One of the most common questions we hear from new state charity registration filers is in which fiscal year they should file. This is not a problem for renewals, because it is clear they are reporting on the previous year. But, should an organization that has never filed in a state use the current fiscal year or the previous one?
Unlike many other questions involving state charitable solicitation registration, this one is more or less straightforward. You should file using the year of your most recently filed tax form, remembering that the states are expecting organizations to register prior to solicitation.
Let’s go through some scenarios to see what this means.
- A new charity that has not yet completed a fiscal year or filed an IRS 990, 990-PF, or 990-EZ would file projected information for the current fiscal year and then send the filed form to the states once it’s ready.
- An existing charity that has not solicited in a state in the past but anticipates doing so will register based on their most recently completed fiscal year.
- An existing charity that has already solicited in a state but is only recently aware of the state’s charitable solicitation requirement would file based on their most recently filed IRS 990, 990-PF, or 990-EZ. Note that some states may require you to back-file a few years. (See our blog on noncompliance).
- In this scenario, because the states require registration prior to solicitation, if you are near the end of your fiscal year, you would use your prior year form and then renew in a few months when your renewals are due.
Thankfully, with Simple Charity Registration you can register more easily and copy your data from one year to the next. Straightforward and Simple!