Start with the IRS Tax Exempt Organization Search (TEOS), using the trust’s exact legal name or employer identification number (EIN). Then compare the records you find with the trust’s determination letter, Pub. 78 information (when applicable), auto-revocation history, Form 990-PF filings, accounting year and filing deadlines, and any pending application. These records answer different questions: recognition of exemption, current filing compliance, a prior automatic revocation, and an application that has not yet been decided are not interchangeable.
This is a general federal verification process, not a status determination for a particular trust. A conclusive review requires the trust’s legal name or EIN and its actual IRS records. State charitable-solicitation, trust-law and fiduciary requirements are separate issues. For consequences specific to a trust, consult a qualified tax professional.
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What you are actually verifying
A “PF trust” usually means a trust treated as a private foundation for federal tax purposes. The verification has several separate parts. First, determine whether the IRS has recognized the organization as exempt under the subsection for which it applied. Second, determine whether the trust has met its annual information-return obligations. Third, check whether an automatic revocation occurred and, if so, whether the IRS later reinstated the organization. Finally, distinguish an application that is still pending from an approved exemption.
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Recognition of exemption
An IRS determination letter recognizes exemption under the subsection for which the organization applied. Read the letter itself: the subsection, effective date, organization name and EIN are more probative than an informal reference to the trust as “tax exempt.” For a section 501(c)(3) organization, the IRS’s Pub. 78 data is one relevant resource for organizations eligible to receive deductible contributions. Pub. 78 information is useful evidence, but it should be read together with the determination letter and other current IRS records.
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Compliance is a separate question
A trust can have a determination letter and still have a filing problem. Conversely, a filing visible in TEOS does not by itself prove that the trust has a current determination recognizing exemption. Treat exemption evidence and return history as separate workstreams, then reconcile them using the same legal name, EIN and accounting period.
Step 1: Search the IRS Tax Exempt Organization Search
TEOS is the starting point because it brings together exemption-related records, determination letters and Form 990-series filings. The IRS identifies Form 990-PF returns as part of the resources available for private foundations. Use the trust’s legal name as it appears on its organizing documents and EIN when available.
- Gather identity details. Confirm the exact legal name, any former name, the EIN, the state of formation and the trust’s accounting year. A trade name, shortened name or trustee’s name can produce a misleading no-result search.
- Search by EIN first when possible. An EIN is generally the most precise identifier. Run a name search as a cross-check, including variations that appear on older filings or the determination letter.
- Open every relevant record. Review determination letters, exemption information and Form 990-series filings rather than relying only on a search-result label.
- Record the data date. The IRS page showed data-posting dates in August and September 2026 when reviewed. TEOS coverage is not necessarily real time, so note the posting date and treat a recent filing or status change as potentially not yet displayed.
- Save an evidence packet. Retain the search results, determination letter, available filings, screenshots or downloaded records, the date searched and the identity information used. This makes a later discrepancy easier to investigate.
A blank search result is a signal to investigate, not proof that a trust is not exempt or has failed to comply. Recheck the EIN, legal name, former names, accounting period and data-posting lag before drawing a conclusion.
How to read the IRS records without confusing them
| Record or result | What it can establish | What it cannot establish by itself |
|---|---|---|
| IRS determination letter | The IRS recognized exemption under the subsection stated in the letter, subject to the letter’s terms and effective date. | That every later annual return was filed or that no later revocation or other change occurred. |
| Pub. 78 data | For eligible section 501(c)(3) organizations, a relevant IRS indication used by donors evaluating deductible contributions. | A complete substitute for the determination letter, current filing history or reinstatement review. |
| Form 990-PF filing | That a return for a particular accounting year appears in the IRS filing records. | That the trust’s exemption was recognized, that the return was timely, or that all required returns are already posted. |
| Auto-Revocation List entry | That the IRS recorded an automatic revocation associated with the organization’s failure to file a required Form 990-series return or notice for three consecutive years. | That the trust has no current exemption; reinstatement may have occurred, and the list can retain a name after reinstatement. |
| Pending application notation | That an exemption application has not yet resulted in a recognition letter, if the IRS record or filing identifies it as pending. | That exemption has been granted or that annual-return obligations disappear. |
| EO Business Master File information | Another IRS data source that can help confirm an organization’s current or reinstated status. | A replacement for reviewing the trust’s actual determination, reinstatement and filing records. |
Step 2: Check the determination letter and current exemption evidence
Locate the trust’s IRS determination letter and compare its identifying details with the TEOS record. Check the legal name, EIN, subsection, effective date and any limitations or conditions. If the trust claims section 501(c)(3) status, look for the corresponding Pub. 78 information when the organization is eligible to receive deductible contributions.
Questions to answer from the letter
- Does the name and EIN match the trust you are reviewing?
- Which subsection does the letter recognize?
- What effective date does the IRS state?
