New Transparency Rule Forces Think Tanks to Publicly Disclose Foreign Gifts Over $10,000

This legislation, officially titled the Think Tank and Nonprofit Foreign Influence Disclosure Act, is straightforward: it forces certain tax-exempt organizations to publicly report significant foreign funding they receive. Specifically, if a non-profit gets more than $10,000 annually from a foreign government, a foreign political party, or an entity controlled by them, that organization now has to detail the source and amount on its annual tax return (SEC. 3).

The core purpose, according to the bill's findings (SEC. 2), is to close a transparency loophole. While U.S. colleges already have to disclose foreign gifts to the Department of Education, many influential think tanks and cultural groups currently do not. The bill argues this lack of disclosure is a national security risk, pointing directly to influence operations run by countries like China that target these organizations to shape U.S. policy.

The Public Scoreboard: Who’s Funding Whom?

The biggest change for the public is the creation of a searchable online database. The Secretary of the Treasury is required to take all this newly reported foreign contribution data and put it online for everyone to see (SEC. 3(b)). This means citizens, journalists, and policymakers will be able to look up which organizations are taking money from which foreign sources, and exactly how much.

The bill doesn't stop there; it specifically singles out funding connected to the People’s Republic of China (PRC) and the Chinese Communist Party (CCP). The database must track and highlight the aggregate amount received from the PRC, the CCP, or any entity they are directing, controlling, financing, or subsidizing. This is a clear signal that Congress is focused on counteracting influence efforts tied to Beijing.

New Paperwork and Reputational Risk

For the organizations affected—primarily think tanks and cultural non-profits—this means a new compliance headache. They now have to set up systems to diligently track every foreign gift over $10,000 and report it annually. This administrative burden, while manageable for large organizations, is a new cost for smaller non-profits. The new rule applies to tax returns filed for any tax year starting after the law is enacted (SEC. 3(c)).

Beyond the paperwork, there’s the reputational risk. Imagine a small cultural exchange group that receives a legitimate grant from a foreign university that happens to get some funding from its government. Even if the grant is benign, having that funding source listed in a public database dedicated to tracking “foreign influence”—especially if it’s flagged under the broad PRC/CCP category—could lead to unwarranted scrutiny or accusations of being a foreign agent. This is where the bill gets a little squishy: the definition of an “entity that those two are directing, controlling, financing, or subsidizing” is quite broad and open to interpretation, which could sweep up organizations that aren’t actually involved in influence operations.