501(c)(3) Application Checklist

501(c)(3) TAX-EXEMPT STATUS APPLICATION CHECKLIST

TABLE OF CONTENTS

1. Eligibility Determination
2. Pre-Application Requirements
3. Form 1023 — Full Application Checklist
4. Form 1023-EZ — Streamlined Application Checklist
5. Required Attachments and Schedules
6. Post-Filing Requirements
7. State-Specific Considerations
8. Sources and References

1. ELIGIBILITY DETERMINATION

1.1 — Threshold Questions

☐ The organization is organized as a corporation, LLC, unincorporated association, or trust

☐ The organization is organized for one or more exempt purposes under IRC § 501(c)(3): charitable, religious, educational, scientific, literary, testing for public safety, fostering amateur sports, or prevention of cruelty to children or animals

☐ The organization is NOT a private foundation (or is willing to comply with IRC § 509 restrictions)

☐ The organization was formed fewer than 27 months ago (for retroactive exemption) — IRC § 508(a)

1.2 — Form 1023-EZ Eligibility (if applicable)

☐ Projected annual gross receipts of $50,000 or less for each of the next 3 years

☐ Total assets of $250,000 or less

☐ Not a successor to a for-profit entity

☐ Not a foreign organization

☐ Not a limited liability company (LLC)

☐ Not applying under a group exemption

☐ Completed the IRS Form 1023-EZ Eligibility Worksheet (all answers "No")

2. PRE-APPLICATION REQUIREMENTS

2.1 — State Formation

☐ Articles of Incorporation filed with Secretary of State and approved

☐ Articles contain required IRS purpose clause (IRC § 501(c)(3) language)

☐ Articles contain required dissolution clause (Treas. Reg. § 1.501(c)(3)-1(b)(4))

☐ Articles do NOT contain prohibited provisions (private inurement, political activity)

☐ Conformed/certified copy of filed articles obtained

2.2 — Governance Documents

☐ Bylaws adopted by the Board of Directors

☐ Conflict of interest policy adopted (IRS Appendix A sample or equivalent)

☐ Organizational meeting minutes documenting adoption of bylaws and policies

☐ Initial Board of Directors appointed

☐ Officers elected (President/Chair, Secretary, Treasurer at minimum)

2.3 — Federal and State Registrations

☐ Employer Identification Number (EIN) obtained — IRS Form SS-4 or online at IRS.gov

☐ State tax-exemption application filed (if required by state)

☐ State charitable solicitation registration filed (if applicable — required in 41 states + D.C.)

3. FORM 1023 — FULL APPLICATION CHECKLIST

Part I — Identification of Applicant

☐ Legal name of organization as shown on organizing document

☐ EIN (must be obtained before filing)

☐ Mailing address and contact information

☐ Month of annual accounting period end

☐ Name and address of primary contact person

Part II — Organizational Structure

☐ Type of organization identified (corporation, LLC, unincorporated association, trust)

☐ Copy of organizing document attached (articles of incorporation)

☐ Copy of bylaws attached (if adopted)

Part III — Required Provisions in Organizing Document

☐ Purpose clause limits activities to IRC § 501(c)(3) purposes — Treas. Reg. § 1.501(c)(3)-1(b)(1)

☐ Dissolution clause directs assets to exempt purposes — Treas. Reg. § 1.501(c)(3)-1(b)(4)

☐ No authorization for activities violating IRC § 501(c)(3) requirements

Part IV — Narrative Description of Activities

☐ Detailed description of all past, present, and planned activities

☐ Description of who benefits from activities

☐ Explanation of how activities further exempt purposes

☐ Revenue sources described

☐ Fundraising methods described

Part V — Compensation and Financial Arrangements

☐ List of officers, directors, trustees, and key employees with compensation

☐ Compensation-setting process described

☐ Conflict of interest policy attached

☐ Financial transactions with interested persons disclosed

Part VI — Members and Other Individuals Who Receive Benefits

☐ Membership structure described (or statement that there are no members)

☐ Benefits provided to members described

Part VII — History

☐ Successor organization status disclosed (if applicable)

