Q&A #140 – How do nonprofits report a name change to the IRS?

Question: My nonprofit organization recently changed its name. Are we required to submit a form notifying the IRS, or can we wait until we file the next Form 990?

Answer: A formal name change must be reported on the organization’s next Form 990 or 990-EZ by checking the “name change” box in Column B on the left side at the top of page 1 and including a state-certified copy of the amendment to the organization’s Articles of Incorporation. Form 990-N filers must instead send a letter or fax with this supporting documentation to the IRS Exempt Organizations Division.

Additionally, all tax-exempt organizations that formally change their name by amending their Articles of Incorporation should (but are not required to) request an affirmation letter from the IRS confirming tax-exempt status under the organization’s new name by submitting a letter or fax with the required supporting documentation to the Exempt Organizations Division. It is important to have this letter when applying for grants, communicating with donors and funders, and submitting state filings and registrations, since providing the original tax-exemption approval letter issued under the organization’s previous name can lead to unwanted confusion.

Planning Tip – If your organization has decided to change its name, consider including a statement explaining the reasons for the name change on the “about” page on your organization’s website, in Schedule O of the Form 990 or Form 990-EZ, and in other communications with donors, grantors, vendors, service recipients, and other interested parties. While not required, this will help to tell the story of your organization’s evolution, mitigate potential confusion, and archive the key reasons for the name change, which otherwise can be forgotten or misinterpreted over time.

Note that the processes described above do not apply to a change of name that is accomplished by registering a “trade name” as described in Q&A #139. These informal name changes are simply reported by entering a “doing business as” name in Column C at the top of page 1 of the Form 990 under the organization’s legal name. In the case of the Form 990-EZ (which does not have a separate line for a “doing business as” name), organizations should report that the organization is “a.k.a.” (also known as) the trade name on the same line where the organization’s legal name in Column C at the top of page 1.

This relatively awkward Form 990 / 990-EZ reporting of a trade name arguably presents the organization’s brand in a way that is less clear and cohesive. This is one of the reasons why a formal name change amendment to the Articles of Incorporation is generally recommended.

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