If you have a technical or procedural questions concerning charities and other non-profit organizations you should contact the IRS Tax Exempt and Government Entities Customer Account Services at (877) 829-5500 (toll-free number). Direct questions about employment taxes to the Business and Specialty Tax Line at (800) 829-4933 (toll-free).
If you prefer to write, you write to:
Internal Revenue Service
Exempt Organizations Determinations
P.O. Box 2508
Cincinnati, OH 45201
The Exempt Organization Determinations office may also issue a determination letter applying the principles and precedents previously announced to a specific set of facts. If you wish to obtain a determination letter, or need to transmit copies of amended documents, you should write to Exempt Organizations Determinations.
The IRS will rule on the tax consequence of proposed changes to an organization’s purposes or activities. Thus, if you are unsure about whether proposed changes are consistent with your status as an exempt organization or as a public charity (if applicable), you may want to request a private letter ruling or determination letter. You may also obtain a determination letter on whether you are exempt from annual exempt organization returns.
In some areas, the law requires that an organization notify the Internal Revenue Service or receive an advance determination before undertaking a transaction resulting in certain tax consequences. Thus, an exempt organization must request a private letter ruling or determination with respect to the following issues:
Advance approval of scholarship programs, and certain other grant-making procedures, of private foundations (Internal Revenue Code section 4945(g))
Voluntary termination of private foundation status, except by transferring assets to, or operating as, a public charity (Code sections 507(b)(1) and (2))
Certain determinations regarding application of the neighborhood land rule (Code section 514(b)(3))
Status as an exempt operating foundation (Code section 4940(d))
Establishment of a set-aside (Code section 4942(g)(2))
Extension of disposal period for certain excess business holdings (Code section 4943(c)(7))
Advance approval of private foundation voter registration activities (Code section 4945(f))
Certain changes in an organization’s accounting methods and periods (see Publication 4221-PC, at p. 8, for a general discussion of accounting methods and periods)
Treatment of a grant as an unusual grant under sections 1.170A-9(e)(6)(ii) and 1.509(a)-3(c)(3) and related provisions of the Income Tax Regulations.
If you want to elevate an issue within the Exempt Organizations management structure about an issue in a specific case, or request a closing agreement, write to the appropriate manager.
Generally, an exempt organization may initiate a closing agreement by sending a letter to the appropriate area office. The letter must contain the following information:
- Why a closing agreement is appropriate
- The advantages to the organization and how the government will sustain no disadvantages
- A detailed description of the method proposed for correcting non-compliant activities
- A narrative description of the correction method, providing specific information to support the suggested method
- How the taxpayer will achieve future compliance
- Proposed methodology to calculate any tax, interest, and penalty, for the tax period(s)
Additional information
- Internal Revenue Manual 4.75.25, Exempt Organizations Examination Procedures, Exempt Organizations Closing Agreements
- Internal Revenue Code section 7121
- Treasury Regulations § 301.7121-1
DISCLAIMER: This information is not intended to provide legal or accounting advice, or to address specific situations. Please consult with your legal or tax advisor to supplement and verify what you learn here.
