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									      Required IRS Tax Filing for 4-H Clubs & Qualified
All 4-H clubs and affiliated organizations that are eligible for the 4-H federal income tax
group exemption GEN 2704, and raise funds or accept donations, must file the
appropriate tax form on time even though some groups will be unsuccessful.

ACTION NEEDED: Communicate information within your states to ensure (1) that duly
authorized 4-H entities under the control of Cooperative Extension and eligible for GEN
2704 file appropriately with the IRS, and (2) share additional information as needed to
manage your 4-H Youth Development Program. Under the control of Cooperative
Extension means that Cooperative Extension has fiduciary responsibility for the duly
authorized 4-H organization.

Cooperative Extension, including State 4-H Program Offices, are responsible for their 4-
H youth development programs, including providing necessary guidance to ensure their
duly authorized 4-H organizations file their taxes correctly. This may include engaging
your university’s business office or otherwise assisting or directing your 4-H
organizations to seek professional tax advice.

IRS Filing Requirements

Qualifying Entities for inclusion under GEN 2704 are those 4-H entities that are:
              duly authorized 4-H clubs and affiliated 4-H organizations that are
              under the control of Cooperative Extension that
              earn income or accept donations (the latter – for which donors want
       charitable giving deductions)
              excluding Army and Air Force clubs (because they do not handle money
       nor have bank accounts), and may include
              those entities not earning income but for which a State 4-H Program
       Office has required an EIN and inclusion under GEN 2704.

Qualifying Entities Typically Earning $25,000 or Less File the 990-N E-Postcard
   Beginning in 2008, small tax exempt organizations needed to begin to annually
       file the 990-N or E-Postcard. This includes GEN 2704 subsidiaries.
   Previously communicated information regarding these organizations not being
       penalized for not filing the 990-N during 2008 does not extend into 2009.
   ALL eligible and qualifying organizations, which have been operating for at least
       one year, MUST file the 990-N on time (by the 15th day of the 5th month following
       the end of their tax period). (this date will be based on the date you indicated
       when you did the SS 4 for an EIN, but at this point we suggest that you just go
       the IRS site and try to do the report quarterly until it actually works.)
   Some organizations will not be successful in filing a 990-N in the near future.
       Reasons include that the organization is eligible for inclusion under GEN 2704,
       but their record is not listed under GEN 2704 with the IRS at this time.
      All organizations must keep documentation from the IRS in their files – including
       confirmation of successful filing and documentation of unsuccessful attempts to
       file the 990-N.
      Note, this is not the time and place to change information about the organization,
       such as tax year.
      The old adage applies here, ―It is better to try and fail rather than to never have
       tried at all.‖
      Instructions, forwarded on 10/2/07, for qualified entities in this income category
       that received IRS penalty notices for not filing in 2008 remain in effect.

Qualifying Entities Typically Earning More Than $25,000 File the 990 or 990-EZ
   There is NO CHANGE regarding the need for organizations in this income
       category regarding tax filing. These organizations have always needed to and
       must continue filing their taxes on time.
   Qualified organizations should list GEN 2704 on their tax forms, and
       indicate their tax exemption status as a 501(c)3 EVEN THOUGH GEN 2704
       subsidiaries are not independent 501(c)3 organizations—this is the most
       appropriate box to check on the tax forms.
   National 4-H Headquarters, USDA cannot provide professional tax advice about
       filing tax forms nor alleviate penalties when 4-H subsidiaries do not follow
       instructions nor file properly.

Role of National 4-H Headquarters, USDA Regarding GEN 2704

National 4-H Headquarters, USDA provides general guidance for state-level
communications regarding 4-H tax exemption—especially regarding inclusion and issues
involving GEN 2704.

National 4-H Headquarters does not provide professional tax advice and is not
authorized to receive hard or electronic copies of 4-H subsidiaries’ tax forms – as we are
not officers of those organizations.

National 4-H Headquarters can write ―emergency‖ tax exemption letters, per instructions
disseminated 10/7/08, for any eligible and qualified duly authorized 4-H organization for
which the State 4-H Program Leader is on record for assuring as duly authorized and
under the control of Cooperative Extension.

Until the IRS completes their assessment of the tax status for GEN 2704 and new plans
are in place with National 4-H Headquarters for 4-H tax exemption, National 4-H
Headquarters is not accepting updates and additions to GEN 2704. In the meantime,
State 4-H Program Offices must be tracking changes to their 4-H subsidiaries’ records.

