As a Registered Student Organization (RSO), you may be required to file taxes with the Internal Revenue Service on an annual basis. Campus Life Programs (CLPs) do not have to file taxes, as they are entities of the university.
To determine your filing requirements, select either "Filing Taxes as an Unincorporated Organization" or "Filing Taxes as a 501(c) or Nonprofit Organization" below.
Filing Taxes as an Unincorporated Organization
Any student organization that does not have federal tax-exempt status (501(c) organizations) may be required to file taxes with the IRS. Student groups that remain unincorporated because they are small entities (under $5,000 in income) do not necessarily need to file, but they do have a responsibility towards detailed financial tracking and documentation.
Groups that are larger in nature (over $5,000 in income) will need to file the IRS Form 1120 as a taxable organization or proceed with filing for nonprofit and tax-exempt status. Your group can meet with a Student Activities Advisor to determine which tax filing option makes the most sense for your group, and learn about recommendations for financial tracking and documentation. Tax filing for non tax-exempt groups filing form 1120 is due withing 3 months of the end of the organization's fiscal year (September 30 for groups operating on a July 1 - June 30 FY).
Filing Taxes as a 501(c) or Nonprofit Organization
In accordance with the federal government and policies of the Internal Revenue Service, all nonprofits that have received federal tax-exempt status (501(c) organizations) must submit an annual federal tax filing. Depending on the size of the organization, there will be an IRS filing. The filing is due by the 15th day of the fifth month after the close of the organization’s fiscal year. For example, if your organization’s tax period ends on June 30, the filing is due November 15.
In addition to filing with the IRS, nonprofit status requires annual registration through the state of Minnesota. Groups who have nonprofit status must renew their status by December 31 each year. This process is completed online through the Secretary of State’s website.
Groups who are receiving charitable donations, as classified by the State of Minnesota, a minimum of $25,000 annually will need to file the Charitable Organization Annual Report Form through the Minnesota Attorney General’s Office.
Registered Student Organizations whose gross receipts (income) are less than or equal to $50,000 annually would file IRS Tax Form 990-N. An organization is required to provide the following information on Form 990-N.
- the organization’s name,
- any other names the organization uses,
- the organization’s address,
- the organization’s website address (if applicable),
- the organization’s employer identification number (EIN),
- name and address of a principal officer of the organization,
- the organization’s annual tax year, and
- a statement that the organization’s annual gross receipts are still normally $50,000 or less.
- if applicable, a statement that the organization has terminated or is terminating (going out of business).
For more information, visit the IRS Tax Information for Charitable Organizations website.
Registered Student Organizations whose gross receipts (income) are (1) less than $200,000, and (2) whose total assets are less than $500,000 would file IRS Tax Form 990-EZ or IRS Tax Form 990. Your student organization may also need to attach various schedules to the Form 990-EZ. Please see the 990-EZ instructions at on Page 6 for a description of each schedule. Common schedules that an RSO may need to file are Schedules A, B, G and O. However, organizations should review the full listing to ensure they file a complete return.
Registered Student Organizations whose gross receipts (income) are (1) equal to or greater than $200,000 or (2) total assets are equal to or greater than $500,000 would file IRS Form 990. Please see the 990 instructions. Your student organization may also need to attach various schedules to the Form 990. These schedules would be identified when completing Form 990, Schedule IV. Common schedules that an RSO may need to file are Schedules A, B, G and O.
Tax Reporting Overview
|Articles of Incorporation||$70||Secretary of State||Legally incorporates the nonprofit.|
|Annual Registration||None||Secretary of State||Maintains organization incorporation status. Organizations must pay a $25 fee to reinstate its incorporation.|
|Request for Reservation of Name||$35||Secretary of State||Reserves a unique name for the organization.|
|Charitable Registration||$25||Attorney General||Registers the organization for charitable solicitation.|
|Form ST-16||None||Department of Revenue||Department of Revenue Applies for exemption from Minnesota sales taxes (Not all 501(c)(3) organizations qualify for this exemption).|
Tax Exempt Status
|Publication 557||None||N/A||An IRS publication that details the rules and procedures for seeking to obtain exemption from federal income taxes.|
|Form 1023 and Form 8718||$850 or $400||IRS||Applies for federal tax exemptions under Section 501(c)(3) of the IRS tax code. Must accompany form 8718 (User Fee for Exempt Organizations Determination Letter Request).|
|Form 1024 and Form 8718||$850||IRS||Applies for federal tax exemptions under Section 501(c) of the IRS tax code. Must accompany form 8718 (User Fee for Exempt Organizations Determination Letter Request).|
|Form 990||None||IRS||Files tax return for tax-exempt organizations with gross receipts greater than or equal to $200,000 or total assets that are greater than or equal to $500,000 at the end of the year.|
|Form 990-EZ||None||IRS||Files tax return for tax-exempt organizations with gross receipts less than $200,000 or total assets that are less than $500,000 at the end of the year.|
|Form 990-N (e-Postcard)||None||IRS||Files tax return for tax-exempt organization with gross receipts less than or equal to $50,000|
|Form 1120 and Instructions for Form 1120||None||IRS||Files tax return for organizations that are not tax exempt. Groups may be responsible for paying taxes on their annual income.|
|SS-4 or EIN Online Application||None||IRS||Applies to obtain a Tax ID/Employer Identification Number (EIN)|
Payment for Services Performed by Individuals
Student groups may pay individuals for services performed, as long as there is reasonable justification for the amount, and payment and the payment process is authorized by the group’s constitution and by-laws. We recommend that authorization be in writing in meeting minutes and that the group draw up a contract.
All amounts paid as salaries, wages, stipends, remuneration, or whatever name is given, are taxable by the IRS and by Minnesota. All groups with payroll must withhold from individual pay for FICA (Social Security), federal income tax, and Minnesota income tax. Additionally, you must pay for Employers FICA, Minnesota unemployment tax, and workers compensation. For those who are not official IRC 501(c) organizations, federal unemployment tax must be paid.
Groups paying independent contractors for services, who are not employees subject to withholding, have a special requirement. Each individual paid $600 or more in a calendar year must be sent a Form 1099-MISC (showing how much was paid) by the following January 31. This applies to stipends for officers of student groups. A copy of this, accompanied by a Form 1096, goes to the IRS by the end of February. Minnesota has a similar requirement. Send a copy of Form 1099 to the Minnesota Department of Revenue.
Paying International Performers or Artists
If you are paying international individuals (including performers, artists or speakers), your student group is responsible for withholding a portion of the amount you plan to pay the “performer”, as outlined in publication 515. The student group (the payer) is responsible for withholding the tax. It is not the responsibility of the payee. In fact, if the group doesn’t withhold the tax, they can become personally liable for the tax, interest and any penalties.
Please contact Student Activities if you have questions about this process or are planning to pay international individuals.
Tax Obligations: Payroll and Income
Please see Maintenance and Records for additional information regarding best practices.
- Nonprofit organizations must comply with all federal, state and local employment laws when hiring and employing personnel, including withholding and payment of payroll taxes and use of restricted funds.
- Paying students (including stipend)
- For student groups that have paid employees, you are required to pay federal and state taxes. We encourage groups to consider using a payroll service to help manage payroll.
- Payroll services can assist with W2s. Please see the list of Payroll Service Providers and recommendations for more information.
Employees of registered student groups classified as Registered Student Organizations are not employees of the University and are not eligible for benefits of any type, including compensation, from the University.
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