Treasury and IRS list Johnson Amendment and fiscal sponsorship reporting guidance among their priorities for the year
The 2026-2027 Priority Guidance Plan, released Sept. 29, has five projects for tax-exempt organizations, among them guidance on the ban on campaign intervention by 501(c)(3) groups and on reporting fiscal sponsorship arrangements. It sets no deadlines.
Washington. Guidance on the Johnson Amendment, the ban on campaign intervention by 501(c)(3) organizations, and on how exempt organizations report fiscal sponsorship arrangements is among the work the Treasury Department and the Internal Revenue Service say they will focus on in the year that began Oct. 1. The agencies released their 2026-2027 Priority Guidance Plan on Sept. 29.
The plan lists 121 projects, up from 105 in last year's. For the first time its year matches the federal fiscal year and runs through Sept. 30, 2027. It is a list of priorities, not a schedule: "the plan does not provide any deadline for completing the projects," the agencies wrote, and they intend to update it during the year.
Five projects for exempt organizations
Its section on tax-exempt organizations has five items: final regulations on the racial nondiscrimination rule for private schools, proposed Sept. 4; guidance "on the statutory prohibition in §501(c)(3) against participation or intervention in political campaigns (the 'Johnson Amendment')"; a revision of Revenue Procedure 2026-8 "for certain types of group exemption letters"; guidance under sections 4966 and 6033 "regarding certain donor advised fund arrangements"; and guidance under section 6033 "regarding exempt organization information reporting requirements, including with regard to fiscal sponsorship arrangements."
Elsewhere the plan lists regulations on the excise taxes on excess compensation at tax-exempt organizations and on investment income of certain private colleges, and on the new credit for contributions to scholarship granting organizations.
Last year's plan listed final regulations on donor advised funds, proposed in November 2023. This year's item does not say what the new guidance will cover.
Houses of worship and fiscal sponsors
The Johnson Amendment item was on last year's plan in the same words. The plan does not mention houses of worship, but on April 3 Treasury and the IRS said the guidance would provide "clear, administrable standards for houses of worship, including how the law applies to certain communications made within the context of religious services," after a federal court dismissed a lawsuit the IRS had sought to settle on a similar view.
The fiscal sponsorship item is new. On April 23 Treasury said the IRS plans to revise Form 990 to require clearer reporting by 501(c)(3) organizations on government contracts, government grants and fiscal sponsorship arrangements. It called fiscal sponsorship a set of "longstanding and lawful structures" but said congressional oversight had raised concerns that some arrangements "may be used to obscure who is operating a project, who controls project funds, and how those funds are being used."
“Public money and tax-exempt status demand public accountability.”
Treasury said it expects to publish proposed regulations and take public comments before any reporting change is final.
About this story
501c3.help wrote this story from the sources listed with it, not from material an organization sent. Our editors approved it on Oct. 1, 2026. Stories in The Nonprofit Herald are free, and nothing is asked in return. Editorial rules.
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