National 4-H Headquarters will process with the IRS changes based on errors in EIN
records the states provided to us, and we provided to the IRS in March, when the EINs
do not belong to the entity listed, but instead belong to a land grant institution, county
government, or other government entity and for which the data we provided the IRS is
creating tax-related problems for the other entity.

Please remember:
       Independent organizations with their own tax status [such as a 501(c)3)] are not
        eligible for inclusion under GEN 2704.
       State and county level 4-H offices that operate through a Land Grant Institution
        typically fall under the university’s tax status and are not eligible for inclusion
        under GEN 2704.
National 4-H Headquarters continues to work with the IRS to resolve issues regarding
the group exemption status and to find appropriate means for managing tax exemption
lists of 4-H subsidiaries. Everyone’s patience and cooperation during this time are
greatly appreciated. We look forward to sharing next steps as soon as they are clear.

Special notice from Charles Cox to clarify above information.

The IRS sent a random sample of postcards some time ago. Some clubs may have done the on-
line filing then and some may have ignored it and many did not get a card at all. It is now time
for EV ERY CLUB with an EIN number on the list you have provided to the State 4-H Offi ce
to ATTEMPT to attempt to complete a report. No one should wait for a postcard. The IRS is
expecting organizations to file on time without notice from them. Remember that the IRS is still
updating their list from Headquarters so it may be a club may try to complete an online report and
not be in the IRS system yet.

990-N links are posted on The site takes the person entering their data to an IRS
contracted site to complete the 990-N.

Here is some information additional information about the 990 -N:,,id=169250,00.html.

Remember that clubs that fail to do the report on time can be denied the right to use the name
and emblem and will not be recognized under the federal group exemption number. When a
leader completes the report, print any confirmation, or denial screens or any other documentation
to verify that every effort has been made to file a report and keep in on file in the county office
along with the clubs annual financial reports.

    Other related previous documents mentioned in the
                     directive above….

                         TAX EXEMPTION LETTERS:
From 10/7/08 email to state leader and tax exempt listserv members:

National 4-H Headquarters, USDA will generate “emergency letters” upon request to
chartered 4-H clubs and duly authorized affiliated 4-H organizations under the control of
cooperative extension up through June 1, 2009. “Emergency letters” are for clubs that
cannot accept funds or grants without some evidence of tax exempt status to share with a
funder. To request such a letter, we need an electronic “paper trail” as follows:

       The State 4-H Program Leader (not a designee) submits the request to us at 4- with an EXCEL attachment containing the usual
        information, with at least required fields A-K as you’ve been doing all along.
      In the body of the request, indicate (1) the organization listed is duly authorized to
       use the 4-H Name & Emblem, (2) is under the control of Cooperative Extension,
       and (3) whether the record was submitted previously to National 4-H
       Headquarters or is totally new to us.

Be advised that county 4-H [offices] are part of the land grant university, and usually
operate under the tax status of the university and are not eligible for inclusion under the
existing GEN 2704. Allow approximately 2 weeks for National 4-H Headquarters to
respond to emergency letter requests. Letters are [mailed to the 4-H subsidiary and e-
mailed to the State 4-H Program Leader and the Extension Director.]

           Update on 4-H Tax Exempt Status & the IRS
Sent: Wednesday, July 23, 2008 12:17 PM
To: 4-H State Leaders
Subject: [4hstateldr] Update on 4-H Tax Exempt Status and the IRS
Importance: High

Action Needed
    1. Please communicate to your chartered 4-H clubs and qualified affiliate groups earning
       less than $25,000 that there will be no penalties for those who do not file an ePostcard
       in 2008. [Those earning more than $25,000 will continue to be subject to the 990
       requirements for filing]. We anticipate having more details from the IRS to be shared
       through State 4-H Program Leaders when the IRS has completed processing the database.

