The JCT Report makes nineteen separate recommendations with respect to disclosure by tax-exempt organizations. INDEPENDENT SECTOR's position on these proposals (as well as a short description of each one) is summarized below.

Recommendations IS Supports
IS supports the following eight of the JCT recommendations:

• Accelerated electronic filing and redesign of Form 990 (The JCT Report called for electronic filing of the Form 990 in 2003, and revisions to the Form 990 to ensure that the forms provide relevant and comprehensive information to the public and the IRS.) 
• Disclosure of third party communications regarding written determinations (The JCT Report would conform the disclosure rules that apply to nonprofit organizations to those that apply to all other taxpayers.)
• Confidentiality of taxpayer identification numbers (The JCT Report recommends that the organization's EIN, which appears on the front page of the Form 990, not be publicly disclosed.)
• Disclosure of tax returns by section 527 organizations (The JCT Report called for greater disclosure by political organizations organized under section 527 of the Internal Revenue Code.) 
• Disclosure of names under which tax-exempt organizations conduct their operations (The JCT Report called for organizations to list both their legal name, as well as the name they do business under, on their Form 990.) 
• IRS notification of public availability of Form 990 (The JCT Report called on the IRS to included notification in its taxpayer publications that the Form 990 is publicly available.) 
• Mandatory disclosure and IRS reporting of tax-exempt organizations' web page (The JCT Report called on the IRS to collect and publicly disseminate the World Wide Web addresses of tax-exempt organizations.)
• Increased preparer penalties for preparers of tax-exempt organizations' annual returns (The JCT Report called for increased penalties on individuals who prepare annual returns for tax-exempt organizations if there was a willful, reckless misrepresentation or disregard of the relevant rules and regulations for filing the Form 990.)

Recommendations IS Supports But That Require Further Study or Refinement
IS supports the following four JCT recommendations, but IS believes these recommendations need further study or technical refinement:

• Greater flexibility for IRS information sharing with state charity regulators (The JCT Report called for additional flexibility in sharing information with state officials in certain cases to promote efficient and effective tax administration.)  
• Increased reporting about transfers among section 501(c)(3), section 501(c)(4), and section 527 organizations (The JCT Report called for more information about these types of transfers so that the IRS can assess whether contributions to a tax-exempt organization are being used to fund political activities.) 
• Permitting private foundations to report only summaries of their investment transactions and assets (The JCT Report would allow private foundations to disclose a summary of their capital gains and losses, but a full listing would still be required to be filed with the IRS and made publicly available.) 
• Annual notice requirement for small exempt entities (The JCT Report would require organizations that do not meet the filing thresholds for filing a 990-EZ to file a brief, annual notice of their status to the IRS.)

Recommendations That IS Opposes
IS strongly opposes the following seven JCT recommendations:

• Non-redacted disclosure of written determinations and related file documents (The JCT Report calls for full disclosure of all written determinations regarding tax-exempt organizations including all information in the determination that identifies the organization and any individuals covered by the ruling.)
• Non-redacted disclosure of closing agreements and audit results (The JCT Report calls for full disclosure of all closing agreements and audit results, including all information that identifies the organization and any individuals covered by the agreement or audit.)
• Non-redacted disclosure of exemption applications at the time of filing (The JCT Report calls for public disclosure of each application for tax-exempt status at the time it is made to the IRS, including all information that identifies the organization and individuals associated with the application.)
• Non-redacted disclosure of Forms 990-T and 1120 (The JCT Report calls for the public disclosure of an organization's Form 990-T (for any unrelated business income) as well as any corporate tax return (Form 1120 and 1165) of any affiliated organizations of tax-exempt organizations.) 
• Narrative description of lobbying by charities reporting under section 501(h) (The JCT Report would require public charities to describe their lobbying activities in addition to providing information about their lobbying expenditures.)
• Reporting of self-defense lobbying expenses (The JCT Report would require public charities to track and report their self-defense lobbying activities, information that is not currently required to be separately collected and reported.)
• Reporting of expenses for nonpartisan analysis containing indirect calls to action (The JCT Report would require that public charities disclose their expenses for certain nonpartisan study, analysis, or research activities.)