As of January 1, 2019, the Internal Revenue Service (IRS) has stopped mailing lists of parent and subsidiary accounts to organizations with a group ruling. In the past, the IRS sent these notifications to central organizations requesting updates.
As a background, Revenue Procedure 80-27 requires central organizations to annually provide the IRS with a list of subordinates with name and address changes, new organizations included in the group exemption, and subordinates to be removed from the group. The information is due 90 days before the end of the central organization’s tax year. Further, if there are no changes to the subordinates, the central organization must provide a statement to the IRS stating there are no changes.
The IRS first published this reminder for organizations on March 20, 2019. Organizations with May 31 year ends would have already been late as the statements would have been due March 1, 2019.
If your central organization did not submit the annual notification 90 days before year end, it should do so immediately. Moving forward, the task should be added to your annual compliance checklist in order to timely file the statement each year.
More information can be found by visiting: www.irs.gov/charities-non-profits/group-exemption-rulings-and-group-returns
Please reach out to Angela Crawford (firstname.lastname@example.org) or your Blue & Co. advisor for more information.