   2. Please communicate to your chartered 4-H clubs and qualified affiliated groups that as
      subsidiaries under GEN 2704 they should be contacting your State 4-H Program
      Office for all tax exempt issues and not National 4-H Headquarters or the IRS. The IRS
      has requested that any information and direction be provided from them to National 4-H
      Headquarters as the parent organization. National 4-H Headquarters then has the
      responsibility to provide updates, assistance, and respond to questions from State 4-H
      Program offices. Having qualified subsidiaries come through your State 4-H Program
      offices ensure that at the federal level, we are dealing with duly authorized 4-H groups,
      and that these groups are under the control and guidance of your Cooperative Extension
      program- as well as ensuring that they are receiving consistent responses. For all issues
      about status under GEN 2704, whether the group is requesting an EIN (SS-4 form) or
      inclusion under GEN 2704, or questions related to filing requirements, determination
      letters, or general status questions, all state and local groups should start with the State 4-
      H Program Office. Again, National 4-H Headquarters will provide instructions and
       technical assistance to the State 4-H Program Offices to assist in responding to
       state and local questions and issues.

   3. Please also be advised that the previous guidance provided for 4-H tax exempt status, the
      1993 4-H Tax Exempt Guidance booklet (or previous versions) and the previously used
      “Kirby” letter dated from 1973 which served as a determination letter in the past, are no
      longer in effe ct and should be removed from state and county websites and/or
      discarded from your files.
IRS Encountering Delays in Processing Lists:
Last year, we began the process of clarifying the 4-H entities that were authorized for inclusion
under the national 4-H tax exempt status (GEN 2704). We began this as a response to questions
from the IRS regarding authorized 4-H subsidiaries under the exemption of the national 4-H
organization, and our system’s ability to communicate and enforce new filing requirements which
would impact subsidiary groups. In March 2008, National 4-H Headquarters forwarded to the
IRS the listings we had received at that time, of all authorized 4-H entities from your programs
and we have been waiting for the IRS to finish updating the list. As we have previously reported,
the IRS has encountered delays in completing the processing of our lists for several reasons
including: 1) there are far more entities requesting inclusion as subsidiaries than the IRS
anticipated; 2) there continue to be significant errors with Employee Identification Numbers
(EIN) listed for thousands of the 4-H entities certified; 3) the IRS is questioning the inclusion of
some affiliated organizations which typically are considered independent organizations rather
than program groups; and 4) there are questions on both the part of the IRS and National 4-H
Headquarters regarding which requirements apply to 4-H, given that 4-H is a unique entity unlike
any other organization.

Clarification of 4-H Tax Exempt Status:
The IRS is working to both clarify the actual tax exempt status for 4-H, and to identify ways
to coordinate the lists of 4-H entities more efficiently and effectively in the future. In the
meantime, we anticipate further delays with the existing data set. Since our current ruling dates
back to the 1970’s and was based on a 1946 ruling that referenced the Internal Revenue Code of
1939, much of which is no longer in current law, regulations, or records, National 4-H
Headquarters has requested a new ruling from the IRS. Our unique status has caused much
confusion in our system- as volunteers and others mistakenly assume that either 4-H is a 501(c)3
organization or it’s just a governmental entity- neither which is true from an IRS perspective.
Local 4-H representatives have interpreted the tax code for either of these entities as being
applicable to 4-H in their local situation which has meant some 4-H subsidiaries are not
compliant with IRS expectations for our group. We anticipate that the Cooperative Extension
System will continue to be subject to requirements to certify the lists of subsidiaries, and
that all subsidiaries will be required to electronically file, however, 4-H entities may not be
subject to other requirements of 501(c)3 entities.

Due to the delays in processing the 4-H listings for groups requesting inclusion, and the data
cleaning that will need to take place in partnership will all of you to correct the EIN’s, National
4-H Headquarters has negotiated with the IRS that there will be no penalties for 4-H
subsidiaries earning less than $25,000 who do not electronically file for the remainder of

We greatly appreciate everything that you, your colleagues, and volunteers have done as we
transition to meet the IRS’ requirements and increased accountability at the national and state
levels for those authorized groups under Cooperative Extension raising money in the name of 4-
H. We appreciate that clear guidance is critical in managing your 4-H Youth Development
Program, and we will provide additional information as soon as we can. Thank you.

Cathann A. Kress
Director, Youth Development
National 4-H Headquarters
Certification of Tax Exempt Groups – OKLAHOMA
 From: Ar nold, Maria on behalf of Kress, Cathann
Sent: Fri 10/5/2007 7:00 AM
To: Charles Cox; Dorothy Wilson
Cc: 4H Tax Info

Greetings. Earlier this summer, we notified State 4-H Program Offices that as part of the
new IRS reporting requirements, as a “parent” tax-exempt organization, National 4-H
Headquarters will now be required to annually certify the list of subsidiaries registered to
use our Group Exemption Number (GEN).

