Public policy news and updates for the philanthropic sector

October 2, 2026

What's Happening This Week...

• Happening at the Council
• What We're Tracking in DC
• Additional Updates

Happening at the Council

With members of Congress on recess until after the midterm elections, Snapshot will be taking a break until mid-November unless there is breaking news impacting the sector.

What We're Tracking in DC

IRS 2026-2027 Priority Guidance Plan

On Tuesday, the IRS released its 2026-2027 Priority Guidance Plan. The plan details the agency’s priorities through September 30, 2027. Among the various tax priorities in the plan, the agency will prioritize several issues that impact foundations:

• Guidance related to certain donor-advised fund arrangements and tax-exempt organization reporting requirements, including for fiscal sponsorship arrangements
• Guidance on the Johnson Amendment
• Implementing provisions from the One Big Beautiful Bill, including guidance on Trump Accounts and regulations related to contributions to scholarship granting organizations
• Reducing burdens and regulations related to expenditure responsibility requirements and the reporting requirements of charitable contributions of trusts
• Finalizing regulations regarding the fundamental public policy of nondiscrimination in private schools

In May, the Council submitted comments to the agency providing recommendations for the Priority Guidance Plan. We closely follow all regulatory activity that may impact the sector and will share further updates in Snapshot.

Congressional Activity Regarding Nonprofits

In recent weeks, House Republicans sent two letters to the IRS calling for the agency to investigate multiple nonprofit organizations. On Monday, House Ways and Means Committee Republicans sent a letter to IRS CEO Frank Bisignano calling for an investigation of the Middle East Children’s Alliance and potential a revocation of the organization’s tax-exempt status due to alleged ties to a designated foreign terrorist organization.

Last week, Ways and Means Committee Chair Jason Smith (R-MO) and House Select Committee on China Chair John Moolenaar (R-MI) sent a letter to Treasury Secretary Scott Bessent and Bisignano asking for an investigation into various nonprofit organizations regarding whether the nonprofits’ anti-data center and artificial intelligence advocacy campaigns are operating for the benefit of foreign nations. The letter also asks the department to investigate if donor-advised funds or other intermediary entities have been used to move foreign funds into advocacy campaigns.

In addition, House Committee on House Administration Democrats released a report on recent actions the Trump Administration has taken to target nonprofits with differing ideological views. The report alleges that these actions have chilled free speech and may impact voting and the upcoming midterm election.

Additional Updates

• The Department of Commerce and the Census Bureau announced an extension of the deadline to submit public comments on proposed decennial census regulations. Comments are now due November 2. Read our summary of the rule, and reach out to govt@cof.org if you’re considering submitting comments.
• The Department of the Treasury and the IRS released a notice of proposed rulemaking (NPRM) on Trump Accounts. Treasury and the IRS also released temporary regulations, effective now, guiding the administration of Trump Accounts and detailing a process for automatic enrollment. The NPRM proposes finalizing the temporary regulations and requests comments regarding the definition of “qualified geographic area.” Charitable organizations are exempt from the annual contribution limit but must donate to all accounts in a certain qualified class, such as all accounts in a qualified geographic area. Treasury and the IRS propose defining that area as a zip code tabulation area. Read our summary of the regulations.
• Last week, the Department of Justice filed a brief to the Fifth Circuit Court of Appeals in the National Religious Broadcasters v. Bessent case, asking the court to reverse the District Court’s earlier decision to dismiss the case for lack of jurisdiction, arguing that the lower court failed to correctly apply a narrow exception to the Tax Anti-Injunction Act that would have allowed the court to consider the consent agreement the plaintiffs had proposed along with the IRS. Read more about this and other court cases we are monitoring.
• The Department of Treasury and IRS released temporary regulations and an NPRM addressing the Federal Scholarship Tax Credit. The temporary regulations would implement new requirements and procedures for states that elect to participate in the program and implement changes to how states maintain a list of eligible scholarship granting organizations. The NPRM updates the definition of scholarship granting organizations. The agency is accepting comments on the NPRM through November 30 and will hold a public hearing on it on December 15.

Keep in Touch!

Please feel free to reach out to any of us on the Public Policy Team with comments or concerns, or to share an issue, article, event, or op-ed you would like to see covered in a future Washington Snapshot.

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