Updated Filing Requirements for Form RRF-1

Effective July 1, 2021, the filing requirements for the California Attorney General Registry of Charitable Trusts Form RRF-1 have been updated for annual registration renewals.  In accordance with the July 1, 2021 U.S. Supreme Court decision in Americans for Prosperity Foundation v. Bonta, the California Attorney General has revised its instructions regarding the IRS Form 990/990-EZ/990-PF that is to be submitted with Form RRF-1.  Effective July 1, 2021, the entire Schedule B (including the first page of Schedule B) is to be omitted from the Form 990/990-EZ/990-PF that is required to be submitted with Form RRF-1.  For further information, please see https://oag.ca.gov/charities/renewals.

As the Form RRF-1 must be executed by an officer or an authorized agent and submitted by mail or directly online (along with the required filing fee and the IRS Form 990/990-EZ/990-PF), you may wish to advise your clients to remove Schedule B from the IRS Form 990/990-EZ/990-PF prior to mailing/uploading with their RRF-1 filing.  Please note that the instructions to the Form RRF-1 have not been revised to reflect the exclusion of Schedule B from the as-filed IRS Form 990/990-EZ/990-PF.  Your advice will be especially timely for those California public benefit corporations that have a fiscal year that ended June 30, 2021 and an upcoming IRS filing deadline of November 15, 2021.

This e-bulletin was written by Lynne M.O. Brickner.

For more information about the Nonprofit Organizations Committee and its programs, please contact Committee Chair Louis E. Michelson (louis@lemtax.com).

Know someone who would like to receive our E-bulletins?  Anyone interested may sign up on the website of the California Lawyers Association.   

Become an official member of the Nonprofit Organizations Committee!  The CLA Business Law Section is accepting applications online here..  Applicants must be Business Law Section members who have been admitted to the California Bar for at least five years. 

Upcoming meeting dates: 

• Jan 20, 2022 10 am, The Unique Aspects of Tax Law Affecting Religious Organizations, Myron Steeves
• Feb 17, 2022 10 am
• Mar 17, 2022 10 am, How to Maintain Your Client Trust Account to Efficiently Run Your Practice AND Avoid Bar Discipline (Ethics Credit)
• Apr 21, 2022 10 am
• May 19, 2022 10 am
• Jun 16, 2022 10 am
• Jul 21, 2022 10 am, Welfare Exemption, Sy Nguyen, Los Angeles County Office of the Assessor