Notice 2016-09 extends the date by which social welfare organizations must notify the Internal Revenue Service of intent to operate under section 501(c)(4), as required by new section 506, added to the Internal Revenue Code by the Protecting Americans from Tax Hikes Act of 2015. With respect to the separate process by which an organization may, at its option, request a determination that it qualifies for section 501(c)(4) tax-exempt status, the Notice states that organizations seeking IRS recognition of section 501(c)(4) status should continue using Form 1024, “Application for Recognition of Exemption Under Section 501(a),” until further guidance is issued and clarifies that the filing of Form 1024 will not relieve an organization of the requirement to submit the section 506 notification.
Notice 2016-09 will be in IRB 2016-06, dated February 8, 2016.