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MAY
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A
Message from EDIN
The transition to electronic filing has officially begun,
with 267 requests for extensions, 56 Form 990s and 137
Form 990-EZs electronically filed with the IRS as of May
18. The expectations for electronic filing of the 990s
this filing season are modest as state and federal regulators,
tax preparation software developers, practitioners and
associations of nonprofit organizations grapple with market
and regulatory incentives to expand the availability of
990 e-filing software, and make e-filing easy and efficient
for nonprofit filers and the CPAs who often are the ones
who actually submit the forms.
The
challenge to identify specific incentives
was evident at two recent meetings,
the 14th Annual IRS Form 990 meeting
hosted by the National
Center for Charitable Statistics’ (NCCS)
at the Urban Institute and the
spring meeting of the Council
of Electronic Revenue Communications
Advancement (CERCA), a not-for-profit
trade association that represents a
broad cross-section of the electronic
tax filing, IRS systems modernization,
and state electronic revenue communities.
The
NCCS meeting brought together 60 representatives
from state charity offices and state
nonprofit associations who share a
common interest in improving access
to timely and accurate information
on the sector. Put Barber, President
of The
Evergreen State Society in Seattle,
WA, believes the strongest incentive
for e-filing from the nonprofit sector’s
perspective is the ability to get more
accurate information out to the public
more rapidly.
In not wishing to create a disincentive to e-file, the
IRS, in the short-term, is treating e-filers the same as
paper filers. Midori Morgan-Gaide, senior manager for the
IRS Exempt Organizations Electronic Initiatives Office,
acknowledged that as the number of e-filed 990s grows,
the information could be made available faster.
Ease
of filing is certainly an incentive
for nonprofits, and the walk-through
of the 990-EZ
Online at NCCS’ meeting
succeeded in making its case for being
user-friendly. New
Hampshire State Charity Registrar Terry
Knowles was so impressed with the free,
web-based application that she suggested
that a “road show” for
the 990-EZ Online would “convince
nonprofits and their practitioners
that e-filing the 990 is not that difficult.”
Exploring
incentives was also the topic at CERCA’s
spring meeting, during which a top
notch group of panelists discussed
the issues affecting 990 e-filing,
including a company’s decision
to invest the resources in 990 e-filing
software. The dialogue with CERCA’s
members and the practitioners attending
the session marked the beginning of
a closer working relationship and a
better understanding of the market
challenges in serving the nonprofit
sector at both the federal and state
levels.
EDIN’s
new ad
hoc working group on nonprofit electronic
reporting will help us develop
strategies to address these market
issues as well as recommend approaches
to achieve a streamlined federal and
state process for reporting and disseminating
information on the sector.
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FAQs
for Exempt Organization Filers
What
is Modernized e-File (MeF)? How is
it different from other IRS e-file
systems?
MeF is a modernized web-based system that allows electronic
filing of returns through the Internet using the widely accepted
XML format, a standardized way of identifying, storing and
transmitting data. Older IRS e-file systems use a telephone
connection to transmit e-filed returns using an IRS proprietary
data transmission format. Both MeF and the older e-file systems
require registered Electronic Return Originators (ERO’s,
e.g. tax practitioners) to use return preparation software
packages that have been certified by the IRS. The modernized
electronic system provides immediate feedback in understandable
terms regarding acceptance of the return or rejects situations
(such as when the Employee Identification Number on the e-filed
return doesn’t match IRS records). The older systems
use error code numbers.
back
to questions
Which
Exempt Organization returns can be
e-filed?
Electronic filing is currently available for Forms 990 (including
Schedules A and B), 990-EZ, 1120-POL, and the extension Form
8868. The Form 990PF will be made available next filing season.
back
to questions
So
how do I submit all those attachments,
explanations, etc. required by the
Form 990 instructions? Can I attach
spreadsheets or similar documents
to my e-filed Form 990?
You will no longer need to attach explanations, spreadsheets
or other documents to your electronically filed Form 990.
In all situations where you are asked to provide an explanation
or description, the software will prompt you for the necessary
information to allow for the automatic inclusion of the required
information. We refer to this as a “structured” attachment.
In some cases the software will create the attachment, and
in other situations you will be able to enter the necessary
information in the structured attachments ranging in size
from 20 to 9000 characters, depending on the specific question
from the Form 990. This should make it easier to provide
all of the required information. The IRS will accept a scanned
Form 8453 signature document, which must be in PDF format.
