I'm on the board of a small 501(c)3 organization, a public charity
not a private foundation. We have no employees, and directors are all >volunteers. Like a lot of small charities, we operate on a
shoestring.
The IRS website says we must have certain documents available for
public inspection at our principal office. But we don't have any
physical office.
In such a case, how do we need to respond to a
request to inspect documents? Is it enough to respond promptly to any
request sent to our mailing address or phone number offering copies
of the documents in question? Or should we just finesse the issue by
carrying the documents on our website?
(This is all theoretical so far: in 25 years, as far as I know, we've
never had a request to inspect documents. But I want us to ready in
the event, however unlikely, of such a request.)
BTW, we're a California corporation, but the CA attorney general's
guide to charities doesn't answer this question. The only inspection >requirement it mentions is the Federal one.
Stan Brown <the_stan_brown@fastmail.fm> wrote:
The IRS website says we must have certain documents available for
public inspection at our principal office. But we don't have any
physical office.
For the purpose of compliance with public disclosure, the office is
wherever your treasurer keeps financial records. I would absolutely not
set up a meeting with a stranger at your treasurer's home. Meet in a
public library if there's a need to disclose paper records.
In such a case, how do we need to respond to a
request to inspect documents? Is it enough to respond promptly to any >request sent to our mailing address or phone number offering copies
of the documents in question? Or should we just finesse the issue by >carrying the documents on our website?
There are multiple ways to comply, so do whatever is easier for you.
Plenty of charities just point to Guidestar given that it provides tax returns, although they don't include all schedules.
On Sat, 3 Jun 2023 18:33:41 EDT, Adam H. Kerman wrote:
Stan Brown <the_stan_brown@fastmail.fm> wrote:
The IRS website says we must have certain documents available for
public inspection at our principal office. But we don't have any
physical office.
For the purpose of compliance with public disclosure, the office is >>wherever your treasurer keeps financial records. I would absolutely not
set up a meeting with a stranger at your treasurer's home. Meet in a
public library if there's a need to disclose paper records.
In such a case, how do we need to respond to a
request to inspect documents? Is it enough to respond promptly to any >>>request sent to our mailing address or phone number offering copies
of the documents in question? Or should we just finesse the issue by >>>carrying the documents on our website?
There are multiple ways to comply, so do whatever is easier for you.
Plenty of charities just point to Guidestar given that it provides tax >>returns, although they don't include all schedules.
Adam, I don't think I ever said thank you for the advice, so: Thank
you.
I looked at Guidestar, and maybe I misread something but it sure
looked like they charge a fee for those records.
Anyway, since storage is cheap, we're going to put the disclosures on
our website, where people can get them on demand and without fee --
not that we've ever received a request since I've been on the Board,
but I want us to be in compliance and this way I know we are.
Your point about not meeting in a Director's home is well taken, but
when stuff is on the website that issue shouldn't arise.
Stan Brown <the_stan_brown@fastmail.fm> wrote:
I looked at Guidestar, and maybe I misread something but it sure
looked like they charge a fee for those records.
With a free account, one can look at the three most recent tax returns
of a specific charity.
I've heard of charities that scan in and put up older tax returns on
their Web site if they receive a request, anything to avoid letting
the requestor look through paper records in person.
Whatever you put on the Web, make sure you do a lot of redacting,
especially financial accounts and names of contributors.
On Wed, 2 Aug 2023 13:02:16 EDT, Adam H. Kerman wrote:
Stan Brown <the_stan_brown@fastmail.fm> wrote:
I looked at Guidestar, and maybe I misread something but it sure
looked like they charge a fee for those records.
With a free account, one can look at the three most recent tax returns
of a specific charity.
Thanks -- obviously I did miss something.
I've heard of charities that scan in and put up older tax returns on
their Web site if they receive a request, anything to avoid letting
the requestor look through paper records in person.
Whatever you put on the Web, make sure you do a lot of redacting, >>especially financial accounts and names of contributors.
We're small enough that we file form 990-N, the online "postcard
return", so names of contributors never appear, and there are no
paper returns.
(We're trying to up our game on fundraising, so hopefully that will
not always be true.)
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