Final regulations on tax-exempt organizations clarify reporting issues

Updated reporting requirements impact tax-exempt organizations with receipts of $50K or less, 501(c)(3) charitable organizations and 527 political organizations.

June 04, 2020

IRS news release IR-2020-103 announces the release of final Treasury regulations clarifying reporting requirements for tax-exempt organizations. The final regulations largely adopt relief announced in earlier guidance, such as Rev. Proc. 2011-15.

Under the final regulations:

  • Tax-exempt organizations with gross receipts of $50,000 or less are exempt from having to file an annual return (Form 990).
    • These organizations are still required to electronically submit a Form 990-N “e-postcard” each year.
  • For organizations that do have an annual return filing requirement, only §501(c)(3) charitable organizations and §527 political organizations are required to report substantial contributors’ names and addresses.
    • Generally, substantial contributors are those that donate $5,000 or more, and must be reported on Form 990, Schedule B.
  • All other tax-exempt organizations, such as social clubs and fraternal organizations, must maintain names and addresses of substantial contributors in their books and records.

Tax-exempt organizations may choose to apply the final regulations to returns filed after September 6, 2019.

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