IRS Issues Revenue Procedure 2018-38, Partially Easing Donor Reporting Requirements
In July 2018, the Internal Revenue Service released Revenue Procedure 2018-38 relating to the reporting of donor names and addresses on Schedule B - Schedule of Contributors of Form 990. The new rule announced that organizations, other than those exempt under Code section 501(c)(3), are no longer required to include identifying information such as names and address of donors when completing the Schedule B. Organizations exempt under Section 501(c)(4), (6), or (7), for example, would qualify for this new rule, and would only be required to list amounts on the Schedule. As a result, the Schedule B for such organizations would mirror the public inspection copy.
It is important to note that while the requirement for listing donor names and address has been lifted, organizations will still be required to complete Schedule B. This new rule will apply to returns for taxable years ending on or after December 31, 2018.
Organizations that are exempt under 501(c)(3) will still be required to follow the old rules and report names and addresses for all contributors when submitting Schedule B as part of a complete Form 990 filing to the IRS. However, the identifying information such as names and address should continue to be excluded from the public inspection copy, as this information is not open to the public.
This new announcement also does not affect private foundations. These organizations should continue to report identifying information of contributors on Schedule B when submitting their complete annual filings to IRS, as well as in all public inspection copies.
What CohnReznick Thinks:
The IRS issued these new rules as a way of easing some of the administrative burden on organizations that are not in the business of solicitation. It is also recommended that organizations that qualify for this new reporting requirement should continue to keep track of such identifying information in their books and records should the IRS ever request such information.
For more information on this topic, contact:Thomas Lanning, CPA, Tax Partner, CohnReznick Not-for-Profit Industry Practice at thomas.lanning@cohnreznickcom, or Sima Wolfson, Manager, CohnReznick, Not-for-Profit Industry Practice at firstname.lastname@example.org.
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