This option to sign electronic returns is available to filers
who elect not to use a PIN to sign their return.
back
to questions
Is
there enough room on the electronically
filed return for my organization
to describe its activities and provide
other required information?
In all cases, the electronic Form 990 provides more space
than the paper return for required explanations and descriptions.
Plus the electronic Form 990 includes up to three General
Explanation “Attachments”. Use of these is optional,
but each provides approximately three pages where filers
can include text to provide any additional explanations or
descriptions as desired.
back
to questions
What’s
in it for me?
- Convenience – no
more photocopying, finding a big
enough envelope, going to the Post
Office for certified mail
- Certainty – MeF
users receive prompt acknowledgment
when returns are accepted
- Correctness – use
of approved software, which conforms
to MeF specifications, dramatically
reduces the number of errors on accepted
returns. Submission of a more accurate
return will reduce the follow up
correspondence and interaction with
the IRS.
back
to questions
So
how, exactly, do I e-file my Form
990, 990EZ, 1120POL or 8868?
Visit www.irs.gov and
click on the e-file logo in the lower right hand corner.
Click on e-file for Charities and Nonprofits for the most
current information. This site will give you or your practitioner
an updated list of return preparation packages that offer
electronic submission of Forms 990, 990EZ, the extension
Form 8868 and Form 1120POL.
back
to questions
Who
can help me if I have a problem with
my electronically
filed Form 990?
If you are a nonprofit organization using a practitioner
to file your return, work with your practitioner to resolve
problems or questions about the information on the return.
There is an E-Help Desk in the Ogden Service Center (1-800-255-0654)
that will work with registered practitioners and transmitters
to help resolve electronic filing problems. You or your practitioner
may also work with the technical support function of the
software developer who produced the software being used to
prepare and transmit your return.
back
to questions
top
of article | table
of contents
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Multi-state
Filers Have Most to Benefit from E-Filing
if IRS, States Consolidate Filing Dates & Streamline
Reporting in One Electronic Submission
At
BDO Seidman LLP’s Bethesda, MD office,
the flurry of activity leading up to
May 15 has temporarily quieted down. “We had the normal
attack of last-minute returns for calendar year 990s and
met our bigger challenge — filing the returns for our
June year end tax-exempt clients whose final six-month extensions
came due,” says Mike Sorrells, CPA, who spoke with EDINews about
the incentives for electronic filing and the need for CPAs
and their clients to pay more attention to the 990.
Sorrells,
a partner and leader of BDO’s
National Nonprofit Tax Consulting Group and
a member of EDIN’s ad
hoc working group on nonprofit electronic
reporting, sees that 501(c)(3)s
that file in multiple states have the
most to benefit from e-filing. “There’s
a ton of paperwork going in a lot of
different directions at a lot of different
times and often with a lot of different
information. If we file a client’s
return in all 40 states that require
reporting, it costs our client significantly
more than the 990 we do for them.
“In
addition, there are always a lot of
extensions requested — the audit’s
not done and other various reasons.
If you request an extension to file
your 990 with the IRS, you then have
to contact the state charitable offices
to request an extension to file their
required annual reports, since many
states accept the 990 or require it
as an attachment to their form. That’s
more practitioner time and more client
staff time, and there’s a cost
to that as well. If the IRS and the
states could adopt the same filing
dates and streamline reporting with
one electronic submission, our nonprofit
clients would save a significant amount
of money.”
From
the regulators’ point of view,
making charitable reporting easier
will result in a better level of compliance.
Says Sorrells: “I suspect that
there are organizations that don’t
file in all the states they should
because it’s an administrative
nightmare.”
E-filing
by itself — without federal-state
consolidation and streamlining — will
not impact BDO’s work processes,
says Sorrells. “We’re already
putting numbers on a computer. The
real work is getting the information,
making sure it’s accurate and
getting it into the required format.” He
does feel that federal-state consolidation
would provide a strong incentive for
501(c)(3)s (who solicit multi-state)
to avail themselves of electronic filing. “However,
the rest of the 990 filing world, such
as 501(c)(4), (5) and (6) organizations,
will probably need more of a carrot
since they do not generally have to
file with the state charity authorities.”
For
more information, see BDO’s Nonprofit
Alert and Sorrell’s quarterly
column in “Exempt,” a new
magazine from the publisher of The
NonProfit Times.
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NASCO
President Calls on IRS to Require More
Uniformity Between Financial Statement,
Form 990
State
charity officials from
the states of California,
Colorado, Florida, Illinois,
Maryland, Massachusetts,
Minnesota, Mississippi,
New Hampshire, Pennsylvania,
Texas, Virginia, and Washington
gathered in Washington,
DC, last month to meet
with the IRS officials
at the 14th annual Form
990 meeting sponsored by
the Urban
Institute’s
National Center for Charitable
Statistics (NCCS).
