现在11月. 许多免税组织的截止日期已经过去了, it is time to reflect on the challenges tax practitioners serving 免除组织 (EO) have encountered. Members of AICPA’s Exempt Organizations 税ation Technical Resource Panel (TRP) shared their experiences, 很多问题都与 美国国税局豁免机构商业主文件(EO BMF). EO BMF信息错误。处理步骤, 以及无法及时更新系统, have caused considerable disruptions for many tax-免除组织. 尽管这些问题以前就存在， 强制性的电子编档, 再加上与大流行有关的IRS处理问题, made it more challenging to file returns for entities that were having issues with the EO BMF this year.
The EO BMF is the IRS’ basic record source for information about tax-免除组织. That includes the IRC subsection under which the organization is exempt, 501(c)(3)条实体的基础分类, the primary return the organization is required to file and a code that indicates whether contributions to the organization are deductible. 《188bet亚洲真人体育下载》中的不准确信息包括:
错误的自动撤销豁免状态 — With the IRS lag time in processing paper-filed Forms 990 and extensions due to the pandemic, some organizations have received notification that their tax-exempt status has been revoked for not filing returns that were at the IRS site but not processed.
税务年终资料不正确 — A mismatched accounting period between the return and the EO BMF will reject an electronic filing, affecting organizations that had a change in the accounting period reported during the pandemic, as well as entities with legacy issues they didn’t know existed. These organizations had past paper filings or electronic filings accepted before recently rejected e-filings.
不正确的实体名称或名称更改未反映在EO BMF中 —类似于错误的年终问题, organizations that have changed their names experienced e-filing rejections of current year Forms 990.
Organizations not listed in EO BMF or listed under the wrong subsection of section 501(c) — Some organizations that have completed the IRS’ exemption recognition process and received their exempt status letter have had their e-filed Form 990 rejected. The explanation is that the EO BMF does not match the information reported on Form 990.
群体裁决和下属组织 — There are a lot of mismatches in the BMF system for the separate accounts. To fix the e-filing group, each account has to be updated separately.
The auto-revocation of tax-exempt status is troubling because the IRS posts the notice on its website and updates its 免税组织搜索(TEOS)工具. TEOS允许用户搜索发布的78个数据, auto-revocation列表, 确定信, 申报表及表格990-N副本. An error indicating an entity is no longer exempt has a substantial impact on the organization’s ability to receive donations, which tend to be the lifeblood of most charitable organizations. 没有这些重要的捐赠收入, 许多组织必须缩减业务规模, 这些都是为边缘人群服务的, 经济脆弱, 环境和其他公共利益的工作. The good news is that they can use a dedicated IRS fax line (855.247.6123) to 纠正这个错误.
Fixing these errors in the EO BMF can be challenging for the organization and its tax advisers. Calls to the IRS’ Customer Account Services often involve wait times of over an hour. 如果有太多的呼叫者在等待帮助, the automated phone system instructs the caller to call back and disconnects the call. While the IRS has a separate e-filing Services number and staff, Customer Account Services must handle any e-filing rejections associated with errors in the EO BMF. This results in a ping-pong effect of multiple calls to resolve the issue. 时机是另一个问题. Since the updates to the EO BMF do not get published to Publication 78 and the 免税组织 搜索 tool until the second Monday of every month, 一月份没有更新, taxpayers often have to wait a few months before the change appears in the system.
Practitioners attempting to resolve these matters on behalf of their clients expend a considerable amount of professional time and face the dilemma of the appropriate amount of fees to charge. These factors are in addition to all of the other challenges practitioners have faced during the pandemic with helping their clients meet their compliance requirements. The exempt organization sector is often already under-resourced, so it has limitations on the ability to pay extra practitioner billings and/or to fund erroneous penalties to prevent the IRS from levying the organization’s bank account.
AICPA®正在密切关注这些问题的进展. 在本纳税年度结束时, 免除组织, 以及他们的税务顾问, are wondering if they will ever catch up from pandemic slowdowns. These have included the repeated cycle of receiving and responding to erroneous notices, the IRS not processing responses promptly and having additional notices issued for the supposed failure of responding to the first notice. Considering the challenges related to the IRS’ budgetary and personnel constraints, 快速解决这些问题将是困难的. The status quo is not sustainable and there should be alternatives to accommodate the requests of tax practitioners. The AICPA is continuing discussions with the IRS regarding the appropriate solutions.