Special to the Philanthropy Journal
By James Gilmer
Nonprofit organizations and their tax preparers are gearing up for a busy season. In addition to the November 15th federal deadline for Form 990, many organizations are rushing to complete independent financial statements with their auditors. At the same time, organizations can be expected to file applications to renew their charitable solicitation registration in as many as half of the states that have requirements.
The purpose of this post is twofold.
First, consider this a friendly reminder to renew your state solicitation registrations on time. Organizations can avoid potential late filing fees and stress by submitting applications well before their due dates.
Second, nonprofit organizations facing these tight deadlines have another option. State charitable solicitation renewals depend on the completion of Form 990. By starting a conversation with their tax preparer, organizations can stress the importance of early filing of Form 990, which in turn allows state registrations to be completed sooner.
Now let’s look at the busy season.
The majority of nonprofit organizations will have a federal deadline on November 15th. Organizations that have a calendar tax year end (December 31) have reached the maximum due date to file Form 990. Organizations whose tax year ends June 30th must file either Form 990 or Form 8868, an extension that moves the deadline to May 15, 2019.
Charitable solicitation renewal deadlines in most states follow roughly the same schedule. The biggest misconception, however, is that the due date in all states will align with the federal due date. Organizations with tax years ending December 31 or June 30 will have deadlines ranging from November 15, 2018 through January 1, 2019.
Those states include:
- California
- Colorado
- Connecticut
- Hawaii
- Illinois
- Kansas
- Kentucky
- Maine
- Maryland
- Massachusetts
- Michigan
- Mississippi
- New Hampshire
- New Jersey
- New Mexico
- New York
- North Carolina
- Ohio
- Oregon
- Pennsylvania
- South Carolina
- Tennessee
- Virginia
- Washington
- Wisconsin
This list won’t apply to all organizations in the same way. Some groups may have to file extensions, whereas others will renew their licenses. Other states have deadlines that don’t match the federal deadline at all, and your organization may have a due date in a state not listed above.
If your organization is registered to solicit in these states, it’s time to start filing your applications. Preparation, submission, and tracking of state solicitation registrations can also be outsourced to a reliable compliance provider. This approach saves valuable staff or volunteer time, and allows your organization to focus on its mission and charitable programs.
The single unifying factor in state solicitation registration requirements is the organization’s tax return, Form 990. Even in states with deadlines that don’t match the federal one, your organization can be expected to submit a copy of Form 990 or information from it.
If your organization finds itself up against tight regulatory deadlines, understand that the conversation starts with you and your tax preparer. Organizations that file Form 990 at the last minute are less able to submit state registrations on time, which incurs late fees and creates unnecessary last minute rush. By discussing proactive filing of Form 990 in this and future years with your tax preparer, your organization will be able to prevent last minute scrambling and effectively meet your state charitable solicitation renewal deadlines.
James Gilmer is a compliance specialist at Harbor Compliance, a leading provider of compliance solutions for companies of all types and sizes. Founded by a team of government licensing specialists and technology trailblazers, Harbor Compliance has helped more than 10,000 organizations apply for, secure, and maintain licensing across all industries. James is also a co-founder of Berks Sinfonietta, Inc., a 501(c)(3) nonprofit chamber orchestra in Reading, Pennsylvania.
