We are a new nonprofit. Do we need to file a 990 for the current tax year before receiving our determination letter?

An organization does not need to file their 990 prior to receiving their 501(c)(3) tax-exempt status, but they will need to file once they do!

An organization that wishes to claim tax-exempt status under section 501(c)(3) but has not yet received an IRS Determination letter recognizing exempt status, is required to file an annual 990 form based on their income and incorporation date. If they are approved the year after they incorporate, they are still expected to file based on their fiscal year end, not their Determination Date. For example, a nonprofit with a December Fiscal yearend month that incorporated in November 2022, doesn’t receive their 501(c)(3) determination letter until June 2023. The organization will be required to file a 990 for Tax year 2022.