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New §501(c)(4) exempt organizations and their advisors need to be mindful of a requirement added to the Code under the PATH Act, enacted December 18, 2015. Under newly-enacted IRC §506 such organizations must electronically submit Form 8976 - Notice of Intent to Operate Under Section 501(c)(4) - within 60 days of formation. This form does not exist on paper and thus will not be found by searching at the IRS website. An individual desiring to electronically submit this form needs to establish an account at the IRS website and pay a user fee of $50 through Late filing can be penalized. (Rev. Proc. 2016-41).

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