CaseMark 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:
- Does the jurisdiction list match actual registration footprint?
- Is the revenue figure and Form 990 line reference correct?
- Expand scope to professional fundraiser/solicitor thresholds?
- 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.