Mark Pacella, president
of the National
Association of State Charity
Officials (NASCO) and
chief deputy attorney general
of the Charitable
Trusts and Organizations
Section in the Pennsylvania
Office of the Attorney
General, presented
IRS Exempt Organizations
Division Director Steven
Miller with several suggestions,
including the need for
more uniformity between
charities’ financial
statements and the Form
990 and changes to the
IRS instructions to improve
the accuracy and quality
of information reported.
NASCO’s major concern
is consistency and quality
in reporting, said Pacella.
For
the first time, the
meeting was expanded
to include state nonprofit
association leaders
to allow more extensive
discussions of the
new e-filing option
for Form 990 offered
by the IRS.
The
NCCS E-filing Pilot
Project to develop
electronic charity
registration for states
co-sponsored the National
Association of Attorneys
General / National
Association of State
Charity Officials (NAAG/NASCO) and GuideStar,
has successfully launched
state charity registration
systems in Colorado
and Pennsylvania that
are compatible with
the IRS e-filing system. Although
the pilot project is
over, other states
can still participate
at a modest cost for
the additional programming
required. The IRS plans
to launch a single
point retrieval system
in 2006 that would
allow charities to
file both federal and
state reports in a
single submission.
“The
best incentive for
Form 990 e-filing is
making the system easy
for charities to complete
all their filing requirements
with one mouse click
and we are committed
to making all the NCCS-developed
programs meet that
goal. We encourage
all Form 990 software
developers to do the
same,” said Lampkin.
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Lessons
Learned and What's Ahead for Modernized e-File
IRS
senior staff and software
developers met recently
to discuss plans for electronic
filing and the challenges
ahead to be successful.
IRS Exempt Organizations
staff believe that as new
forms are added for e-filing,
more practitioners will
e-file the Form 990, since
their other clients' forms
will be submitted electronically
as well.
Software
developers told the
IRS they would need
14 months’ lead-time
to review the IRS’s
Schemas for future
forms (1041, 1065 and
the 1040 for Modernized
e-File). It would be helpful, they added, if the IRS were
to standardize, develop, and issue Schemas for all the forms
at the same time. IRS funding patterns have prevented the
IRS from issuing all schemas and business rules at once.
Software
developers and IRS
staff confirmed that
changes in state e-filing
mandates would continue
to affect the rollout
of other forms. In
2006, the IRS plans
to launch a new Fed-State
system for the 1120s
(corporate income tax)
and 990s, similar to
its existing State
Retrieval System for
the 1040s, but built
on the IRS’s
Modernized e-File platform,
which would allow taxpayers
and their practitioners
to electronically file
state and federal reports
simultaneously with
a single “click.” As
with the launch this
February, commercial
software will be needed.
The
IRS’s Fed-State
model for the 1120s
involves representatives
of 20 states who are
in the process of identifying
and defining all the
common data elements
and creating a standardized
taxonomy. “It’s
a lot of work up-front
with a huge pay-off,” remarked
South Carolina Department
of Revenue’s
Terry Garber, Chair
of the Tax Information
Group for EC Requirements
Standardization (TIGERS).
Jointly sponsored by
the Federation of Tax
Administrators and
the ANSI X12 national
standards organization,
TIGERS works with the
IRS to develop compatible
XML standards for state
and fed/state e-filing
for a variety of tax
types.
The
states are building
the schemas based on
categories of required
information — data
elements that relate
to federal income,
additions to federal
income, subtractions
to federal income,
assets, and liabilities,
for example. While
there will be only
one data element it
may be computed differently
from state to state. “It
will not be possible
to harmonize every
aspect of reporting
for all states,” said
Garber, noting that
some states send out
an acknowledgement
if the report is simply
legible while others
examine the return
against the business
rules before acknowledging
a successful submission.
One
of the challenges for
software developers
will be how to package
all the federal and
state reports in one
bundle for transmission.
