Written policy for tax-exempt bonds required for the 2011 Form 990 (Fiscal Year 2012)

June 2012


The IRS continues to focus on post-issuance compliance for tax-exempt bonds. The 2010 Form 990 Schedule K (Supplemental Information on Tax -Exempt Bonds) asked organizations if they have adopted management practices and procedures to ensure the post-issuance compliance of its tax-exempt bond liabilities. For 2011, the IRS has further revised Form 990, Schedule K to include a new question regarding whether the organization has established written procedures to ensure that violations of federal tax requirements are timely identified and corrected through the voluntary closing agreement program if self-remediation is not available under applicable regulations. In order for an organization to answer "yes" to this question the procedures must be in place by its FY12 fiscal year end. Unlike certain other policies, in order to answer "yes", such procedure may be implemented through the organization's standard processes and does not require approval by the board or a committee of the board.

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