From our Learn library: Form 1023 vs Form 1023-EZ and the IRS language for your Articles.
All In One Nonprofit's nonprofit lifecycle tools
- Nonprofit Formation (part of the Formation Suite), covers state incorporation through state registration. Use this BEFORE Form 1023 or Form 1024.
- Form 1023, this app, the federal application step for 501(c)(3) status. Comes after state incorporation.
- Form 1024, this app, the federal application step for other exempt status (501(c)(4), (c)(5), (c)(6), (c)(7)). Comes after state incorporation.
- Form 990, this app (Operations & Compliance Suite), the annual federal filing once you're exempt. Use every year after approval.
- Document Retention & Security Policy Generator, produces policies referenced in Form 990 Part VI.
- Nonprofit HR Management Policy Generator, once you have employees.
- Risk Management & Insurance Audit, D&O insurance, risk register, crisis plan.
- See all suites & pricing
Questions, suggestions, bug reports
We read every message and incorporate feedback into the tools. Reach us through the contact form on allinonenonprofit.com or via the support links on the main site.
A note on legal advice
All In One Nonprofit provides plain-language educational tools and document drafts, not legal advice. For decisions with legal consequences, consult a qualified attorney who works with nonprofits.
Important disclaimers
This tool generates document drafts, calculations, and walkthroughs based on widely-applicable Form 1023, Form 1024, and Form 990 reporting rules. It is not tax advice, not legal advice, and does not establish a CPA-client or attorney-client relationship. The rules behind all three filings are detailed, and edge cases (group rulings, supporting organizations, fiscal-year changes, mergers, foreign affiliates, retroactive reinstatement, and certain industry-specific rules) may produce different answers than this tool's general logic. Always confirm with a qualified CPA or attorney before relying on any output for an actual filing. The full Form 1023 and Form 1024 in particular benefit substantially from CPA or attorney review before submission. All In One Nonprofit is not responsible for filing decisions, IRS determinations, penalties, or other consequences arising from use of the outputs.
↑ Back to topWorking with your organization
All In One Nonprofit works as a shared organization. From My Organization you can set up your organization and see who has joined, and everyone is recognized across every app once they sign in. Anyone who signs in with an email address on your organization's own domain (for example [email protected]) joins automatically; people using a personal address such as Gmail, Yahoo, or Outlook join with the invite code or email invitation you send them. Signing in is passwordless: enter your email at the member portal, app.allinonenonprofit.com, and we email you a one-click sign-in link (signing in with Google also works). New to the platform? The Platform Workflows shows what to do first, by role. For step-by-step walkthroughs of real situations, see the Workflow Scenarios. Deeper in-app collaboration arrives with your suite as we roll it out, so you can set up your organization now and grow into it.
See the whole platform
Want to see how this fits the rest of All In One Nonprofit? The Complete Platform Guide walks through every app and suite, with screenshots.
Open the Complete Platform Guide →