- Is the letter for the current entity, or for a predecessor, merged organization or former name?
- Has a later IRS letter modified, revoked or reinstated the status?
Do not treat a trustee’s statement, a state registration or a donation receipt as a substitute for the federal determination evidence. Those documents may be relevant to other obligations but do not answer the federal recognition question.
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Step 3: Check the Auto-Revocation List, then verify the present result
Federal law provides for automatic revocation after three consecutive years of failing to file a required Form 990-series return or notice. Search the IRS Auto-Revocation List using the same legal name and EIN used in TEOS.
“Presence of an organization’s name on the Auto-Revocation List doesn’t necessarily reflect its current tax-exempt status.” — Internal Revenue Service, “Search for tax exempt organizations.”
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If the trust appears on the list
- Identify the revocation date and the organization identity shown on the list.
- Compare the list entry with the trust’s EIN, legal name and former names to avoid a false match.
- Search Pub. 78 data, if applicable, for a later indication of status.
- Look for a later determination or reinstatement letter in TEOS records.
- Check EO Business Master File information for reinstatement or another current-status indication.
- Review the Form 990-PF history to identify the missing three-year filing sequence and any later returns.
The Auto-Revocation List can retain a name after reinstatement. Therefore, an entry is evidence of a revocation event, not a standalone answer to whether exemption is currently in force. If the records conflict, preserve both records and obtain professional advice before telling donors, trustees or counterparties that the trust is currently revoked.
If the trust does not appear on the list
Absence from the list does not replace the determination-letter and filing review. Confirm the current exemption evidence and check whether all Form 990-PF returns required for the trust’s accounting years are present. A record can be missing from a public dataset because of identity differences, posting delays or a filing that has not yet been processed.
Step 4: Review the Form 990-PF filing history
Private foundations generally file Form 990-PF every year, including years with no taxable income or activity. A section 4947(a)(1) nonexempt charitable trust treated as a private foundation is included in this annual-return framework. “Nothing happened this year” is therefore not, by itself, a reason to omit the return.
Build a year-by-year filing schedule
Make a table with one row for every accounting year in which the trust was required to file. For each year, record the period end, original due date, any extension, the date filed, the TEOS posting date if visible and whether the return is complete. Compare that schedule with the returns shown in TEOS.
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| Item to record | Why it matters |
|---|---|
| Accounting-period end | The due date is calculated from the close of the accounting period, not automatically from December 31. |
| Required form | A private foundation generally uses Form 990-PF; other filings may apply to particular activities or income. |
| Original due date | Lets you distinguish a timely return, an extended return and a late return. |
| Extension information | An extension can change the filing deadline; verify that the extension was valid for the relevant year. |
| Filed and posted dates | IRS public records may lag the actual filing, so a missing posting is not automatically a missed filing. |
| Three-year continuity | Three consecutive years without a required return or notice can trigger automatic revocation. |
When Form 990-PF is due
The IRS states that Form 990-PF is due on the 15th day of the fifth month after the close of the accounting period. For a calendar-year foundation, the IRS gives May 15 as the due date. For a trust with a different year-end, count from that accounting-period close and verify the applicable year’s IRS instructions and any extension before labeling a return late.
Do not infer lateness from a blank TEOS entry alone. First confirm the accounting year, the correct filing requirement, the original due date, any extension and the IRS data-posting date.
Step 5: Treat a pending exemption application as a separate status
A pending application means the organization has sought recognition but has not received its recognition letter. It is not the same as an IRS determination recognizing exemption. The IRS says a foundation that claims exemption but has not received its recognition letter generally still must file the annual return when due, e-file it and mark the application as pending.
Annual filings while the application is pending
- Track the Form 990-PF due date from the trust’s accounting-period close.
- E-file the required annual return when due, following the IRS instruction for marking the exemption application as pending.
- Retain the filing confirmation and a copy of the pending application.
- Do not tell donors that the application itself proves approved tax-exempt status.
Unrelated business income
If unrelated business income exceeds $1,000, the IRS says Form 990-T must also be e-filed. The $1,000 figure is the threshold cited in the IRS guidance for a foundation with a pending application; determine the amount under the applicable tax rules and have a tax professional evaluate unusual income, expenses and filing positions.
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If the trust is applying for recognition
The IRS directs applicants to submit Form 1023 or, if eligible, Form 1023-EZ through Pay.gov with the required fee. Eligibility matters: private operating foundations and certain other organizations cannot use Form 1023-EZ. Selecting the shorter form without confirming eligibility can create a processing problem and does not accelerate recognition by itself.
Application-control checklist
- Confirm that the applicant’s legal name and EIN match its organizing documents and planned filings.
- Determine whether the organization is a private foundation, private operating foundation or another category for purposes of form eligibility.
- Use Form 1023 or Form 1023-EZ only after checking the IRS eligibility rules.
