Political Law Notes

New IRS 501(c)(4) Filing Requirements

Date: October 3, 2016

The PATH Act, which was enacted at the end of 2015, requires a 501(c)(4) organization to notify the IRS within 60 days of organizing of its intent to operate under that section of the IRC. The notification must be submitted on Form 8976, which can only be filed electronically. The first filings, for organizations that were formed prior to July 8, 2016, were due last month. The IRS portal for submitting the form can be accessed at this link.

New filers should note that the electronic filing portal cannot be accessed using the URL cited in Revenue Procedure 2016-41 – use the link above. Law firms, accountants and other third-party filers will be happy to learn that one individual can file notifications for many organizations at the filing portal. There is a $50.00 fee for filing the notification, and a late fee of $20 per day (up to $5000 maximum).