Any church that has employees, files employment tax returns, or has a bank or brokerage account, must have an "employer identification number" (EIN). This includes nearly every church in the United States. An EIN is obtained by filing a Form SS-4 with the IRS using the IRS website (irs.gov) or by submitting a paper form. Since 2010, line 7 of Form SS-4 has asked for the name and Social Security number of a "responsible party" of the applicant.
The IRS became increasingly frustrated by its inability to communicate with responsible parties identified in employers' SS-4 forms, usually because the responsible parties designated by employers no longer served in those capacities due to any number of reasons, including resignation or death. On November 18, 2013, the IRS adopted an entirely new requirement to address this problem, stating any employer with an EIN must report changes in the identity of its responsible party to the IRS by March 1, 2014, using Form 8822-B.
Many church leaders want to know if this new reporting rule applies to churches. In the upcoming April 2014 issue of Church Finance Today, I go deeper on the rule's application to churches, including how to complete the form, how to respond to this requirement depending on when your church was founded and obtained an EIN, and how to maintain compliance in future years.
However, to help address some immediate concerns, given the looming March 1, 2014, deadline, here are five key items to note: