Treasury and IRS put donor-advised fund guidance on 2026-2027 priority plan

Treasury and the IRS put donor-advised fund guidance on the 2026-2027 Priority Guidance Plan released at the end of September. The item cites two code sections: 4966 and 6033. WealthManagement.com reports that the 6033 reference is new; because Section 6033 sets out nonprofits' annual reporting requirements, the addition may signal further reporting obligations for donor-advised fund sponsors.

The 4966 half is likely a pointer to the donor-advised fund regulations proposed in 2023, according to the report; those regulations drew concern that they could reduce giving through the vehicle. A separate line item covers "Guidance under §6033 regarding exempt organization information reporting requirements, including with regard to fiscal sponsorship arrangements." The report links that item to Treasury's Form 990 Transparency Initiative announced in April. Treasury has already confirmed it is working on fiscal sponsorship reporting regulations, and the plan item may extend to other nonprofit reporting as well.

An IRS official said at an American Bar Association event that donor-advised fund guidance addressing the most frequently raised concerns about the 2023 proposal would be released soon, according to the report. Agency officials have made similar near-term predictions at other conferences over the past year; the report gives no date beyond "soon."

The plan does not signal the outcome of any guidance or regulation and may not represent all of Treasury's active work, according to the report. Other charitable-sector entries include finalizing proposed racial nondiscrimination regulations for private schools and issuing guidance on the Johnson Amendment, which the report describes as barring 501(c)(3) charities, universities, foundations and houses of worship from endorsing or opposing political candidates. WealthManagement.com reads the plan as making nonprofit regulation a priority on several fronts. It says a divided Congress next year would still leave room for agency-driven changes as proposals take shape.

No guidance has been issued, so the plan does not change how donors currently fund, grant from or report a donor-advised fund.