Bundling the files
means that if the federal
return is rejected,
the states returns
are rejected, so each
return will have to
go through separately,
and the software will
have to provide a separate
acknowledgement for
each return.
| Software
Vendors for Form
990 |
Name
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Status
of Plans for
E-Filing Option
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currently
available
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| NCCS
990-EZ Online |
currently
available |
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expected
2004
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expected
2005
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expected
2006
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information
not available at
this time
|
The
National Center
for Charitable
Statistics at the
Urban Institute
now provides
free
software for
nonprofit organizations to
electronically
file Form 8868
(Application
for Extension
of Time to
File) with
the IRS. When
the request
for extension
has been accepted,
the IRS will
send an email
acknowledgement. |
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Quick
news about e-filing from EDIN:
- Steve Miller, Director,
IRS Exempt Organizations Division, presented
the TE/GE Commissioner's Award to Linda
Lampkin, program director of the National
Center for Charitable Statistics at
the Urban Institute, in recognition of
her efforts on the 990 e-filing program.
The award is the highest honor that can
be bestowed by TE/GE and is “in
recognition and appreciation of dedication
and outstanding personal contribution
to accomplishing the goals and mission
of TE/GE division and the IRS.”
- Julie
Floch, CPA, Partner and Director of
Not-for-Profit Services at
Eisner LLP (New York), has been selected to serve on
the IRS Advisory Committee on Tax Exempt and Government
Entities.
- The
May 17 issue of Nonprofit
Online News featured “Breakthroughs
in Electronic Filing for Nonprofits,” by
Putnam Barber, President of The
Evergreen State Society.
- Panelists
for EDIN’s session on 990 e-filing
issues at the Council
on Electronic Revenue Communication
Advancement’s (CERCA) Spring
Meeting included Midori Morgan-Gaide,
Senior Manager, IRS Exempt Organizations
Electronic Initiatives Office; Gene
Salo at Creative
Solutions; Bob Taylor, CFO, UTS and
Chairman of CERCA; Dan Moore, Vice
President of Public Affairs at GuideStar;
James Siegal, Assistant Attorney General
for Enforcement Technology in the New
York State Attorney General’s
Charity Bureau; Patty O’Malley,
Senior Manager of the Exempt Organizations
Specialty Group at Rubino & McGeehin;
and Linda Lampkin, Program Director
at NCCS.
top
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Calendar
May
27
The Colorado Society of CPAs’ Not-for-Profit Conference
will include a presentation on e-filing the 990s. For a copy
of the PowerPoint presentation to share with your colleagues,
members, or other CPA Societies, contact
EDIN.
June
3–4
IRS
Annual Software Developers
Conference, Arlington,
Virginia. Sessions
will include a discussion
of this year’s
launch of Modernized
e-File for Forms 990,
990-EZ and 8868, IRS e-Services, and signature authentication
issues. Registration is free.
June
8–10; 22–24
The IRS TE/GE Division will hold one-day
workshops for small and mid-sized tax-exempt 501(c) (3)
organizations. Locations include San Diego (June 8, 9 and
10) and Boston (June 22, 23 and 24). Registration is $25
per person. Topics include the Form 990. For more information,
call 1-800-826-1076.
June
14
Pennsylvania
Institute of CPAs (PICPA)
Not-for-Profit Conference,
Hershey Lodge and Convention
Center, Hershey, PA
June
15
Attorney
General's Education
Conference for Nonprofit
Board Members and Managers,
The Office of Massachusetts
Attorney General Tom
Reilly,
Worchester, MA
June
22
"Right
from the Start: Registration, Accounting and Tax Issues for Not-for-Profit Organizations," Attorney
General's Charities Symposium, The Office of New York Attorney General Elliot
Spitzer, New York City, NY
June
23
"Right
from the Start: Registration,
Accounting and Tax
Issues for Not-for-Profit
Organizations," Attorney
General's Charities
Symposium, The Office
of New York Attorney
General Elliot Spitzer,
Albany, NY
July – September
The IRS will hold a series of six
Tax Forums where tax professionals can receive assistance
in completing an application to participate in the IRS electronic
filing program.
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SUBMIT
NEWS AND COMMENTS
EDINews is a free online newsletter covering electronic
filing of the Form 990. Distributed monthly via e-mail
to subscribers, EDINews provides readers with the latest
news, information and comments from the IRS; state
charity bureaus; professional accountants serving the
not-for-profit community; and tax preparation software
developers. If you have news or comments to share,
we invite you to send them to EDINews editor Claudia
Holtzman at edin@IndependentSector.org
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EDINews
Contacts:
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Phone:
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Mail:
EDINews
Independent Sector
1200 Eighteenth Street, NW
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Copyright
© 2004 Independent Sector. All Rights Reserved.
1200 Eighteenth Street, NW, Suite 200, Washington, DC 20036
phone 202-467-6112; fax 202-467-6101
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