Final Treasury Regulations Reduce Donor Reporting Requirements for Some Tax-Exempt Organizations

Snell & Wilmer

Snell & WilmerThe Department of the Treasury has adopted Final Regulations, providing guidance on information to be reported on the annual return of tax-exempt organizations with respect to their “substantial contributors." For these purposes, a tax-exempt organization’s substantial contributor is any donor who, in a taxable year, contributes to the organization an aggregate of $5,000 or more (in cash or property).

Tax-exempt organizations (other than those described in Code § 501(c)(3) or Code § 527) are no longer required to report, on their annual return, the names and addresses of their substantial contributors. However, such tax-exempt organizations must continue to: (i) report, on their annual return, the amount of contributions from their substantial contributors; and (ii) maintain, in their books and records, the names and addresses of their substantial contributors – information which may have to be provided to the IRS upon request.

Tax-exempt organizations described under Code § 501(c)(3) or Code § 527 must continue to report, on their annual returns, the names and addresses of their substantial contributors.


  1. Treas. Reg. § 1.6033-2(a)(2) (the “Final Regulations”), effective as of May 28, 2020, which generally adopted the 2019 proposed regulations.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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