Rev Proc 2018 38 exempt organizations | KPMG | US
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Section 501(a) organizations no longer required to report contributor data

Rev. Proc. 2018-38 revised reporting requirements

The IRS today released an advance version of Rev. Proc. 2018-38 to modify the information to be reported to the IRS by organizations exempt from tax under section 501(a) (other than section 501(c)(3) organizations) that are required to file an annual Form 990 or Form 990-EZ information return.

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Rev. Proc. 2018-38 [PDF 25 KB] states that these section 501(a) organizations are no longer required to report the names and addresses of their contributors on the Schedule B of their Forms 990 or 990-EZ. These organizations, however, must continue to collect and keep this information in their books and records and to make it available to the IRS upon request, when needed for tax administration.

This revenue procedure provides that:

  • Tax-exempt organizations required to file Form 990 or Form 990-EZ—other than those described in section 501(c)(3)—will no longer be required to provide names and addresses of contributors on their Forms 990 or Forms 990-EZ and will not be required to complete these portions of their Schedules B (or complete the similar portions of Part IV of the Form 990-BL). 
  • Organizations described in section 501(c)(7), (8), or (10) will no longer be required to provide on Forms 990 or Forms 990-EZ the names and addresses of persons who contributed more than $1,000 during the tax year to be used for exclusively charitable purposes. 
  • Organizations relieved of the obligation to report contributors’ names and addresses must continue to keep this information in their books and records in order to permit the IRS to examine the information. 

 

Rev. Proc. 2018-38 specifically provides that:

  • These changes do not affect the information required to be reported on Forms 990, 990-EZ, or 990-PF by organizations described in section 501(c)(3) (including non-exempt charitable trusts under section 4947(a)(1) and non-exempt private foundations under section 6033(d)) or political organizations under section 527.
  • It does not affect the reporting of contribution information, other than the names and addresses of contributors, required to be reported on Schedule B of Forms 990 and 990-EZ and Part IV of the Form 990-BL.
  • It does not affect the disclosure requirements of any information reported on the Schedule B of Forms 990 and 990-EZ and Part IV of the Form 990-BL.
  • It will not affect the reporting of Schedule B information that is currently open to public inspection. 

The revised reporting requirements will apply to information returns for tax years ending on or after December 31, 2018. The revised reporting requirements generally will apply to returns that become due on or after May 15, 2019. 

 

Read a related Treasury Department release

 

For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Alexandra Mitchell | +1 202 533 6078 | aomitchell@kpmg.com

Preston Quesenberry | +1 202 533 3985 | pquesenberry@kpmg.com

Randall Thomas | +1 202 533 3786 | randallthomas@kpmg.com

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