NASCO Letter to the IRS With Exhibit 11/27/2023
NASCO Board Letter to the FTC 8/14/2023
NASCO Drafts Letter to IRS regarding 501(c)(3) status for an LLC
On February 4, 2022, the NASCO Board submitted comments to the IRS in response to the Notice 2021-56 invitation to comment on standards that an LLC must meet to obtain 501(c)(3) status. Through these comments, the NASCO Board supported the standards that the IRS and Treasury Department currently apply and requested that the IRS and Treasury Department consider the importance of state charity oversight and the variation of state law applicable to oversight of LLCs and formation of charitable LLCs. The Board also recommended that tax-exempt standards for charitable LLCs require similar notifications to state charity officials as those under state nonprofit corporation law. And finally, the Board offered to help connect the IRS and Treasury Department with any individual state charity official office for any state-specific questions.
Please find a link to the letter here.
NASCO Drafts Letter to FTC Regarding Impersonation Scams
On March 22, 2022 the NASCO Board responded to the FTC’s Advance Notice of Proposed Rulemaking (“ANPR”) by submitting the NASCO letter . The FTC has stated that their ANPR is to combat government and business impersonation fraud and is intended to allow the FTC to seek strong relief for consumers in cases involving imposter scams. The NASCO letter specifically requests that the FTC consider impersonation of charitable organizations and causes in its rulemaking.
https://www.nasconet.org/wp-content/uploads/2022/02/NASCO-Letter-to-FTC-2022-02-22-002.pdf
NASCO Recommendations for 2021-2022 Priority Guidance Plan Notice 2021-28
May 28, 2021 – NASCO’s response to the IRS request for submissions regarding the IRS Priority Guidance Plan. NASCO provided the following suggestions: 1) Revisit the Use of the Abbreviated Form 1023EZ; 2) Reinstate Schedule B Filing Requirements; and 3) Enhance IRS Information Sharing with State Charities Regulators. Read the full text of the letter here.
NASCO Letter to FASB Exposure Draft for Topic 958
April 10, 2020 – NASCO President Yael Fuchs writes to FASB Exposure Draft for Topic 958 regarding Presentation and Disclosures by Not-for-Profit Entities for Contributed Nonfinancial Assets. Read the full text of the letter here.
NASCO Letter to ICANN on the Proposed Sale of the .org Registry to a Private Equity Firm
January 17, 2020 – NASCO President Yael Fuchs writes to the board of directors of ICANN expressing concern regarding the proposed sale of the .org registry to Ethos Capital, a private equity firm. Read the full text of the letter here.
Comments on the Proposed Regulation Eliminating a Schedule B Requirement for Tax-Exempt Organizations to Submit the Names and Addresses of Substantial Contributors
December 5, 2019 – NASCO President Michael T. Foerster writes to the IRS and Treasury Department in support of continued requirement for Form 990 Schedule B for 501(c)(4) organizations. Read the full text of the submission IRS REG 102508 16 NASCO.
NASCO Letter to Congressional Leaders regarding the Johnson Amendment
April 17, 2019. NASCO President Michael T. Foerster writes to Congressional Leaders expressing NASCO’s concern about efforts to repeal or weaken the so-called “Johnson Amendment” which prohibits 501(c)(3) tax-exempt organizations from endorsing, opposing, or contributing to the campaigns of candidates for public office. Read the full text of the letter here.
NASCO Letter to the Financial Accounting Standards Board regarding Gift-In-Kind Pharmaceutical Donations
July 23, 2018. NASCO President Karen Gano writes to the Financial Accounting Standards Board to express concerns about potential changes to the gift-in-kind accounting rules. Read the full text of the letter here.
Letters in Support of the Taxpayer First Act
April 6, 2018. NASCO and the National Council of Nonprofits submit comments on the Discussion Draft of the bipartisan Taxpayer First Act.
National Council of Nonprofits letter can be found here.
Letter from NASCO President Karen Gano can be found here.
Letter from NASCO Past President Hugh R. Jones can be found here.
Op-Ed: Congress, Defend the Common Law and Common Sense of Nonpartisanship
September 7, 2017. Karen Gano, NASCO President, and Tim Delaney, President and CEO of the National Council of Nonprofits, publish an article opposing the Johnson Amendment. Read the full text of the article here.
NASCO Letter to Congressional Leaders regarding the Johnson Amendment
August 23, 2017. NASCO President Karen Gano writes to Congressional Leaders expressing NASCO’s concern about efforts to repeal or weaken the so-called “Johnson Amendment” which prohibits 501(c)(3) tax-exempt organizations from endorsing, opposing, or contributing to the campaigns of candidates for public office. Read the full text of the letter here.
NASCO Letter to Senator Orrin Hatch on Senate Bill No. 1343, The Charities Helping Americans Regularly Throughout the Year Act of 2017
July 17, 2017. NASCO President Karen Gano writes to the Chairman of the Senate Finance Committee to urge passage of the Charities Helping Americans Regularly Throughout the Year Act of 2017. Read the full text of the letter here.
NASCO Letter to the Members of the Senate Finance Working Group on Business Income Tax
April 9, 2015. NASCO President Janet M. Kleinfleter writes to the members of the Senate Finance Working Group to express NASCO’s strong support for tax reform that would require all tax-exempt nonprofits to file their IRS Form 990s electronically, and require the IRS to release 990 data in a machine-readable format. Read the full text of the letter here.
NASCO Letter to Congressman David Camp on Tax Reform Discussion
June 9, 2014. NASCO President Alissa Hecht Gardenswartz writes to the Chairman of the House Committee on Ways and Means to express NASCO’s strong support for the provisions requiring all nonprofits to file their IRS Form 990s electronically and requiring the IRS to release 990 data in a machine-readable format. Read the full text of the letter here.
NASCO Letter on Concerns About IRS Implementation of the 1023-EZ
NASCO Submits Comment on Proposed Form 1023-EZ
May 1, 2014. NASCO submits 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. See NASCO’s comments to Treasury and suggestion for embracing electronic filing as a more effective alternative to achieving accountability, transparency, and efficiency here.
NASCO Letter to Senator Max Baucus on Chairman’s Staff Tax Administration Discussion
January 15, 2014. NASCO President Alissa Hecht Gardenswartz writes to the Chairman of the Senate Finance Committee to express NASCO’s support for the proposal that all nonprofits be required to file their IRS form 990s electronically, and that the IRS be required to release 990 data in a machine-readable format. Read the full text of the letter here.
Internet and Social Media Solicitations: Wise Giving Tips
Federal/State Information Sharing Letter
October 28, 2011. Attorneys General of the various States and the National Association of Attorneys General sent a letter to Chairman Baucus and Ranking Member Orrin Hatch of the United States Senate’s Committee on Finance regarding the sharing of certain information between the Internal Revenue Service and State Charity Regulators (Attorneys General). This document is available for download here.