859 
charitable assets of such organizations. Such infor-
mation may only be inspected by or disclosed to a 
person other than the appropriate State officer if 
such person is an officer or employee of the State 
and is designated by the appropriate State officer to 
receive the returns or return information under this 
paragraph on behalf of the appropriate State officer. 
‘‘(4) USE IN CIVIL JUDICIAL AND ADMINISTRA-
TIVE PROCEEDINGS.—Returns and return informa-
tion disclosed pursuant to this subsection may be 
disclosed in civil administrative and civil judicial pro-
ceedings pertaining to the enforcement of State laws 
regulating such organizations in a manner pre-
scribed by the Secretary similar to that for tax ad-
ministration proceedings under section 6103(h)(4). 
‘‘(5) NO
DISCLOSURE
IF
IMPAIRMENT.—Re-
turns and return information shall not be disclosed 
under this subsection, or in any proceeding described 
in paragraph (4), to the extent that the Secretary 
determines that such disclosure would seriously im-
pair Federal tax administration. 
‘‘(6) DEFINITIONS.—For purposes of this sub-
section— 
‘‘(A) RETURN
AND
RETURN
INFORMA-
TION.—The terms ‘return’ and ‘return informa-
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860 
tion’ have the respective meanings given to such 
terms by section 6103(b). 
‘‘(B) APPROPRIATE STATE OFFICER.—The 
term ‘appropriate State officer’ means— 
‘‘(i) the State attorney general, 
‘‘(ii) the State tax officer, 
‘‘(iii) in the case of an organization to 
which paragraph (1) applies, any other 
State official charged with overseeing orga-
nizations of the type described in section 
501(c)(3), and 
‘‘(iv) in the case of an organization to 
which paragraph (3) applies, the head of 
an agency designated by the State attorney 
general as having primary responsibility 
for overseeing the solicitation of funds for 
charitable purposes.’’. 
(b) CONFORMING AMENDMENTS.— 
(1) Paragraph (2) of section 6103(a) is amend-
ed by inserting ‘‘or section 6104(c)’’ after ‘‘this sec-
tion’’. 
(2) Subparagraph (A) of section 6103(p)(3) is 
amended by inserting ‘‘and section 6104(c)’’ after 
‘‘section’’ in the first sentence. 
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861 
(3) Paragraph (4) of section 6103(p) is amend-
ed— 
(A) in the matter preceding subparagraph 
(A), by inserting ‘‘, any appropriate State offi-
cer (as defined in section 6104(c)),’’ before ‘‘or 
any other person’’, 
(B) in subparagraph (F)(i), by inserting 
‘‘any appropriate State officer (as defined in 
section 6104(c)),’’ before ‘‘or any other per-
son’’, and 
(C) in the matter following subparagraph 
(F), by inserting ‘‘, an appropriate State officer 
(as defined in section 6104(c)),’’ after ‘‘includ-
ing an agency’’ each place it appears. 
(4) The heading for paragraph (1) of section 
6104(c) is amended by inserting ‘‘FOR CHARITABLE 
ORGANIZATIONS’’ after ‘‘RULE’’. 
(5) Paragraph (2) of section 7213(a) is amend-
ed by inserting ‘‘or under section 6104(c)’’ after 
‘‘6103’’. 
(6) Paragraph (2) of section 7213A(a) is 
amended by inserting ‘‘or under section 6104(c)’’ 
after ‘‘7213(a)(2)’’. 
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ccoleman on PROD1PC71 with BILLS
862 
(7) Paragraph (2) of section 7431(a) is amend-
ed by inserting ‘‘ or in violation of section 6104(c)’’ 
after ‘‘6103’’. 
(c) EFFECTIVE DATE.—The amendments made by 
this section shall take effect on the date of the enactment 
of this Act but shall not apply to requests made before 
such date. 
SEC. 1225. PUBLIC DISCLOSURE OF INFORMATION RELAT-
ING TO UNRELATED BUSINESS INCOME TAX 
RETURNS. 
(a) IN GENERAL.—Subparagraph (A) of section 
6104(d)(1) is amended by redesignating clauses (ii) and 
(iii) as clauses (iii) and (iv), respectively, and by inserting 
after clause (i) the following new clause: 
‘‘(ii) any annual return filed under 
section 6011 which relates to any tax im-
posed by section 511 (relating to imposi-
tion of tax on unrelated business income of 
charitable, etc., organizations) by such or-
ganization, but only if such organization is 
described in section 501(c)(3),’’. 
(b) EFFECTIVE DATE.—The amendments made by 
this section shall apply to returns filed after the date of 
the enactment of this Act. 
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863 
SEC. 1226. STUDY ON DONOR ADVISED FUNDS AND SUP-
PORTING ORGANIZATIONS. 
(a) STUDY.—The Secretary of the Treasury shall un-
dertake a study on the organization and operation of 
donor advised funds (as defined in section 4966(d)(2) of 
the Internal Revenue Code of 1986, as added by this Act) 
and of organizations described in section 509(a)(3) of such 
Code. The study shall specifically consider— 
(1) whether the deductions allowed for the in-
come, gift, or estate taxes for charitable contribu-
tions to sponsoring organizations (as defined in sec-
tion 4966(d)(1) of such Code, as added by this Act) 
of donor advised funds or to organizations described 
in section 509(a)(3) of such Code are appropriate in 
consideration of— 
(A) the use of contributed assets (including 
the type, extent, and timing of such use), or 
(B) the use of the assets of such organiza-
tions for the benefit of the person making the 
charitable contribution (or a person related to 
such person), 
(2) whether donor advised funds should be re-
quired to distribute for charitable purposes a speci-
fied amount (whether based on the income or assets 
of the fund) in order to ensure that the sponsoring 
organization with respect to such donor advised fund 
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