Before 2006, small charities with less than $25,000 of annual gross receipts were not required to file Form 990.  After 2006, small charities are required to file Form 990-N (e-Postcard).   Failure to file Form 990-N for three consecutive years generally results in loss of tax-exempt status.  As of May 17, 2010, calendar year small charities that have not filed Form 990-N for the 2007 through 2009 tax years are in jeopardy of losing their tax-exempt status.   We suspect several thousands of small charities are currently in jeopardy of losing tax-exempt status for failure to file Form 990-N.

The IRS recently announced, however, that  it will do what it can to help small charities avoid losing their tax-exempt status.   Although the IRS has not clarified this statement, it is possible this statement means the IRS will not automatically revoke the tax-exempt status of every late filer.  If your small charity still has not filed, it is advisable to file Form 990-N as soon

Joint ventures between Section 501(c)(3) organizations and for-profit parties are becoming more and more common.  The attached memorandum (which may be obtained by clicking the link below) provides a brief overview of tax issues related to joint ventures between tax-exempt and for profit entities:

Structuring Joint Ventures