Form 8822-B Requirements for Churches: Staying Compliant

Discover why churches must comply with Form 8822-B requirements, including timely updates to the IRS about responsible party changes.

Last Reviewed: January 11, 2025

Any church that has employees, files employment tax returns, or maintains a bank or brokerage account must have an Employer Identification Number (EIN). This requirement applies to nearly every church in the United States.

In 2010, the IRS introduced a process to collect information about the “responsible parties” associated with EINs. This step aimed to ensure that all tax-related correspondence reached the appropriate individuals. The IRS requested the name and Social Security number of a responsible party through Form SS-4, which is used to obtain an EIN.

The Introduction of Form 8822-B

By 2013, the IRS became increasingly frustrated with its inability to contact responsible parties identified on Form SS-4. Many responsible parties had moved, resigned, or passed away. As a solution, the IRS established a new requirement for all EIN holders: the need to report changes in their responsible party using Form 8822-B. This change was first announced on November 18, 2013, in the IRS newsletter Employee Plans News:

Key IRS Announcement:

“Beginning January 1, 2014, any entity with an EIN, such as a plan sponsor, must report a change in the identity of their plan’s responsible party on Form 8822-B, Change of Address or Responsible Party – Business, within 60 days of the change.”

Clarifying Form 8822-B Requirements

Church leaders were initially confused about this requirement. While the IRS did not impose penalties for failing to meet the original March 1, 2014, compliance date, the agency strongly encourages timely reporting of any changes to responsible parties. Failure to submit Form 8822-B could result in missed correspondence, including:

  • Warnings about incomplete paperwork
  • Notices of taxes owed
  • Information about potential fines and penalties

To remain compliant, churches must notify the IRS of any changes to their responsible party within 60 days by filing Form 8822-B. This ensures that critical IRS communications are directed to the appropriate individual.

Why Compliance Matters

Filing Form 8822-B helps churches avoid miscommunications with the IRS that could lead to administrative complications or financial penalties. Keeping the IRS updated about responsible party changes ensures churches remain informed about their tax obligations and avoids unnecessary risks.

FAQs

  • What is Form 8822-B?
    Form 8822-B is used to report changes in the responsible party or address for any entity with an EIN.
  • Who is considered a responsible party?
    A responsible party is the individual who controls, manages, or directs the entity’s funds and assets.
  • What happens if Form 8822-B is not filed?
    Failure to file may result in missed IRS communications, leading to fines or penalties for unresolved tax issues.
  • How soon must Form 8822-B be filed after a change?
    It must be filed within 60 days of a change in the responsible party or address.

Church leaders should prioritize updating the IRS promptly to ensure compliance and maintain smooth operations.

Richard R. Hammar is an attorney, CPA and author specializing in legal and tax issues for churches and clergy.
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