On July 22, 2026, the House Ways and Means Committee voted to advance four bills that would impose new requirements for tax-exempt organizations in the following areas:
- Foreign Contributions: Two of the bills, HR 9771 and HR 9772, address foreign contributions to certain tax-exempt organizations. HR 9772 establishes disclosure requirements for contributions received from foreign nationals, including the aggregate amount of the contribution and the foreign country of the contributor. HR 9771 imposes a penalty on tax-exempt organizations that make a contribution to a political entity, which is defined to include a 501(c)(4) organization, if they received a contribution from a foreign national during the two-year period ending on the date of the contribution. The penalties can range from 100% to 200% of the contribution, plus loss of tax exemption for two years.
- Fiscal Sponsorships: HR 9721 establishes disclosure requirements for fiscal sponsorships, which are generally defined to include arrangements between a tax-exempt and non-tax-exempt organization, where the tax-exempt organization receives and administers funds on behalf of the non-tax-exempt organization and retains discretion and control over such funds to ensure that they are used to further the exempt purpose of the organization. The bill would impose a tiered set of taxes on the amount transferred between the tax-exempt and non-tax-exempt organization (ranging from 5% to 100%) where the tax-exempt organization fails to exercise discretion and control over the use of funds. What constitutes “discretion and control” would be defined in Internal Revenue Service regulations.
- Religious Purpose: HR 9722 would add a new provision to the Internal Revenue Code to clarify that a religious belief or practice concerning marriage, sexuality, or gender identity would not be treated as being inconsistent with law or public policy, even if it is not compelled by or central to a system of religion.
While it is unclear what the likelihood of passage of these bills will be, we will continue to monitor them, particularly since a number of them would impose significant penalties, restrictions, and burdens on tax-exempt organizations.