Part VIII — Specific Activities

☐ Political campaign intervention — confirmed NO

☐ Legislative activities — describe any lobbying or § 501(h) election

☐ Gaming activities disclosed

☐ Fundraising activities described

☐ Joint venture / partnership arrangements disclosed

Part IX — Financial Data

☐ Revenue and expenses for current year and 3 prior years (or projections for new organizations)

☐ Balance sheet for current year

☐ All financial data prepared on consistent accounting basis (cash or accrual)

Part X — Public Charity Status

☐ Public charity classification selected under IRC § 509(a)(1) or § 509(a)(2)

☐ Supporting organization status under § 509(a)(3) (if applicable)

☐ Public support test calculations (if applicable)

User Fee

☐ User fee paid through Pay.gov — currently $600 (verify with Rev. Proc. 2025-5)

4. FORM 1023-EZ — STREAMLINED APPLICATION CHECKLIST

☐ Form 1023-EZ Eligibility Worksheet completed — all responses confirm eligibility

☐ Form completed on Pay.gov

☐ Attestations signed confirming:
- Organization is organized and operated exclusively for IRC § 501(c)(3) purposes
- Organizing document contains required purpose and dissolution clauses
- Organization will not engage in prohibited political activity
- No substantial part of activities will consist of lobbying

☐ User fee paid through Pay.gov — currently $275 (verify with Rev. Proc. 2025-5)

5. REQUIRED ATTACHMENTS AND SCHEDULES

Depending on the organization type, the following schedules may be required with Form 1023:

☐ Schedule A — Churches (IRC § 170(b)(1)(A)(i))

☐ Schedule B — Schools, colleges, universities (IRC § 170(b)(1)(A)(ii))

☐ Schedule C — Hospitals and medical research organizations (IRC § 170(b)(1)(A)(iii))

☐ Schedule D — Supporting organizations under IRC § 509(a)(3)

☐ Schedule E — Organizations not filing within 27 months of formation

☐ Schedule F — Homes for the elderly or handicapped

☐ Schedule G — Successors to for-profit entities

☐ Schedule H — Organizations providing scholarships, fellowships, educational loans

6. POST-FILING REQUIREMENTS

6.1 — After Receiving Determination Letter

☐ Determination letter received and filed in permanent corporate records

☐ Annual information return filing obligation noted:
- Form 990 (gross receipts > $200,000 or total assets > $500,000)
- Form 990-EZ (gross receipts < $200,000 AND total assets < $500,000)
- Form 990-N (e-Postcard) (gross receipts normally ≤ $50,000)

☐ State annual report filings scheduled

☐ State charitable solicitation registration renewed (if applicable)

☐ Public disclosure requirements noted — IRC § 6104(d) (Form 1023, determination letter, and Form 990 must be made available for public inspection)

6.2 — Ongoing Compliance

☐ Annual Form 990 filing calendar established (due 15th day of 5th month after fiscal year end)

☐ Board governance calendar established (annual meetings, conflict of interest disclosures)

☐ Donor acknowledgment procedures implemented (IRC § 170(f)(8))

☐ Unrelated business income tax procedures established (Form 990-T if applicable)

☐ Employment tax obligations established (Forms 941, W-2, 1099 as applicable)

7. STATE-SPECIFIC CONSIDERATIONS

SOURCES AND REFERENCES

• IRS, "How to Apply for 501(c)(3) Status," https://www.irs.gov/charities-non-profits/how-to-apply-for-501c3-status
• IRS, "About Form 1023," https://www.irs.gov/forms-pubs/about-form-1023
• IRS, "Instructions for Form 1023 (Rev. December 2024)," https://www.irs.gov/instructions/i1023
• IRS, "About Form 1023-EZ," https://www.irs.gov/forms-pubs/about-form-1023-ez
• IRS Publication 557, "Tax-Exempt Status for Your Organization"
• IRS, "Charitable Solicitation — State Requirements," https://www.irs.gov/charities-non-profits/charitable-organizations/charitable-solicitation-state-requirements
• Treasury Regulation § 1.501(c)(3)-1
• Internal Revenue Code §§ 501(c)(3), 508, 509