Proskauer’s 19th Annual Trick or Treat Seminar was held on Friday, October 31.

The Seminar discussed:

  • Charitable giving techniques
  • Labor and employment issues with using volunteers and interns
  • Recent developments in employee benefits

In her introductory remarks, Amanda Nussbaum discussed recent tax developments, including the development of IRS Form 1023-EZ, the process for reinstatement of tax-exempt status, and the proposed regulations under Section 501(c)(4), and introduced the presenters.

Tax-exempt organizations that have had their tax-exempt status automatically revoked because of failure to file required annual returns for three consecutive years can follow new procedures for seeking reinstatement of their tax exemptions.  The IRS released these procedures in Revenue Procedure 2014-11 on January 2, 2014.  The Revenue Procedure, which is the first IRS guidance on this topic since 2011, outlines three procedures that organizations may use to apply for reinstatement.

First, under a “Streamlined Retroactive Reinstatement Process,” small organizations eligible to file a short form (Form 990-EZ) or postcard return (Form 990-N) may have their tax-exempt status retroactively reinstated to the date of revocation, provided that they have not previously had their exemptions automatically revoked.  Under this procedure, organizations must complete and submit Form 1023 (Application for Recognition of Exemption Under Section 501(c)(3)) or Form 1024 (Application for Recognition of Exemption Under Section 501(a)) not more than 15 months after revocation.