We want to bring to your attention an important new IRS filing requirement for churches and non-profits: the FinCEN Beneficial Ownership Information (BOI).

Here are the key points:

1. Churches and nonprofits are NOT automatically exempt from BOI reporting.
2. If your church or nonprofit has a valid 501(c)(3) determination letter from the IRS, you are NOT required to report BOI.
3. However, churches that are automatically considered 501(c)(3) organizations for certain purposes without an IRS determination letter fall under a different requirement:

Those churches operating as 501(c)(3) organizations under the presumption of tax exemption, without obtaining a 501(c)(3) determination letter, ARE required to file their BOI information and any future updates.

The crucial factor is whether you have an IRS determination letter stating your church has valid 501(c)(3) status. If not, your church or non-profit must comply with the BOI federal reporting requirement. We strongly advise consulting your accountant for clarification.

We hope this information will be helpful to our SWC congregations.