The IRS has released Rev. Proc. 2018-38 that announces that tax-exempt organizations, other than section 501(c)(3) organizations, will no longer be required to report the names and addresses of their substantial contributors as previously required on Schedule B.
Currently substantial donor information is required to be listed in Schedule B, Schedule of Contributors, as part of an exempt organization’s annual filing of Form 990, Form 990-EZ and Form 990-PF, or, with respect to organizations described in section 501(c)(21), in Part IV of Form 990-BL. Per section 1.6033-2(a)(2)(ii)(f), all types of tax exempt organizations are required to report the names and addresses of each person who contributed $5,000 or more to the organization during the tax year. In addition, section 1.6033-2(a)(2)(iii)(d) requires organizations described in section 501(c)(7), (8), or (10) to report the name and address of each person who contributes $1,000 or more during the tax year.
Rev Proc. 2018-38 provides relief for all tax-exempt organizations, other than 501(c)(3) organizations, from the requirement to provide the names and addresses of substantial donors to the organization. The revenue procedure does not relieve the organization of the need to complete the other information required to be reported in Schedule B, such as donor amounts. As a result, this revenue procedure will have no effect on the reporting of Schedule B information that is currently open to public inspection. Additionally, the organization is required to maintain adequate books and records listing the donor’s information even though it is not required to be reported to the IRS as part of the organization’s annual filing.
Rev. Proc. 2018-38 is effective for tax years ending on or after Dec. 31, 2018.