- Submit through Pay.gov with the required fee and preserve the submission confirmation.
- Continue tracking annual-return obligations while the application is pending.
- After the IRS responds, replace the pending-status evidence with the determination letter and update the compliance calendar.
A practical compliance workflow for trustees and staff
At the start of each accounting year
- Confirm the accounting-period end and calculate the 15th-day-of-the-fifth-month due date.
- Assign responsibility for Form 990-PF preparation, review, e-filing and retention.
- Check whether the trust has a pending application, a prior revocation, a reinstatement or a change of legal name.
- Separate federal exemption records from state charitable registrations and trust-administration records.
Before filing
- Reconcile the trust’s EIN and legal name to the IRS records.
- Confirm whether the year had taxable income, unrelated business income or no activity; no activity does not automatically eliminate the Form 990-PF requirement.
- Review the applicable IRS instructions for the tax year and any extension.
- Have a qualified preparer or tax adviser review unusual grants, transactions, investments and compensation.
After filing
- Save the signed or authorized return, e-file acceptance and payment records, if any.
- Check TEOS after a reasonable processing period, while remembering that public data is not necessarily real time.
- Update the year-by-year filing schedule and flag any missing posting for follow-up.
- Keep the determination letter, reinstatement letter and filing evidence together so a donor, auditor or successor trustee can reproduce the status check.
Common mistakes and how to correct them
Using a trustee’s name instead of the legal entity
Searches based only on an individual trustee’s name can miss the organization or produce an unrelated result. Correct the search with the trust’s legal name and EIN, then compare the result to the governing instrument and IRS letter.
Calling a return late because it is not visible
Public posting can lag filing. Verify the accounting year, due date, extension, filing confirmation and TEOS posting date before describing a return as late or missing.
Assuming an Auto-Revocation List hit is final
The list records a revocation event, but the organization may later have been reinstated and the name may remain on the list. Check later determination or reinstatement evidence, Pub. 78 data when relevant and EO Business Master File information.
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Private foundations generally file annually even with no taxable income or activity. Put the return on the compliance calendar before deciding whether any exception applies.
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Treating a pending application as an approval
A pending application is not a determination letter. File the annual return as the IRS directs, mark the application pending and communicate the status accurately to donors and counterparties.
Using Form 1023-EZ without checking eligibility
Private operating foundations and certain other organizations cannot use Form 1023-EZ. Confirm eligibility before submitting an application and fee.
What to do when records conflict
Conflicts are common enough to deserve a documented escalation path. If TEOS shows a determination letter but the Auto-Revocation List also shows the name, look for a later reinstatement or determination record before reaching a conclusion. If a return appears in the trust’s files but not TEOS, retain proof of filing and allow for posting lag while contacting the preparer or IRS through an appropriate channel. If the name matches but the EIN does not, treat it as an identity problem until resolved.
When the status affects a major grant, donor deduction, restricted-fund decision, merger, dissolution or trustee action, give the tax adviser the complete evidence packet: organizing documents, EIN confirmation, determination letter, all relevant IRS notices, Auto-Revocation List result, Pub. 78 or EO Business Master File result, filing confirmations and the accounting-year schedule. A professional can then analyze effective dates, reinstatement consequences, filing exposure and any excise-tax or donor issues that a public-record search cannot answer.
Limits of a federal records check
This workflow addresses federal exemption recognition and Form 990-series compliance. It does not establish compliance with state charitable-solicitation registration, state trust law, fiduciary duties, grant restrictions, investment rules or every federal excise-tax requirement. It also cannot establish a specific trust’s status without the trust’s identity and records. A missing public record, an old determination letter or a pending application should be described precisely rather than converted into a categorical claim of noncompliance.
Quick Recap
Printable verification checklist
- Search TEOS by the trust’s exact legal name and EIN.
- Note the IRS data-posting date and recognize that coverage may not be real time.
- Retrieve and read the determination letter, including subsection and effective date.
- Check Pub. 78 data when the organization is a section 501(c)(3) organization eligible to receive deductible contributions.
- Search the Auto-Revocation List and investigate any matching entry.
- Look for later reinstatement or determination evidence and check EO Business Master File information when needed.
- List every accounting year for which Form 990-PF was required.
- Calculate each due date as the 15th day of the fifth month after the accounting period closes; for a calendar-year foundation, use May 15 as the IRS-stated due date.
- Verify extensions, filing confirmations and posting delays before calling a return late or missing.
- Remember that a private foundation generally files Form 990-PF even with no taxable income or activity.
- If an exemption application is pending, file the annual return as directed and mark the application pending.
- If unrelated business income exceeds $1,000, determine whether Form 990-T must also be e-filed.
- If applying, confirm eligibility for Form 1023 or Form 1023-EZ, submit through Pay.gov with the required fee and preserve the confirmation.
- Obtain qualified tax advice for trust-specific consequences and state-law obligations.
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