Can anyone tell me if there is IRS rule requiring Officer's SSN on 990 (Part IV - Taxpayer Signature).

[TaxGuyBill]

Last year the IRS e-file system changed it so it seems like you must enter SOMETHING there to e-file.

AIPCA wrote to the IRS to ask them to remove that from the e-file system.

As far as I can tell, there is NO requirement, but perhaps the IRS "recommends" it.

If your client doesn't want to have his SSN entered, personally, I would enter some other numbers.  But that could delay the processing for the return, and could possibly trigger the IRS to otherwise look at the return for other purposes.

https://us.aicpa.org/content/dam/aicpa/advocacy/tax/downloadabledocuments/56175896-aicpa-comments-on...

[PATAX]

I would explain to the client that our tax software is very secure, and the only other entity that would see this is the IRS. I would ask them for the number, and if they don't provide it, then maybe tell them you may consider withdrawing from preparing that 990 return. I think most reasonable people would provide it after that. But of course this is just my opinion.

[BobKamman]

What’s interesting is that the Form 990 instructions don’t address this, but they reveal that PTIN’s are not confidential.

“Enter the paid preparer's PTIN, not his or her social security number (SSN), in the “PTIN” box in the paid preparer's block. The IRS won't redact the paid preparer's SSN if such SSN is entered on the paid preparer's block. Because Form 990 is a publicly disclosable document, any information entered in this block will be publicly disclosed”

[qbteachmt]

"and the only other entity that would see this is the IRS"

And anyone checking on the entity, such as the public. I use Guidestar.

"Tax-exempt forms that must be made public by the IRS are clearly marked “Open to Public Inspection” in the top right corner of the first page. These include Form 990, Form 990-EZ, Form 990-PF and others."

From: https://www.irsvideos.gov/CharitiesAndNonProfits/SocialSecurityNumbers/SocialSecurityNumbers

And...

",,,remember, when an organizations applies for tax-exempt status, or files an annual 990 series return, the law requires that both the IRS and the exempt organization make those forms available to the public. And the law does not permit the IRS to remove social security numbers from those forms before making them available to the public.

Don't put social security numbers on any version of a Form 990. There is no reason for your organization to include them The IRS doesn't ask for it and we don't want them. Here are the forms that should not include social security numbers: Forms 990, 990EZ, 990N-and 990PF – the annual returns for charities and private Foundations Form 990T filed by charities Form 5227- filed by split interest trusts Forms 1023 and 1024 – applications to the IRS for tax-exempt status Forms 8871 and 8872 – filed by political organizations The forms and their instructions are available at www.irs.gov under the Forms and Pubs."

[PATAX]

@BobKamman @qbteachmt several years ago when I checked 990 returns that I filed on online website, I do believe my PTIN number was blocked out. If they block out the ptin number, then why wouldn't they block out a social security number for an officer? Maybe something has changed since then. How hard is it to block out that social security number, and who in their right mind is going to complain that it is blocked out when publicly viewing the return? Just wondering and just my opinion.

[qbteachmt]

This was a Tax Topic just emailed as part of the e-newsletters, so the IRS obviously realizes it is a concern. I get "TE/GE" which is tax exempt and governmental entities.

[IRonMaN]

This was discussed here a few months ago.  The IRS is treating it as optional but Intuit doesn’t really acknowledge that.  Ignore the box and disable the error checking when you transmit it.

[PATAX]

Thanks QB, I used to get those, as well as others from them, but they stopped. Maybe they got mad at Heidi?🐕☝😉

[BobKamman]

Are they programmed to block out just the SSN location on the signature block, or just a PTIN on the PTIN block?  

[taxiowa]

 I think this is much adoo about nothing.  The officer SS# does not get printed with any return copy.  It would not be available for public record unless you print the 990 information sheet with the copy provided for public.  I don't think anybody gives that sheet with any return copy.  That is the only place entered and is not available to public.

As far as transmitted, I think maybe the IRS does verify the signer and SS# to make sure they are legit.  But that is merely between you, the software and the IRS.  If we cannot trust the info with the IRS, then we are all in the wrong business.

[BobKamman]

There is a lot of residual antagonism about anything to do with  IRS nonprofit regulation, even when they don't involve any suspected political activity.  

Tax Court is supposed to expunge SSN's from public filings, also -- but I can show you examples of where they don't.  And now we have to worry about what information is really shown on those 3-D bar codes that our software, and IRS software, produce.  

[joshuabarksatlcs]

RE: Can anyone tell me if there is IRS rule requiring Officer's SSN on 990 (Part IV - Taxpayer Signature).

Wait a minute.  Form 990 Part IV is Checklist of Required Schedules.   Is the question about one of the thirty-something questions has to do with SSN?

The Signature block is Part II.  Part of the earlier discussion mentioned PTIN.  Is the question about PTIN in Part II?

Or is it about the entries for Officers (in Lacerte - Screen 2), where the bottom field is SSN.  In Lacerte, the instructions specify: SSN (Used for California reporting, others options.)

On a separate note, be aware that Form 990's are available on the CA Attorney General's Charitable Trust website.  Even if the IRS blocks certain info, you may want to check if AG website does the same.   Schedule B is NOT supposed to be open for public inspection.  In the past, I have seen Sch B on certain websites.

I'm confused.