IRS has asked for comments on its proposal (REG 143787- 06) to redesign Form 990, which has not been updated since 1979. Various organizations are contributing their comments. Among them are the following:

  • The American Institute of Certified Public Accountants stated that it is “troubled by the limited information on tax-exempt purpose, by the use of performance metrics that do not have significant industry-wide acceptance, and the level of emphasis on compensation.”
  • The Catholic Health Association of the United States focused on Schedule H and the need to clarify the definition of which entities should file Schedule H. It also discussed adding community benefit questions beyond those which are purely quantitative in nature, including “community building” activities as a category of community benefit, and continuing to exclude Medicare losses and bad debt as community benefit categories.
  • The Credit Union National Association argues that credit unions, because they are substantially different from other tax-exempt entities such as charities, should not have to file Form 990. CUNA said that each state credit union is thoroughly regulated and regularly examined by its state supervisory agency and deposit insurer.
  • OMB Watch recommended that the IRS drop the requirement that exempt organizations report lobbying expenses for non-employees, as proposed in the new draft Form 990. According to OMB, “the IRS has not justified why it should impose new ways of allocating lobbying costs when it already collects detailed information through Schedule C.”