II 

118TH CONGRESS 

2D SESSION S. 4326 

To amend the Internal Revenue Code of 1986 to modify the penalties relating 

to the disclosure of tax return information relating to contributors to 

certain tax-exempt organizations, and for other purposes. 

IN THE SENATE OF THE UNITED STATES 

MAY 14, 2024 

Mr. YOUNG (for himself and Mr. LANKFORD) introduced the following bill; 

which was read twice and referred to the Committee on Finance 

A BILL 

To amend the Internal Revenue Code of 1986 to modify 

the penalties relating to the disclosure of tax return 

information relating to contributors to certain tax-exempt 

organizations, and for other purposes. 

1 Be it enacted by the Senate and House of Representa2 tives of the United States of America in Congress assembled, 

3 SECTION 1. SHORT TITLE. 

4 This Act may be cited as the ‘‘Protecting Charitable 

5 Giving Act’’. 


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1 SEC. 2. UNAUTHORIZED DISCLOSURE OF INFORMATION RE2 LATING TO CONTRIBUTORS TO CERTAIN TAX3 EXEMPT ORGANIZATIONS. 

4 (a) IN GENERAL.—Section 7213 of the Internal Rev5 enue Code of 1986 is amended by redesignating subsection 

6 (e) as subsection (f) and by inserting after subsection (d) 

7 the following new subsection: 

8 ‘‘(e) SPECIAL RULES FOR DISCLOSURES OF CON9 TRIBUTORS TO CERTAIN TAX-EXEMPT ORGANIZA10 TIONS.— 

11 ‘‘(1) INCREASED PENALTY.—In the case of any 

12 disclosure of form 990 schedule B return informa13 tion, paragraphs (1), (2), (3), and (4) of subsection 

14 (a) shall each be applied by substituting ‘not less 

15 than $10,000 and not exceeding $250,000’ for ‘not 

16 exceeding $5,000’. 

17 ‘‘(2) VENUE.— 

18 ‘‘(A) IN GENERAL.—A prosecution for an 

19 offense under paragraphs (1), (2), (3), or (4) of 

20 subsection (a) relating to the disclosure of form 

21 990 schedule B return information may be 

22 brought in— 

23 ‘‘(i) the judicial district in which a 

24 victim of the offense resides, or 

25 ‘‘(ii) any other judicial district with 

26 jurisdiction otherwise provided for by law. 


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1 ‘‘(B) RESIDENCY.—For purposes of deter2 mining venue under this paragraph— 

3 ‘‘(i) an individual shall be deemed to 

4 reside in the judicial district in which that 

5 individual is domiciled, and 

6 ‘‘(ii) an organization shall be deemed 

7 to reside in the judicial district in which 

8 the organization maintains its principal 

9 place of business. 

10 ‘‘(C) VICTIM.—For purposes of this para11 graph, the term ‘victim’ includes— 

12 ‘‘(i) the organization whose form 990 

13 schedule B information was disclosed, and 

14 ‘‘(ii) any contributor to such organiza15 tion who is described in paragraph (3)(B). 

16 ‘‘(3) FORM 990 SCHEDULE B INFORMATION.— 

17 For purposes of this subsection, the term ‘form 990 

18 schedule B information’ means any information 

19 which— 

20 ‘‘(A) is return information (as defined in 

21 section 6103(b)) of— 

22 ‘‘(i) an organization described in sec23 tion 501(c)(3) (other than a private foun24 dation, as defined in section 509(a)), or 


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1 ‘‘(ii) an organization described in sec2 tion 501(c)(4), and 

3 ‘‘(B) contains the names or address of any 

4 contributor to such organization.’’. 

5 (b) EFFECTIVE DATE.—The amendments made by 

6 this section shall apply to disclosures made after the date 

7 of the enactment of this Act. 

8 SEC. 3. AUDITS AND REPORTS ON UNAUTHORIZED DISCLO9 SURES RELATING TO CONTRIBUTORS OF 

10 CERTAIN TAX-EXEMPT ORGANIZATIONS. 

11 Section 7803(d)(3) of the Internal Revenue Code of 

12 1986 is amended by striking ‘‘and’’ at the end of subpara13 graph (B), by striking the period at the end of subpara14 graph (C) and inserting ‘‘; and’’, and by adding at the 

15 end the following new subparagraph: 

16 ‘‘(D) issue a report with respect to any 

17 disclosure of form 990 schedule B information 

18 (as defined in section 7213(e)(3)) to which sec19 tion 7213(e) applies, which report shall— 

20 ‘‘(i) describe the result of an audit on 

21 the occurrence of such disclosure, 

22 ‘‘(ii) recommend steps to prevent simi23 lar further such disclosures in the future, 

24 and 


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1 ‘‘(iii) be appropriately redacted to pro2 tect any return information (as defined in 

3 section 6103(b)).’’. 

Æ 


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