On June 15, 2020, Cindy Lewin was quoted in USAE News on state action following final regulations from the IRS on nonprofit donor disclosure requirements.
According to the article, the IRS issued final donor disclosure requirements removing the condition 501(c)(4) social welfare organizations and 501(c)(6) professional trade associations provide the names and addresses of donors contributing $5,000 or more on the Schedule B of their Form 990s.
Some states are already beginning to require this information separately, meaning nonprofits active nationally may have to prepare two versions of their Form 990 - one with donor identities shown on the Schedule B and one without - and track the variety of requirements in different states.
Lewin told USAE some states already require the filling of two Form 990s. “California, New Jersey, and New York each require nonprofit organizations registered to solicit with the state to file a copy of the organization’s completed Schedule B. New Jersey’s revised regulations went into effect in May 2019,” said Lewin. “Thus, Section 501(c)(4) organizations registered to solicit in each of these states are required to file a completed Schedule B even if not required to be filed with the IRS.”