As upcoming Form 990 filing season approaches, organizations are adapting to changes from the prior year’s form and instructions, as well as new IRS mandatory e-filing requirements discussed here which are now required for all 2020 (and beyond) Forms 990 going forward under the Taxpayer First Act enacted in 2019.
It has come to Withum’s attention, that the IRS may be requiring that the social security number of the officer signing Form 990 be provided for electronic verification purposes. While this may be the interpretation of our vendor and we are not aware of any new IRS requirements, we are concerned enough to be notifying you of this issue and raising our concerns with the IRS. Although this information would presumably not be made public with Form 990, the IRS’s record on not releasing confidential information is not flawless.
This potential new requirement is concerning to all filers of publicly posted returns and was not formally discussed with the community of Form 990 tax return preparers in advance of implementation. This requirement has caught the exempt organization industry by surprise, as well as, Withum, and we will be addressing this with the IRS and other practitioners. We will keep you updated as this develops.