Will the IRS assess late filing penalties for the three years my organization failed to file its return or notice, or for any other earlier year we didn’t file?
The IRS has decided not to impose any late filing penalties against organizations on the list of automatically revoked organizations (Auto Revocation List) for any of the three consecutive years they failed to file, or for any prior periods. Further, an automatically revoked organization does not need to file any Form 990, Form 990-EZ, or Form 990-N that was delinquent at the time of automatic revocation. It must, however, comply with all filing requirements after automatic revocation to avoid incurring penalties in the future.
Certain larger organizations seeking retroactive reinstatement, however, must submit with their applications for reinstatement all delinquent annual information returns beginning with the three-year period for which they were automatically revoked. For more information, see Revenue Procedure 2014-11.