Nonprofit and 501(c)(3) Compliance
Form 990, Form 199 and RRF-1 Filing for California Nonprofits
You run a California nonprofit, and three separate agencies want their own filing from you every year - the IRS, the Franchise Tax Board and the Attorney General, each with its own threshold and its own penalty for missing it. We prepare all three filings, put your financial statements in proper shape, and give your board a straight answer on whether the law requires an audit. We do not perform audits - which is exactly why the answer is straight.
3
Agencies that each want an annual filing: IRS, FTB, Attorney General
May 15
Deadline for all three filings, for calendar-year nonprofits
$2M
Gross revenue at which California makes an independent CPA audit mandatory
3 years
Consecutive missed 990s before the IRS revokes exemption automatically
Does our nonprofit need an audit, a review, or a compilation?
An independent CPA audit is mandatory once a registered California charity reaches $2,000,000 in gross revenue - not counting government grants and contracts where the agency requires its own accounting of the money (Gov. Code section 12586(e)). Spending $1,000,000 or more of federal award money in one year triggers a separate federal-grant audit called a Single Audit. Below those lines, a review or compilation is a board or funder choice, not a legal duty.
When Boards Call Us
The nonprofit problems we are usually brought in to fix
Your Registry status says Delinquent
A grantmaker checked the Attorney General's Registry of Charities and Fundraisers, and your charity shows Delinquent - meaning it may not legally solicit or spend charitable money in California. The fix is mechanical: file every missing RRF-1 with its matching return, pay the fees, confirm the status changed.
Nobody can remember the last Form 990 that went out
A volunteer treasurer left, and the filing history went with them. We pull the real record from the IRS, the Attorney General's Registry and your FTB account, then hand your board a written list of every unfiled year - before you commit to anything.
The IRS revoked your exemption automatically
Three straight years without a Form 990 and the IRS cancels your exemption automatically - no warning letter, and the revocation itself cannot be appealed (IRC section 6033(j)). Getting it back means a new exemption application, plus separately clearing the Franchise Tax Board and the Registry.
The board is arguing about whether an audit is required
One director read a grant agreement, another read a blog post, and the numbers in the room do not match. We do not sell audits, so the answer you get from us is an answer, not a sales pitch. We walk your actual revenue and federal spending through the legal tests.
Your books are not ready for the auditor's document list
The audit is scheduled, the auditor's document request list has arrived, and your books do not yet split costs between programs, management and fundraising. We close the books, build that split, and hand your auditor a clean starting point. No firm can audit books it keeps.
The Board Question
Audit, review or compilation - what each one gives you, and what triggers it
Work down the trigger rows first. The highest line you cross sets your legal floor; everything below it is a board or funder choice, not a California requirement.
Scroll the table sideways to compare all three
The Annual Cycle
How a California nonprofit filing year actually runs
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Close the books, with costs already split by function
Match every bank and investment account to its statements for all twelve months, and split shared costs across programs, management and fundraising as the year runs. Doing that split in April, from memory, is how program-spending ratios end up wrong.
- 2
Pin down gross receipts and total assets
Gross receipts - everything that came in before any expenses - and year-end total assets decide which federal return you owe, not your budget. Assets matter on their own: a small organization sitting on a building can owe the full Form 990 despite modest revenue.
- 3
Determine Form 990, 990-EZ or 990-N
Form 990-N, the e-Postcard, if gross receipts are normally $50,000 or less. Form 990-EZ if receipts are under $200,000 AND assets under $500,000. Cross either line - $200,000 in receipts OR $500,000 in assets - and you file the full Form 990.
- 4
Screen for taxable business income
Some income is taxable even for a nonprofit: hall rental with staffing, advertising sales, property bought with borrowed money. That income goes on Form 990-T, with California Form 109 covering the same income - and under IRC section 512(a)(6) each activity is tallied in its own silo, so a loss in one cannot shelter another.
- 5
Prepare California Form 199 or 199N
Filing the federal Form 990 does not satisfy California. The Franchise Tax Board wants its own return: the short online FTB 199N if gross receipts are normally $50,000 or less, Form 199 above that. There is no Form 199 filing fee anymore - guides still telling you to send a check are out of date.
- 6
Prepare Form RRF-1 for the Attorney General's Registry
The Registry of Charities and Fundraisers requires an annual RRF-1 from essentially every registered charity, at every size, with a fee that scales with revenue. Too small to file a 990 or 990-EZ? Form CT-TR-1 must go with it - without it the RRF-1 counts as incomplete, and incomplete means Delinquent.
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Run the audit test before the year is behind you
Hit $2,000,000 in gross revenue - excluding qualifying government grants and contracts - and an independent CPA audit is mandatory for that same fiscal year, not the next one. A large one-time gift in month eleven can create an audit bill your board never budgeted.
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Board review, then file and confirm
Form 990 Part VI asks in writing whether your board reviewed the return before filing, so make it a real agenda item with minutes. Then e-file federal and state, submit the Registry renewal - and go back to confirm the Registry status actually updated. Do not assume it did.
Underneath The Return
Four things that decide whether your Form 990 reads well
A Form 990 is a public document. Grantmakers, charity raters and your own donors read it before they read anything you write about yourself. These four mechanics decide whether the return supports your case or quietly undermines it. We prepare the filings and keep the books underneath them - we do not perform audits, reviews or Single Audits, and we will say so plainly when that is what you need.
Public support test: 509(a)(1) versus 509(a)(2)
Your public charity status is retested every year on Schedule A, over a rolling five-year window. Broadly, at least one-third of your support must come from the public, and large single gifts get capped in the count - so one windfall year can push you toward private foundation status.
