Among the most significant happenings in 2007 was implementation of the Pension Protection Act of 2006 (the “PPA”). The PPA triggered several changes to Form 990, Return of Organization Exempt from Income Tax, and added a new requirement that small exempt organizations file an annual notice with the IRS.

The IRS also issued several documents offering guidance regarding some of the more technical provisions of the PPA:

  • Announcement 2006-93 discusses how an organization currently classified under Section 509(a)(3) of the Internal Revenue Code of 1986, as amended (the “Code”), may go about changing its public charity status to Code section 509(a)(1) or (2).
  • Notice 2006-109 addresses the PPA requirements impacting supporting organizations, donor-advised funds, and private foundations that make grants to supporting organizations.
  • Notice 2007-45 explains the new requirement that 501(c)(3) organizations make their unrelated business income tax returns (Forms 990-T) available for public inspection. 

The published guidance on these topics can be found on the IRS Web Site at