The Putting Trust in Transparency Act would amend the Internal Revenue Code to require public disclosure of donors to 501(c) organizations that receive federal funding. Specifically, it would mandate that the IRS publish Schedule B information from Form 990, including donor names, zip codes, and total contributions, within 60 days of processing the form, for organizations described in section 501 that receive federal funding during the taxable year.
It also expands the IRS’s enforcement tools, revoking tax-exempt status for those that fail to file Schedule B. The bill frames transparency as a means to empower oversight and ensure taxpayer dollars are used with appropriate accountability.
It is important for compliance professionals because it creates a new public-facing data obligation and a new trigger for loss of exempt status, with a clear timeline and publication requirement.
At a Glance
What It Does
The bill requires public disclosure of Form 990 Schedule B for eligible 501(c) organizations that receive federal funding, by adding an explicit public-access provision and publishing donor-level details within 60 days of processing. It also makes these disclosures non-redacted except as otherwise provided.
Who It Affects
501(c) organizations receiving federal funding, the IRS, and oversight bodies that monitor nonprofit funding and tax-exemption compliance.
Why It Matters
This sets a new transparency standard for nonprofit funding, enabling taxpayers and policymakers to trace donor influence and use of federal dollars; it also changes incentives around fundraising and reporting for nonprofits.
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What This Bill Actually Does
The act targets nonprofits that receive federal money and requires that their Form 990 Schedule B disclosures be made public. By adding a new subsection to the tax code, the bill ensures that donor names, partial addresses (zip codes), and total contributions attached to those Schedule Bs are accessible to the public within 60 days after the IRS processes the form.
An enforcement mechanism ties non-compliance to the revocation of tax-exempt status, with formal notice procedures and a published list of revoked organizations. The amendments are intended to increase government oversight of how federal funds are used and to disclose who is funding organizations that receive federal support, appealing to lawmakers and watchdogs who seek greater accountability.
The measure would apply to taxable years beginning after enactment. In practical terms, nonprofits must adapt to this disclosure regime, and donors may face new privacy considerations as their contributions become public data.
Overall, the bill reframes donor transparency as a prerequisite for exempt status when federal funding is involved and elevates oversight of nonprofit funding streams.
The Five Things You Need to Know
The bill requires public disclosure of donor names, zip codes, and total contributions for 501(c) organizations that receive federal funding, via Schedule B of Form 990.
Nonprofits failing to file Schedule B face potential revocation of their tax-exempt status after notice and a 60-day cure period.
The amendments apply specifically to organizations described in Section 501 that receive federal funding during the taxable year.
Retroactive reinstatement of tax-exempt status is allowed if the organization shows cause and meets filing requirements.
The changes apply to returns filed for taxable years beginning after enactment, setting a forward-looking compliance baseline.
Section-by-Section Breakdown
Every bill we cover gets an analysis of its key sections.
Short Title
This section establishes the act’s formal title as the Putting Trust in Transparency Act. It sets the legal anchor for the bill and outlines the general purpose of introducing donor transparency for nonprofits receiving federal funds.
Findings and Sense of Congress
This section lays out statements about the rationale for oversight of NGOs and the sharing of taxpayer dollars. It frames transparency as a tool for responsible stewardship and emphasizes the need for accountability in nonprofit funding, while asserting Congress’s prerogatives to oversee the use of public resources.
Annual Disclosure of Contributors to Exempt Organizations
This core section amends the Internal Revenue Code to require public disclosure of donor information for eligible organizations. It adds a new clause to 6104 specifying that Schedule B data must be publicly available for organizations receiving federal funding, within 60 days of processing. It also expands enforcement by adding a new provision to 6033(j) that permits revocation of tax-exempt status for failure to file Schedule B, with a notice-and-cure process and a requirement to publish a list of revoked organizations. The effective date clarifies that these amendments apply to returns for taxable years beginning after enactment.
Reinstatement and Notice Provisions
This section (tied to the reinstatement mechanism) details the process for reinstatement of tax-exempt status after revocation, including the possibility of retroactive reinstatement if the organization demonstrates cause and meets the new filing obligations. It creates a pathway for corrective action, ensuring that organizations have a means to regain exempt status under defined conditions.
Effective Date
This section designates the effective date for the amendments, specifying that the changes apply to returns filed for taxable years beginning after the enactment date. It sets the timing for implementation and publication obligations, framing the rule set’s forward-looking applicability.
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Explore Finance in Codify Search →Who Benefits and Who Bears the Cost
Every bill creates winners and losers. Here's who stands to gain and who bears the cost.
Who Benefits
- Taxpayers and the general public gain visibility into donor networks and how federal funds flow to NGOs, enabling oversight and accountability.
- Congressional oversight committees and the IRS gain access to donor data that supports audits and funding decisions.
- Investigative journalists, think tanks, and civil-society watchdogs can analyze funding networks to assess influence and transparency.
- Policy researchers and compliance professionals benefit from clearer reporting requirements and a defined transparency framework.
Who Bears the Cost
- Nonprofit organizations receiving federal funding incur new compliance costs to file Schedule B and prepare donor disclosures.
- Donors to these organizations face increased privacy exposure as donor information becomes public, potentially affecting privacy and fundraising dynamics.
- The IRS and Treasury will incur administrative costs to process, publish, and maintain the new public data and enforcement mechanisms.
Key Issues
The Core Tension
The central dilemma is balancing donor privacy and nonprofit fundraising flexibility with the need for government oversight of public funds. Public disclosure improves accountability but risks chilling effects and donor retreat, which could reduce charitable activity and impact the programs NGOs support.
The bill sharply increases transparency of nonprofit fundraising by requiring public disclosure of donor information for federally funded NGOs. While this strengthens accountability and enables oversight, it raises privacy concerns for donors who may be exposed to public scrutiny.
The administrative burden on nonprofits—particularly smaller entities with limited resources—could be significant, and the public availability of donor data may influence donor behavior in ways that affect funding dynamics. The provision to revoke exempt status for noncompliance creates a strong enforcement signal, but also raises questions about due process and the sustainability of funding for organizations that depend on donor contributions.
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