Annual revenue procedures released; revised process for Form 1024-A for section 501(c)(4) determinations

Revised process for submitting Form 1024-A

The IRS today released an advance version of Rev. Proc. 2021-8 to update the determination letter procedure for organizations described in section 501(c)(4).

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Rev. Proc. 2021-8 [PDF 153 KB] modifies Rev. Proc. 2021-5, published yesterday, to provide that effective today, electronic submission is the exclusive means of submitting a completed Form 1024-A, Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code, except for submissions eligible for the 90-day transition relief provided by today’s revenue procedure. 

Rev. Proc. 2021-5 was published yesterday in Internal Revenue Bulletin 2021-1 [PDF 19.19 MB] (dated January 4, 2021) (299 pages) along with five other annual revenue procedures:

  • Rev. Proc. 2021-1 - Letter rulings, information letters, and determination letters
  • Rev. Proc. 2021-2 - Technical advice
  • Rev. Proc. 2021-3 - Areas in which rulings will not be issued (domestic area)
  • Rev. Proc. 2021-4 - Determination letters and letter rulings (tax-exempt and government entities, employee plans)
  • Rev. Proc. 2021-7 - Areas in which rulings will not be issued (international area) 

Rev. Proc. 2021-8 and electronic submission rules

The electronic submission process for Form 1024-A replaces the paper submission process for Form 1024-A after January 5, 2021. The IRS will accept for processing a completed paper Form 1024-A (accompanied by the correct user fee) if the submission of the Form 1024-A is postmarked on or before April 5, 2021, the date that is 90 days after January 5, 2021 (the effective date of the revenue procedure).

Rev. Proc. 2021-8 also addresses the procedures for requesting expedited handling, which must be made in writing, preferably in a separate letter sent with, or soon after filing, the request for the determination letter. If the request is not made in a separate letter, then the letter in which the determination letter request is made must have the following notation at the top of the first page: "Expedited Handling Is Requested. See page ___ of this letter." In the case of an electronically submitted Form 1024-A, a request for expedited handling must be indicated on the form and a supporting written statement must be submitted as an attachment with the completed application.

Organizations described in section 501(c)(4) may choose to seek a determination letter recognizing tax-exempt status under section 501(c)(4) by filing Form 1024-A, but are not required to do so except in certain cases.  However, all section 501(c)(4) organizations must electronically submit Form 8976, Notice of Intent to Operate Under Section 501(c)(4), within 60 days of formation.

Read a related IRS release—IR-2021-02 (January 5, 2021).

Read a TE/GE memorandum [PDF 127 KB] providing interim guidance for IRS processing of electronically submitted Forms 1024-A


For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Ruth Madrigal | +1 202 533 8817 | ruthmadrigal@kpmg.com

Preston Quesenberry | +1 202 533 3985 | pquesenberry@kpmg.com

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