28 March 2019 IRS no longer issuing lists of parent/subsidiary accounts; group ruling holders must provide own updates The IRS is reminding exempt organizations that although, as of January 1, 2019, the agency stopped mailing lists of parent and subsidiary accounts to central organizations (group ruling holders) for verification and return, central organizations are nonetheless obligated to provide the IRS with periodic updates to the mailing lists. Under the annual reporting requirements found in Section 6 of Revenue Procedure 80-27, central organizations must provide certain information at least 90 days before the organization's annual accounting period closes. The requisite information includes the names, addresses and employer identification numbers of subordinated organizations that (1) have terminated, (2) are no longer affiliated with the group, (3) have been added to the group, or (4) have changed names or addresses. If no changes have occurred, the central organization must nonetheless submit a statement to the IRS saying there are no changes. Annual updates must be mailed to: Department of the Treasury, Internal Revenue Service Center, Ogden UT 84201. The IRS reminder, posted March 20, 2019 as an EO Update on irs.gov, also emphasizes that central organizations with a year-end of June 30, 2019 must submit an update by April 1, 2019. Finally, the EO Update refers group ruling holders to additional materials on the IRS's website explaining federal tax rules and procedures for group exemptions and group returns. This procedural update creates an additional administrative duty for exempt organizations that have applied for and received a group ruling from the IRS. Historically, the IRS's mailing of annual supplemental group ruling information notices reminded central organizations to update and verify the parent and subsidiary group members' information. Central organizations must now be proactive in timely submitting their annual group ruling updates to the IRS at least 90 days before the close of the central organization's annual accounting period. Thus, central organizations should create internal reminders, similar to other tax filing deadlines, to ensure their notification obligations are met in a timely fashion.
Document ID: 2019-0634 | |||||||||||||||||||||||||||
