reporting requirements under the CTA within 180 days of the revocation. It is essential the nonprofit’s leadership keep an eye on this 180-day deadline as it may arrive prior to the IRS’ reinstatement of the organization’s tax-exempt status. Nonprofit Organizations Formed Before Jan. 1, 2024, That Have Not Yet Received Recognition as 501(c) Organizations If an organization is required to apply for recognition of tax-exempt status and the IRS has not yet issued a determination letter recognizing the organization’s status under 501(c), the organization is not exempt from the reporting requirements under the CTA. However, for nonprofit organizations formed prior to Jan. 1, 2024, there is a one-year grace period to comply with the CTA. Directors and officers of these organizations should be monitoring when they expect a determination letter from the IRS regarding tax-exempt status and the requirement to report under the CTA by Jan. 1, 2025, if tax-exempt status has not yet been granted. New Nonprofit Organizations Formed in 2024 or Later That Are Required to File for Recognition of Tax-Exempt Status For nonprofit organizations formed after Jan. 1, 2024, the organization is required to report under the CTA within 90 days of formation. Because it is very unlikely that the IRS would grant a determination of a new organization’s tax-exempt status within 90 days, advisers to new nonprofit organizations should discuss reporting responsibilities under the CTA during the time that the organization may be waiting to obtain tax-exempt status. Nick O’Brien and Kate Hughes, attorneys at Koley Jessen, are integral members of the firm’s Estate, Succession, and Tax Department. Their expertise spans a spectrum within this specialized area, covering estate and wealth transfer planning, charitable planning, nonprofit formation and compliance, and tax. With their extensive knowledge and experience, they serve as dependable guides for CPAs navigating the nuanced impact of the Corporate Transparency Act on charities. For additional information or assistance, please contact O’Brien at nick.obrien@koleyjessen.com and Hughes at kate.hughes@koleyjessen.com, respectively. ENDNOTES 1 See 87 FR 59498 (2023) (including official comments by FinCEN regarding public comments and final regulations). CLASSIFIED AD Nebraska Practices for Sale: Gross Shown: $635K Southwest, Nebraska $311K Lincoln, Nebraska For more information Call 1-800-397-0249 or visit www.APS.net THINKING OF SELLING? Accounting Practice Sales is the leading marketer of accounting and tax practices in North America. To learn more about our risk-free & confidential services, call Trent Holmes 1-800-397-0249 or email Trent@apsholmesgroup.com REACH OUT TODAY TO LEARN MORE! Determining the worth of your business is an intricate task. There are many factors involved. Results Business Advisors 12020 Shamrock Plaza #200 Omaha, NE 68154 402.913.9080 www.resultsba.com Scan QR code to watch the EBITDA vs. SDE video. https://www.resultsba.com/ebitda-vs-sde/ 21 www.nescpa.org
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