casemark/charity-filing-thresholds

State Charity Filing Threshold Research

Produces a citation-backed, state-by-state matrix of audit/review/compilation thresholds, fees, and deadlines for charitable solicitation filings. States define revenue triggers differently — "gross annual revenue," "total revenue," "contributions," and "gross support and revenue" map to different Form 990 lines and shift which financial-statement tier applies. Thresholds change frequently through administrative action without legislation.

Pre-Draft Intake

Gather before drafting (apply defaults if user says "use defaults" or "just draft"):

| Parameter | Default | |---|---| | Jurisdictions | All 41 registration states + DC | | Gross revenue / contributions (Form 990) | $1,000,000 | | Fiscal year end | December 31 | | Entity category | 501(c)(3) public charity | | Output format | Full compliance package (memo + matrix) |

Scope: Charitable solicitation registration/renewal filings for 501(c)(3) organizations. Excludes corporate annual reports, IRS filings, and professional fundraiser/solicitor regimes unless requested.

Core Workflow

1. Source Identification

For each state, locate and record: regulator/agency, statute citation, regulation citation, filing form(s) with links, fee schedule, due date authority, and last-verified date.

Primary-source-first rule: Prefer statute/regulation text over FAQ summaries. Flag guidance-only sources.

2. Data Extraction

Extract per state:

• Audit — threshold amount (≥ or >), revenue basis term (verbatim), exemptions
• Review — threshold range, revenue basis term
• Compilation — threshold, whether acceptable below review threshold
• Fees — tier table with revenue basis term
• Due date — rule (e.g., "4.5 months after FYE"), extension availability and mechanism

Critical — Revenue Definition Variance:

| State Term | Typical 990 Line | Example States | |---|---|---| | "gross annual revenue" | Part VIII, Line 12 | CA | | "total revenue" | Part VIII, Line 12 | NY, GA, PA | | "contributions" | Part VIII, Line 1h | IL, FL | | "gross support and revenue" | Part VIII, Line 12 | MA |

Never assume "gross revenue" equals "contributions." Capture each state's term verbatim and map to the applicable Form 990 line.

Extraction rules:

• Statute/regulation controls over instructions — note conflicts
• Capture Form 990 line references explicitly when states use them
• Label which program a threshold applies to when multiple exist (trust reporting vs. solicitation)

3. Normalization

Standardize into fields: state, audit_threshold_amount, audit_threshold_basis_raw, audit_threshold_990_line, review_threshold_amount, compilation_acceptable_below, fee_schedule, due_date_rule_raw, due_months_after_fye, extension_available, extension_length, extension_mechanism, citations, last_verified_date.

Maintain a decision log for ambiguities: issue, state, sources consulted, decision taken, follow-up needed.

4. Assemble Deliverables

Master matrix — one row per state with: audit threshold, revenue basis, review threshold, compilation threshold, fee summary, due date, extension info, primary sources, verified date.

Attorney review memo (1–3 pages) addressing:

• Definitional variances across states
• Guidance-only items not backed by statute
• Statute-vs-instruction conflicts
• Lowest thresholds and strictest deadlines
• Recommended re-verification cadence

Post-Draft Alignment

After delivering initial matrix, confirm:

1. Does the jurisdiction list match actual registration footprint?
2. Is the revenue figure and Form 990 line reference correct?
3. Expand scope to professional fundraiser/solicitor thresholds?
4. Different output format needed (CSV, JSON, spreadsheet)?

Quality Checklist

• [ ] Every threshold has a statutory/regulatory citation or is marked [VERIFY]
• [ ] Revenue basis term captured verbatim per state — not normalized away
• [ ] Form 990 line mapping provided for each revenue definition
• [ ] Fee schedules sourced from official agency pages
• [ ] Extension mechanisms specified (not just Yes/No)
• [ ] Decision log maintained for all ambiguities
• [ ] Statute-vs-instruction conflicts noted and resolved
• [ ] Last-verified date recorded per state
• [ ] No fabricated thresholds, fees, or deadlines

Pitfalls

• Fees change without legislation — always check state charity bureau websites for current schedules
• Revenue ≠ contributions — the definitional difference can shift which tier applies
• Staleness — mark any source not verified within 90 days for re-verification
• Organization bylaws may impose lower thresholds than state-mandated levels
• Mark all uncertain citations with [VERIFY]

Required disclaimer on every output:

THIS RESEARCH REQUIRES INDEPENDENT VERIFICATION OF ALL THRESHOLDS, DEADLINES, AND STATUTORY CITATIONS BY A QUALIFIED ATTORNEY OR CPA BEFORE RELIANCE, AND DOES NOT CONSTITUTE LEGAL ADVICE.