Yesterday NASCO submitted comments to the US Department of Treasury recommending against the proposed Form 1023-EZ, citing the 2012 ACT Report and endorsing ACT’s reasons for recommending against development of an abbreviated application for tax-exempt status.
“While we appreciate that the IRS will be committing more resources to back-end compliance examinations to address the potential for malfeasance, our concern is that the current 17% of all applicants for which the Form 1023-EZ would apply could grow exponentially if the process for obtaining tax-exempt status was significantly simplified. Both IRS and state charities regulator enforcement capabilities are already stretched thin. While use of the Form 1023-EZ may result in somewhat of a short-term reduced burden in processing applications, the long-term effect certainly will be a greatly increased burden on already overburdened state and federal regulators,” stated NASCO President Alissa Hecht Gardenswartz. “We submit that there are alternate and more effective ways to foster ‘accountability, transparency, and openness in Government and society’ consistent with the spirit of the Paperwork Reduction Act.”
See NASCO’s comments to Treasury and suggestion for embracing electronic filing as a more effective alternative to achieving accountability, transparency, and efficiency here.