IRS Annual

The Taxpayer
First Act, enacted July 1, 2019, requires tax-exempt organizations to
electronically file information returns and related forms with the Internal
Revenue Service.  The new law affects
tax-exempt organizations in tax years beginning on or after July 1, 2019.

Several tax
forms are included in the mandate, including:

  • Form 990, Return of
    Organization Exempt from Income Tax.
  • Form 990-PF, Return of Private
  • Form 8872, Political
    Organization Report of Contributions and Expenditures.
  • Form 1065, U.S. Return of
    Partnership Income (if filed by a Section 501(d) apostolic organization).

that file Form 990-EZ (annual gross receipts less than $200,000 and total
assets less than $500,000) have “transitional relief” from the mandate.  These organizations are required to file
electronically starting in tax years ending August 31, 2020.  Of course, organizations with gross receipts
under $50,000 already file electronically by using the Form 990-N
postcard.  Although Forms 990-T and 4720
will come under the e-filing requirement in 2020, the IRS will continue to
accept these forms on paper pending conversion to electronic format.

IRS Initial
Application for Exemption

As of January
31, 2020, the IRS requires that Form 1023, Application for Recognition of
Exemption Under Section 501(c)(3) of the Internal Revenue Code, be completed
and submitted electronically through  There is a 90-day grace period during which
the IRS will continue to accept paper versions of Form 1023.

CA Attorney

February 1, 2020, California Attorney General’s Registry of Charitable Trusts
requires charities and professional fundraisers to use new and amended

changes include:

New Form
– The annual RRF-1 filing includes a requirement that an
organization include a copy of the Form 990. 
Charities with revenue under $50,000 file the 990-N postcard, so they don’t
have a requirement to send the 990 to the Attorney General.  Because the AG wants additional information
on an organization’s revenue and expenses, this new form was created and

Revised Form
– This annual RRF-1 form has been revised to include a required
report of noncash donations.

Revised Form
– The initial registration form now requires a lot of additional
information about a newly-registering organization.  New information requested includes DBAs used
by the organization, a list of other states in which the organization solicits
charitable donations, whether the organization in under common control with any
other nonprofit or for-profit organization, whether the organization has ever
been suspended or revoked by the FTB or SOS, whether any officers, directors,
trustees, or employees of the organization are related by blood or marriage,
and whether any of the organization’s officers, directors, or trustees have
been convicted of any crime involving the misuse or misappropriation of funds
or any crime involving deception in the operation of a charity.

One thing to
keep in mind is that all of these documents are publicly posted on the AG’s
Registry website.

If you have
questions regarding which forms to file for your charitable organization, and
how to file the forms with the IRS, FTB, or California Attorney General, please
contact us.

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