STIMULUS CHECKS FOR NON-FILERS OF RELIGIOUS INSTITUTES AND NEWLY- ANNOUNCED IRS TOOL

APRIL 12, 2020: Members of RCRI may recall receiving on April 2, 2020 RCRI’s document containing highlights of the Phase 3 legislation, known as the CARES Act, which included information regarding stimulus checks as provided by Section 2201 of the CARES Act (officially named “Economic Impact Payments”).

In this documentation, RCRI stated that if a member of a religious institute

• did not file a federal income tax return Form 1040 for either 2018 or 2019;
• normally does not file a Form 1040; and,
• does not receive Social Security benefits

that member will probably not receive a stimulus payment.

At the same time, RCRI expressed its wariness that such a member (presumably a younger member, as younger members usually do not receive Social Security benefits) file a 2019 federal income tax zero-return in order to obtain a $1,200 stimulus payment. To do so may result in the IRS looking for Form 1040 in future years from the member.

Of course, this wariness does not apply to a member who has filed a federal income tax return Form 1040 for the years 2018 or 2019 or received Social Security benefits resulting in a statement of benefits (Form SSA-1099) being issued. Such a member should receive their stimulus payment automatically, either through direct deposit or by means of a check sent by US Mail.

However, on Good Friday, April 10, 2020, the US Treasury and the Internal Revenue Service launched a new web tool for those who do not normally file a tax return to receive an Economic Impact Payment. This new web tool is found at:

https://www.irs.gov/coronavirus/non-filers-enter-payment-info-here

This non-filer tool is designed for individuals, such as members of religious institutes, who did not file a tax return for 2018 or 2019 and who do not receive Social Security retirement or disability benefits. In addition, those who should utilize this non-filer tool include those who have not filed a 2018 or 2019 return because they are under the normal income limits for filing a tax return, specifically, members of religious institutes whose gross income for 2019 was less than $12,200 (for those under age 65) or $13,850 (or those 65 or older).

Per the IRS, beginning the week of April 12, 2020, members of religious institutes who filed tax returns for either 2018 or 2019 and chose direct deposit of their refund will automatically receive an Economic Impact Payment of $1,200. Members who receive Social Security retirement or disability benefits but did not file a return for 2019 or 2018 will automatically receive a payment in the near future.

This web-tool seems to have greater advantages for so-affected members of religious institutes who otherwise would have to file a zero-return federal income tax return in order to receive an Economic Impact Payment, though consideration should be given to the Practice Points found below.

For more information on this web tool, including how to use the Non-Filers: Enter Payment Info tool, please consult IRS Newswire Issue Number IR-2020-69 released on April 10, 2020. Go to:

https://www.irs.gov/newsroom/treasury-irs-launch-new-tool-to-help-non-filers-register-for-economic-impact-payments

SEE BELOW FOR “PRACTICE POINTS” AND ATTRIBUTIONS

Practice Points

In consultation with treasurers, RCRI would like to highlight these practice points and questions that have arisen which are unique to members of religious institutes if a community elects to utilize the aforementioned Non-Filers web tool:

What “current mailing address” should be used?

For members whom the community is paying FICA taxes on the value of the “perquisites provided,” some communities issue a W-2 form for each of them and use the province office as the member’s address on the W-2 form. For many, if not most, this is the only address currently attached to the member’s Social Security number in the IRS system. However, this address may be the residential address for a minority number of total community members, the remaining majority members live in local communities located in other cities and/or states.

In answer to this, some communities may wish to use  the province office address as the mailing address since this is the address that matches the annual IRS Form W-2 for deemed wages.

What about the driver’s license information?

With the exception of those who may live at the residential address where the province office is located, a member’s driver’s license may be issued by a state other than where the province office is located. Some members may not have obtained a new driver’s license when they transferred from one community to another community located in a different state. In other words, what of the situation where the address of a member’s current driver’s license may not have the address where they are now living?

In answer to this, a member could be assigned to another locale, and hold a driver’s license at that place, yet consider their “domicile” as the location of the province office.

Our members do not have bank accounts in their name (i.e., utilizing their Social Security number). What is the best option for them?

The best option would seem to not provide any banking information (that is, not provide the banking information for their local community’s account) and thus, the members will receive a paper check in the mail. For instance, if the address of the province office is used, all checks would go there. If a member uses the address of the local community (or the address that corresponds to the address found on a member’s driver’s license, should that be different), then the check would be sent to that address.

Some communities require their members to use the province office address as the permanent mailing address. As a result, all Social Security and Medicare correspondence is sent there. A member on Medicaid is in a different situation since the Medicaid program is tied to the state welfare office where the individual actually resides.

Who should actually enter the information on the IRS website?

In order to forestall any possible accusations of fraud, it would seem advisable to have each individual member utilize the website to enter their information and claim their Economic Impact Payment.  The individual must provide an email address and set up a User ID and Password.in order to create an account.  The treasurer may wish to guide each individual member through the process, by telephone if not in person, in order to ensure that the proper information is entered into the individual’s submission.

Attribution: IR-2020-69; Lawrence Lundin, SJ; John Steingraeber, CSsR