The bill creates procedural protections (notice, cure period, appeals, classified-information handling) for nonprofits facing designation, but still permits secrecy and preliminary penalties that can cause financial harm, hinder meaningful rebuttal, and chill nonprofit activity—especially for small organizations.
Nonprofit organizations will receive advance notice and a 90-day cure period before losing tax-exempt status, reducing the risk of immediate, wrongful loss of benefits and donations.
Designated organizations can seek administrative review at the IRS Independent Office of Appeals and obtain district-court review (including procedures to handle classified evidence), preserving formal avenues to challenge designations.
The Treasury must adopt classified-information handling policies, which can protect sensitive national security information in disputes and enable use of classified evidence without public disclosure.
Nonprofits may lose tax-exempt status or access to donor support during the designation process, causing immediate financial harm and program disruption.
The Secretary can make or sustain designations in ways that risk being erroneous or politically influenced, chilling nonprofit advocacy and creating broad compliance burdens.
Treasury may withhold descriptions of alleged support for national security reasons, limiting an organization’s ability to meaningfully rebut accusations and undermining transparency in the process.
Based on analysis of 2 sections of legislative text.
Introduced December 17, 2025 by John Cornyn · Last progress December 17, 2025
Allows the Treasury Secretary to designate certain organizations as “terrorist supporting organizations” and treat them like organizations that can have their federal tax-exempt status suspended or terminated if they provided material support to designated terrorist groups in the prior three years. The bill sets notice and a 90-day cure period for organizations, creates administrative appeal and district court review paths (including procedures for handling classified information), and requires Treasury policies for classified evidence; it applies to designations made after enactment for taxable years ending after enactment.