Dear Commissioner Rettig,
I am concerned with the Internal Revenue Service's (IRS) lax oversight of charitable
organizations. There is a glaring lack of transparency surrounding daily operations, grant
reporting, investment disclosures, fiscal sponsorship, and financial conduct of an organization's
highly compensated individuals. Proper oversight of these organizations is a tremendous benefit
to the American people, and I hope you will consider improving oversight and ensuring
compliance.
While there have always been bipartisan calls to improve the oversight of tax-exempt
organizations, a series of high-profile groups have demonstrated the desperate need for reform.
For instance, a bipartisan Senate investigation revealed several tax-exempt advocacy
organizations were working on medical issues while maintaining influential relationships with
pharmaceutical manufacturers. While these groups were working under the guise of charitable
advocacy, they were accepting donations from companies that intentionally downplay the risks
of opioid addiction, contradicting each organization's purpose and mission. Additionally, the
Black Lives Matter Global Network Foundation's (BLMGNF) refusal to answer basic questions
about its finances and leadership raises serious questions about its mission and legitimacy.
Finally, within the environmental sector, environmental think tanks with political agendas often
receive unchecked foreign funding to support their research and programming. Organizations
like the Sea Change Foundation intentionally manipulate Americans' opinions about pipelines, fossil fuels, and fracking while lobbying Congress for legislative action on targeted issues. Not
only are environmental non-profits slowly infiltrating environmental policy, but foreign actors
are using their platforms to promote climate change ideologies that undermine our national
security.
For an immediate fix to this ongoing issue, the IRS should conduct greater oversight to ensure
compliance with Form 990 for tax-exempt organizations, nonexempt charitable trusts, section
527 political organizations, and 990-PF, Return of Private Foundation or Section 4947(a)(1)
Nonexempt Charitable Trust Treated as a Private Foundation to certify foundations are filing
complete and honest returns. It has been revealed that several of the largest foundations in the
United States fail to report their investments properly. These groups publicly discuss their grants
and donations but refuse to disclose any stocks and bonds they own. Together they own tens of
billions of dollars of assets, but the public contributing to a charitable organization's service are
denied transparent financial investment reports. Any information indicating an organization is
investing directly into or intentionally receiving donations from adversarial foreign nations, or
their state-owned entities should be publicly disclosed. Increased clarity on grant reporting will
allow the public to properly examine if an organization's grants align with its goals and mission.
While penalties exist for not filing or filing an incomplete Form 990, the IRS rarely imposes
penalties. The IRS's failure to ensure compliance has created an environment where tax-exempt
organizations continuously fail to disclose relevant information and raise concerns about the
illicit financial activity. Additional reporting requirements for foreign grant recipients would help
deter and detect illicit financial activity in the tax-exempt sector of non-profit organizations.
It is critical that we maintain the public's trust in tax-exempt organizations and prohibit activities
that are not part of their charitable mission. I hope if you are not already taking a serious look at
the transparency issues surrounding tax-exempt organizations, you will begin immediately by
taking the following steps.
* Revising instructions for Part II, Balance Sheets, to encourage investments to be itemized
to the extent practicable on the required schedules and noting that lump-sum reporting is
unacceptable.
* Revising Form 990 Part II of the applicable Schedule F to include foreign grant
recipients' names and other relevant information.
* Revising Form 990's Schedule I and Form 990-PF's Part XIV to improve transparency
regarding grants made to fiscal sponsorship projects.
I appreciate your attention to this critical matter, and I look forward to your prompt reply