Commission Recommendations - Other Recommendations


IRS Advisory Committee for Religious Organizations

Religious and Charitable Organizations

  1. Religious organizations should engage meaningfully in the input process when opportunities are presented by the IRS or Treasury Department, and they should provide practical examples and insights. Only through such input will the views of religious organizations be made known, resulting in better outcomes.

IRS/Treasury

  1. The IRS should not establish an additional advisory committee for religious organizations.
  2. The IRS and Treasury Department should, however, more thoroughly address the unique federal tax issues of the religious community and provide more helpful and educational guidance in key areas of the tax law. Guidance should be issued in draft form in a manner that permits input from the religious community. Any such guidance should be appropriately respectful of constitutionally-protected religious freedoms. Separately, we have provided recommendations for improved guidance in specific topical areas.


Independent Accreditation and ECFA’s Model

Religious and Charitable Organizations

  1. Secular nonprofit organizations and faith groups not within the scope of ECFA’s charter should consider the possibility of utilizing or forming independent accreditation organizations similar to ECFA that rigorously address good governance, accountability, and financial integrity.
  2. Denominational and associational organizations should evaluate the effectiveness of their systems for accountability and ensure that their congregations and member organizations have adequate oversight in the areas of accountability and financial integrity.
  3. Independent religious organizations that are not part of a larger structure such as a denomination or association with robust accountability practices and that choose not to pursue independent accreditation should adopt other practices that verifiably demonstrate to their donors and other stakeholders their commitment to accountability and financial integrity.


Religious Organization Examinations and Third-Party Oversight

IRS/Treasury

  1. In our separate recommendations related to the question of whether the IRS should form a new advisory committee focused on religious organizations, we recommend against the formation of such a committee. We recommend against the adoption of any formal IRS policy or practice that would involve an advisory committee or any third-party organization in the process used by the IRS to select religious organizations for examination.


Examinations of Church Leaders

IRS/Treasury

  1. The audit protection provided in the Treasury Regulations with respect to church leaders and excess benefit transactions should be preserved.