On April 23, 2026, the U.S. Department of the Treasury announced that the IRS plans to revise the Form 990 to improve transparency and provide clearer reporting on certain transactions of 501(c)(3) organizations, including government contracts, government grants, and fiscal sponsorship arrangements. In this alert, we provide a summary of the announcement, an estimate of how long any such changes may take, and our recommendations for next steps for exempt organizations given the increased scrutiny these organizations are already facing.

Photo of Susan Leahy Susan Leahy

Susan Leahy has advised tax-exempt, nonprofit organizations on tax and corporate governance matters for over 25 years. She assists organizations in obtaining and maintaining tax-exempt status and advises boards and senior executives on a range of governance policies and procedures.

In her work…

Susan Leahy has advised tax-exempt, nonprofit organizations on tax and corporate governance matters for over 25 years. She assists organizations in obtaining and maintaining tax-exempt status and advises boards and senior executives on a range of governance policies and procedures.

In her work with tax-exempt organizations that operate in the United States, as well as internationally, Susan regularly:

Counsels clients on the tax implications involving:

Self-dealing, inurement, and impermissible private benefit to individuals and for-profit companies;
Lobbying, and political activities;
Unrelated business income tax;
Excess benefit transactions and compensation of executives;
Joint ventures and relationships with for-profit organizations;
Mergers of tax-exempt organizations and the acquisition or donation of assets; and
Corporate sponsorship.

Advises nonprofit boards of directors, board committees, and management with respect to:

Corporate formation and good governance principles;
Preparation for board and committee meetings; and
Conflicts of interests.
Provides guidance on state corporate and tax compliance for nonprofit organizations.

“Susan has been my ‘Go-To’ attorney for adept legal strategy and guidance for over 20 years. Susan skillfully led our organization’s volunteer leadership through a needed transition with compassion and sensitivity. Her legal assistance remains invaluable!” a nonprofit organization client noted.

“I highly value Susan’s expertise, responsiveness, and pragmatism,” said another client. “Her insight and advice have proven invaluable time and time again and remain integral to our ability to operate quickly and nimbly.”

Susan is the past chair of the Exempt Organizations Committee of the District of Columbia Bar and a member of the American Bar Association. Susan received her J.D. from Catholic University of America, Columbus School of Law and a B.B.A. from St. Bonaventure University.

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Photo of Christina Danberg Bubel Christina Danberg Bubel

Christina Danberg Bubel is an associate in the firm’s Washington, DC office, where she is a member of the Tax Practice Group. Christina also maintains an active pro bono practice.

Christina earned her J.D. from the Georgetown University Law Center, where she mentored…

Christina Danberg Bubel is an associate in the firm’s Washington, DC office, where she is a member of the Tax Practice Group. Christina also maintains an active pro bono practice.

Christina earned her J.D. from the Georgetown University Law Center, where she mentored law students in legal writing as part of the Law Fellow Program.

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