Q: Are we still tax-exempt after not filing 990N since 2018?

A: Your 501(c)(7) tax-exempt status may have been automatically revoked due to your failure to file the entities tax return for three consecutive years. Section 6033(j) of the Internal Revenue Code states (in so many words) that a tax-exempt organization's status can be automatically revoked if it fails to file tax returns for 3 consecutive years. While certain organizations are exempt from these filing requirements under IRC 6033(a)(3) and other sections, 501(c)(7) organizations are not explicitly listed in the exemptions. It is still possible you fall under an exception, but for many tax-exempt organizations, their tax-exempt status is revoked after 3 years of failing to file the required returns.

To confirm your organization's current status, you should be able to look it up using the IRS Tax Exempt Organization Search (TEOS) tool on the IRS website. https://www.irs.gov/charities-non-profits/tax-exempt-organization-search.

If your status is revoked, you may be able to apply for reinstatement. Retroactive reinstatement may be possible under specific circumstances, and filing delinquent returns may be required as part of the reinstatement process. There can be penalties and there can be reasonable cause excuses that allow for the waiver of those penalties. It all depends on a variety of factors. Given the complexities involved, consulting a legal or tax professional specializing in nonprofit organizations is strongly advised.