What would happen if I were to call the IRS, have them enable my Employer Identification Number (EIN) to file a 990-N (we’re under $5k/year in gross receipts), and then file a 990-N at the end of the year? Perhaps they would flag my e-postcard since we have never filed one, but the EIN has existed for many years. Can my organization apply for a new EIN?
Since your organization has existed for many years, but has not filed any annual information returns (990/990EZ, 990-N), the IRS will look back and revoke your tax exempt status. You will need to apply for tax exempt status.
Your current organization could dissolve and some of your leaders could form a new organization with a new name and new EIN. But the former head of the IRS Exempt Organizations, Lois Lerner, has said,
“I don’t know if it’s purposeful, but I do know that it’s important for people to understand getting a new EIN is not the answer. It’s like getting a Social Security number, they’re very easy to get. You can get one, we’ll enter it in our system but when we actually start looking and you’ve got two EINs, and one of them is revoked, unless you came back in, the other is not going to be legitimate in terms of your status. So keep that in mind.”
So, getting a new EIN does not satisfy the IRS. You should probably look into getting your tax exempt status reinstated. I can help with that. More information here.
Carol Topp, CPA