Taxable side income and the section 512(a)(6) silos
Income from a regular business activity unrelated to your mission is taxable - Form 990-T is due once that gross income reaches $1,000. Space-only hall rental is usually fine; rental with staffing or catering often is not. Under IRC section 512(a)(6), a loss in one activity cannot shelter profit in another.
Functional expenses and the program-spending ratio
Form 990 Part IX splits every dollar you spent into programs, management and fundraising - and that split is the ratio grantmakers judge you on. It has to be built into your books all year, on a written basis like time studies or square footage, not estimated in April.
Registration and good standing on the Registry
Registration with the Attorney General starts with Form CT-1, due within 30 days of first receiving charitable money, and stays alive through the annual RRF-1. Miss it and status slides from Delinquent to Suspended to Revoked - with late fees directors and officers can be held personally liable for.
Who Does The Work
The people who prepare your filings
AJ Singh
Founder and Managing Partner, G&S Accountancy Inc
CPA and Enrolled Agent
AJ Singh, CPA and Enrolled Agent - federally authorized to represent taxpayers before the IRS. That matters here for one reason: a missed nonprofit filing does not stay a filing problem. Three missed years becomes an automatic revocation, and a revocation becomes a reinstatement application, a Franchise Tax Board problem and a Registry problem all at once. AJ handles the IRS representation himself. He also gives boards the audit answer directly - easy advice to keep honest when the firm does not sell audits. The firm has served as auditor of record for California nonprofits and private foundations, issuing independent opinions under US auditing standards alongside the Form 990-PF, California Form 199 and RRF-1 filings that sit beside them.
Nonprofit Filing and Bookkeeping Team
Form 990 series preparation, FTB Form 199, RRF-1 and fund-accounting bookkeeping
The team that closes the books, builds the split of costs across programs, management and fundraising, prepares the 990-series return, the California Form 199 and the Registry renewal, and assembles the document package your independent auditor asks for. Nonprofit work is a deliberately small part of this firm - a handful of Form 990 clients a year, taken on where we can do the work properly rather than at volume. If your organization needs something outside that scope, you will hear it on the first call, before anything is signed.
Who We File For
The organizations we actually work with in the Inland Empire
Booster clubs, PTAs and youth sports leagues
All-volunteer, under the 990-N line, and the most common delinquency we see. Three filings are still owed every year: the federal e-Postcard, the California e-Postcard and the RRF-1 with CT-TR-1. Catching a miss in year one costs a filing fee; in year four it costs a reinstatement.
Faith-based and congregational organizations
Churches and their integrated auxiliaries are exempt from the Form 990, and religious organizations do not register with the state Registry - but separately incorporated schools, foundations and community arms usually must. Sorting which entity is which is most of the work. We can walk a board through it in Punjabi.
Community and social services nonprofits
County service contracts and federal block-grant money passed through San Bernardino or Riverside County are exactly the dollars that decide whether the $2,000,000 audit rule and the $1,000,000 Single Audit line apply to you. Someone has to read the award terms, not just the deposit amount.
Nonprofits with a taxable side activity
A thrift store, a rented hall, an ad-funded newsletter or a mortgaged rental property changes which returns you file. If the side activity has grown into a real business, our Real Estate Investors page and our Bookkeeping service cover the accounting that sits underneath it.
Small foundations and grantmaking entities
Form 990-PF, the private foundation return, has its own payout and excise tax rules. We take on small, straightforward foundations. Where the structure or the investments are complex, we say so at the first call and help you find the right firm rather than learn on your filing.
Questions Boards Ask Us
California nonprofit filing questions, answered directly
No - government grants and contracts are excluded from the $2,000,000 test where the agency requires its own accounting of the money (Gov. Code section 12586(e)). County service contracts and federal block-grant dollars passed through a county usually qualify; a no-strings city grant usually does not. The test is gross revenue, not net, so special-event gross receipts count.
Board Preparation
What your board assembles before the annual filing
Financial records
What we need to close the year and prepare the returns
- QuickBooks (or other accounting software) access, or a full-year backup file
- Bank and investment statements for every account, all twelve months
- Payroll reports and every Form W-2, 1099-NEC and 1099-MISC issued
- Grant agreements and award letters, including federal money passed through the state or county
- A list of federal award dollars spent during the year, with each award's Assistance Listing number
- Donor restriction paperwork - gift letters, pledge agreements and award terms
- The written method you use to split shared costs between programs, management and fundraising
- A list of any business-type income - rentals, sales, advertising - described activity by activity
- A list of equipment, vehicles and property owned, noting anything bought with grant money
- Last year's filed Form 990, Form 199 and RRF-1
Governance records
What the Form 990 and the Registry renewal ask you to evidence
- Board minutes for the full fiscal year, signed and dated
- Your IRS determination letter and your FTB exemption letter
- A current printout of your Registry of Charities status page and your Form CT-1 registration confirmation
- Names, addresses and terms of all current officers and directors
- Conflict-of-interest disclosure forms signed by each director for the year
- Written conflict-of-interest, whistleblower and document retention policies
- Board minutes approving key employees' pay, with the salary comparison data used
- Minutes showing the board reviewed the draft Form 990 before it was filed
- Names of audit committee members, if gross revenue is at or above $2,000,000
Next Step
Find out what is actually open before you engage anyone
Send us your last filed Form 990, a screenshot of your Registry status page, and access to your accounting file. We will come back with a written list of every open year and what it takes to get current. You will speak with AJ Singh, CPA and Enrolled Agent. If the answer is that your organization does not need an audit, that is what you will hear. G&S Accountancy Inc, Rancho Cucamonga, California - serving nonprofits across the Inland Empire. Call 909-217-7855.
Request a nonprofit compliance call
Tell us your fiscal year end, roughly what your gross revenue was, and what you think is unfiled. That is enough for us to be useful on the first call.