501(c)3 with no physical office

I'm on the board of a small 501(c)3 organization, a public charity not a private foundation. We have no employees, and directors are all volunteers. Like a lot of small charities, we operate on a shoestring.

The IRS website says we must have certain documents available for public inspection at our principal office. But we don't have any physical office. In such a case, how do we need to respond to a request to inspect documents? Is it enough to respond promptly to any request sent to our mailing address or phone number offering copies of the documents in question? Or should we just finesse the issue by carrying the documents on our website?

(This is all theoretical so far: in 25 years, as far as I know, we've never had a request to inspect documents. But I want us to ready in the event, however unlikely, of such a request.)

BTW, we're a California corporation, but the CA attorney general's guide to charities doesn't answer this question. The only inspection requirement it mentions is the Federal one.

Reply to
Stan Brown
Loading thread data ...

For the purpose of compliance with public disclosure, the office is wherever your treasurer keeps financial records. I would absolutely not set up a meeting with a stranger at your treasurer's home. Meet in a public library if there's a need to disclose paper records.

There are multiple ways to comply, so do whatever is easier for you. Plenty of charities just point to Guidestar given that it provides tax returns, although they don't include all schedules.

You are not required to disclose Schedule B Schedule of Contributors, and it's not always a mandatory part of the tax return since the Trump administration regulation change.

Also, some recent tax returns are available on the IRS Web site, but there are plenty of tax returns missing. If your tax return for a particular year is available on the IRS Web site, then you are in compliance with the disclosure requirement, at least for that year.

Might as well disclose your state filing as well if asked. It's the same information in a different layout, and it demonstrates that you are complying.

Reply to
Adam H. Kerman

Adam, I don't think I ever said thank you for the advice, so: Thank you.

I looked at Guidestar, and maybe I misread something but it sure looked like they charge a fee for those records. Anyway, since storage is cheap, we're going to put the disclosures on our website, where people can get them on demand and without fee -- not that we've ever received a request since I've been on the Board, but I want us to be in compliance and this way I know we are.

Your point about not meeting in a Director's home is well taken, but when stuff is on the website that issue shouldn't arise.

Reply to
Stan Brown

You're welcome. I'm glad you found a solution that works for your organization.

With a free account, one can look at the three most recent tax returns of a specific charity.

I've heard of charities that scan in and put up older tax returns on their Web site if they receive a request, anything to avoid letting the requestor look through paper records in person.

Whatever you put on the Web, make sure you do a lot of redacting, especially financial accounts and names of contributors.

Reply to
Adam H. Kerman

Thanks -- obviously I did miss something.

We're small enough that we file form 990-N, the online "postcard return", so names of contributors never appear, and there are no paper returns.

(We're trying to up our game on fundraising, so hopefully that will not always be true.)

Reply to
Stan Brown

Oh. I didn't realize there were no tax returns.

Given that you would want to prove you had given timely notice on 990-N you should refer your Web site's visitors to the IRS Web site anyway.

Tax Exempt Organization Search

formatting link
Tell them to search with your EIN without the hyphen.

This reminds me that two of my tiny organizations had June year ends and I really should make sure the 990-N get filed. I have to look for the credentials I haven't used in a year!

Reply to
Adam H. Kerman

BeanSmart website is not affiliated with any of the manufacturers or service providers discussed here. All logos and trade names are the property of their respective owners.