AAFCPAs would like to make our nonprofit clients aware that as of January 1, 2019, the IRS stopped mailing lists of parent and subsidiary accounts to central organizations (group ruling holders) for verification and return.
If your organization is the Central Organization of a group exemption, historically you would have received an annual mailing from the IRS with a list of subordinate organizations. This mailing allowed the Central Organization to simply verify the information, provide updates if necessary, and return the mailing back to the IRS.
The responsibility now lies with the Central Organizations to comply with the annual reporting requirements in Section 6 of Revenue Procedure 80-27. As noted in the Revenue Procedure, the required information must be submitted at least 90 days before the end of the Central Organization’s year end. For example, a Central Organization with a June 30, 2019 year end had to submit its annual update by April 1, 2019. If you missed this deadline and would like guidance on complying with this IRS reporting requirement, please contact your AAFCPAs partner.
The required information, which must be submitted annually, includes the names, addresses, and employer identification numbers of subordinate organizations that have terminated, disaffiliated from the group, been added to the group, or changed names or addresses. If there are no changes, the Central Organization must submit a statement to that effect. AAFCPAs recommends also submitting a list of the names, addresses, and employer identification numbers of subordinate organizations that are current and still under the group exemption.
Annual Updates should be sent to:
Department of the Treasury
Internal Revenue Service Center
Ogden, UT 84201