The IRS recently unveiled its new streamlined online search tool, Exempt Organizations Select Check (“EO Select Check”), which provides one place where taxpayers can go to find out: (1) whether an organization is eligible to receive tax-deductible contributions; (2) whether the organization has ever been subject to automatic revocation of its tax-exempt status for failing to file a required Form 990, Form 990-EZ or Form 990-N (aka, the “e-Postcard”) for three consecutive years; and (3) whether a small organization has filed the e-Postcard. Previously, taxpayers had to utilize three separate online search sites to find this information (the electronic version of Publication 78 (i.e., the list of exempt organizations eligible to receive tax-deductible contributions), the online Auto-Revocation List and the e-Postcard database).
EO Select Check consolidates these three former online search sites and also includes an expanded menu of search options, allowing users to search organizations by employer identification number, name, city, state, zip code, country, exemption type and revocation posting date. Additionally, under the new platform both the Publication 78 data and the Auto-Revocation List will be updated monthly. Previously, the electronic version of Publication 78 was only updated quarterly. The Form 990-N (e-Postcard) data will continue to be updated weekly.
Contributors and grantors may rely on the Publication 78 data found in EO Select Check to determine whether contributions to an organization are tax-deductible just as they could rely on the information in the electronic version of Publication 78. It is important to note that EO Select Check only includes the 501(c)(3) exempt organizations that would have been listed in Publication 78, i.e., it doesn’t include subordinate organizations covered under a group exemption. Such subordinate organizations and other non-501(c)(3) exempt organizations will continue to be listed in the online Exempt Organizations Master File.
Notably, the IRS recently clarified that once an organization’s tax-exempt status has been automatically revoked for failing to file a required Form 990, Form 990-EZ or Form 990-N (e-Postcard) for three consecutive years, the organization will appear on the Auto-Revocation List permanently unless it can show that the listing was erroneous (i.e., by showing that it had in fact timely filed the applicable Form 990 for at least one of the prior three consecutive years or had received an IRS determination letter that no filing was required). The IRS reminded organizations that the Auto-Revocation List is the IRS’s official record of organizations whose tax-exempt status has been automatically revoked and, thus, the subsequent reinstatement of an organization’s tax-exempt status will not result in the organization being removed from the list. Exempt organizations should take note that this permanent public record of the automatic revocation of an organization’s tax-exempt status could have a long-term impact on how potential contributors and grantors perceive the organization, especially now that EO Select Check makes it easier than ever for potential contributors and grantors to access this information online.
Further information about the Auto-Revocation List and EO Select Check can be found at the IRS website and in our previous posts on April 5, 2010, July 27, 2010 and June 20, 2011.