In July, National 4-H Headquarters received the current listing from the IRS of all the
subsidiaries currently registered under our GEN. We have divided the listing by state and
are now forwarding the state lists to State 4-H Program Offices for your review and

Each list should be reviewed for accuracy (including additions, deletions, and changes).
   1) All groups listed should be groups formally authorized within your state [We
        define “formal” authorization as that they have a written document, such as a
        charter, establishing their authorization and recognition from your institution].
   2) You should identify any groups utilizing the 4-H Name and Emblem and raising
        funds in your state that are not included in your listing. All 4-H groups raising
        funds, or accepting funds, need to establish tax exempt status either through the
        National 4-H GEN or independently, or they will need to pay federal income tax
        on any income generated. Those authorized groups eligible for inclusion under
        the GEN but do not yet have their own Employer Identification Number (EIN)
        can obtain an EIN (see fact sheets at for
        instructions) and then appear as an “addition” on your state certification list. Any
        of these eligible and authorized groups that do not obtain an EIN before you
        complete your 2007 certification would not be considered tax exempt by the IRS.
        If this is an issue for groups in your state, please contact us National 4-H
        Headquarters directly.
   3) You should also note any group that appears on your listing, and that you have
        not authorized within your state. These could be regional or national level
        groups, or completely unknown entities. We have already identified a few of
        those and notified the IRS to delete them.

Any additions, corrections, or deletions should be noted, and returned to National 4-H
Headquarters by December 1. National 4-H Headquarters will then forward the
completed certification back to the IRS.
In reviewing the lists, we noted there is a wide variance in the number of groups by state.
Many states have a current listing of about 400-900 groups while a few states have less
than 20. We have become aware that there is some confusion among local groups and
many did not realize that they have to request inclusion under the National 4-H GEN to
be granted tax exempt status. Apparently, many assumed that simply being recognized
by your state office granted them such status. We’ve also had some indicate that since
they had a printed copy of the “Kirby” letter, they assumed that possession of that letter
granted them tax exempt status.

The Kirby letter was simply a letter from the early 1970’s that verified that the IRS
recognized our National 4-H GEN and that recognized subsidiaries did indeed qualify for
tax exempt status. You should review if this confusion exists in your state and encourage
groups that have not requested inclusion, to do so. Our Fact Sheet, “Tax Exempt Status
for 4-H Clubs and Affiliated 4-H Organizations” (
details how new groups can obtain inclusion under the National 4-H Group Exemption.
If an existing group is authorized but is not listed on your state listing, and does not have
independent tax exempt status from another entity such as your university, a school, or an
independent organization, then you should assume that they do not have federal income
tax exempt status. Eligible groups that have or obtain an EIN before December may
simply be listed as an addition on your state certification list.

Due to the fact that the IRS files groups under states, we have no way of knowing which
land grant university a particular group may be affiliated with; therefore, we ask that if
there is more than one institution in your state, that those responsible for the 4-H program
at each institution coordinate to ensure a complete and comprehensive state listing to
report back to the IRS.

Attached to this message, you will find your state listing and instructions for completing
the certification. For this year, we are sending EXCEL files to be amended and returned
to us. For future years, we are currently building a web-based system that will allow you
to make additions, corrections, and deletions as they occur. As a result, while this year
there may be a lot of work to ensure a correct listing, in the future it should be a much
easier process.

The attachments you should have with this message include:
   1) Instructions for Certifying 4-H Clubs and Affiliated 4-H Organizations under the
        National 4-H Federal Income Tax Exempt Status; and
   2) An EXCEL table showing 4-H Clubs and Affiliated 4-H Organizations in your
        state that have been granted tax exempt status by the IRS under the National 4-H
        GEN (Group Exemption Number) as of July 2007.

As noted on the instructions, a single updated EXCEL table from each state—
coordinated among institutions within a state—and a certification letter from the
appropriate Extension Directors and/or Administrators involved, is due to National
4-H Headquarte rs by December 1, 2007.
If you have questions, we invite you to review the Fact Sheets posted at
http://www.national4-, or email us at
or call 202-720-2908. We also invite you to register and participate in two webinars
being hosted by National 4-H Headquarters to address certification questions. These
webinars will be held on 11/14 at 3:00 p.m. EST and repeated on 11/19 at 3:00 p.m.
EST. To register, send an email with your name and contact information to the email
address noted above.

Cathann A. Kress
Director, Youth Development
National 4-H Headquarters

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