As noted previously on the Exempt Organizations Blog, the IRS has put in place certain procedures whereby tax-exempt organizations that have had their exempt status can apply for reinstatement of tax-exempt status and request retroactive reinstatement. For small organizations, in particular, Notice 2011-43 and Rev. Proc. 2011-36 provide "transitional relief" in the form of a reduced filing fee of $100 and a lesser burden for showing reasonable cause for filing failure, thereby allowing reinstatement back to the date of revocation. In order to qualify for small organization transitional relief under Notice 2011-43/Rev. Proc. 2011-36, an organization must:
- Not have been required to file Form 990 or 990-EZ for tax years beginning before 2007
- Been eligible to file Form 990-N for 2007, 2008, and 2009
- Submit its application for reinstatement for exempt status by December 31, 2012.