Any entity with an EIN (Employer Identification Number) must report to the IRS any changes to its mailing address, location, or “responsible party.” A “responsible party” is the person in the organization who, as a practical matter, controls, manages, or directs the funds and other assets of the organization. In all likelihood, for most RCA churches and other assemblies and institutions the responsible party will be its treasurer.
The IRS form to use when reporting such changes is Form 8822-B. Click here to access the form and related instructions regarding how to complete and submit it.
The stated purpose of the form is to ensure that the IRS has current information regarding who to contact if it has any questions regarding the organization. Contact information would have been provided at the time the organization originally applied for its EIN (using IRS Form SS-4), but over time, with changes in staff, officers, and other leadership, that information becomes outdated.
Contact your own accountant, attorney, or other qualified professional for specific advice regarding the form and any other tax related matter. Having said that, however, we note the following:
1. Filing the form is mandatory, but there are no direct penalties (such as fines) for failing to do so. The instructions for Form 8822-B state: “If you are an entity with an EIN and your responsible party has changed, use of this form is mandatory. Otherwise, use of this form is voluntary. You will not be subject to penalties for failure to file this form. However, if you fail to provide the IRS with your current mailing address or the identity of your responsible party, you may not receive a notice of deficiency or a notice of demand for tax. Despite the failure to receive such notices, penalties and interest will continue to accrue on any tax deficiencies.”
2. When completing the form, be sure to check the box near the top indicating that your organization is tax-exempt.
3. If you are unable to locate the Form SS-4 that was completed and filed when your organization originally applied for its EIN, consider filing Form 8822-B anyway and providing as much information as possible.
4. Finally, when you send the completed Form 8822-B to the IRS, please send a copy to the office of the RCA’s general counsel. The mailing address is 612 8th St. SE, Orange City, Iowa 51041. The email address is groupexemption@rca.org. The general counsel must file annual updates to the group exemption roster that is maintained by the General Synod. Information in the completed Form 8822-B will be very helpful for that process.
If you have questions after reading this summary and reviewing Form 8822-B and its related instructions, feel free to contact the RCA’s finance office at finance@rca.org or the general counsel’s office at groupexemption@rca.org.
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