Who Determines Where the Sun Shines: Nonprofit Sector Stakeholders and the IRS Form 990 Redesign

Despite the importance of Internal Revenue Service (IRS) Form 990 to exempt organizations’ regulation, management, and accountability, scholars and practitioners have overlooked how the form evolved over time. This study uses public comments, submitted during the most recent revision of the form in 2007, to examine who participated, stakeholder priorities, and how the updated form was shaped by the federal rulemaking process. The study finds that (a) the submitters of public comments provide a comprehensive view of the nonprofit sector’s diverse set of stakeholders and (b) the public comments highlight substantive self-identified priorities for the sector that can serve as a guide to future research. Key takeaways include the need to consider for-profit and trade association influence in nonprofit policy formation, to recognize selective transparency in reporting requirements, and to understand how stakeholder interests shape regulatory outcomes. Implications suggest researchers should fully leverage Form 990’s extensive changes while remaining cognizant of information gaps.