Blog · 16 October 2026

Form 8050 and §6104(d) Public Disclosure: Keeping EO Bank Data Off Public Copies for US CPA Firms

By Keshav Bansal, CA

Form 8050 puts an exempt organization’s routing and account numbers on a refund-deposit attachment that travels with Forms 990-PF, 990-T, 1120-POL or 4720—while IRC §6104(d) already forces those same organizations to show much of their IRS paperwork to the public. The Journal of Accountancy (Martha Waggoner, Oct. 13, 2026) reports that an AICPA letter asks the IRS to say plainly that Form 8050 is not part of the public-disclosure copy. For US CPA firms, the hook is less about one checkbox and more about running a clean §6104(d) / UBIT disclosure checklist when direct deposit meets paper-check phase-out.

What the AICPA asked the IRS to clarify

According to the Journal of Accountancy, the AICPA recommended that the IRS modify Form 8050, Direct Deposit of Tax Exempt or Government Entity Tax Refund, to indicate that the form is not included in copies of a return made available for public inspection. The article says Form 8050 was introduced for Executive Order 14247, Modernizing Payments to and From America’s Bank Account, but does not address privacy for exempt organizations that must make public various forms—including Form 990-T.

The AICPA’s letter (dated Monday relative to the Oct. 13 article—Oct. 12, 2026) said marking the form outside the public-disclosure copy would be “an efficient and practical approach to implementing the order while reducing the risk of inadvertent disclosure of sensitive information.” Scott Klein, CPA, senior manager–Tax Policy & Advocacy for the AICPA, said in a news release quoted by the Journal that clarification would “provide certainty to taxpayers and practitioners” and help “safeguard sensitive direct deposit and banking information from unnecessary public access.” As of the IRS “About Form 8050” page, recent developments were listed as none—so this remains an open clarification ask, not a published IRS answer.

What Form 8050 actually collects

Form 8050 (Rev. December 2025) is how a filer asks the IRS to deposit a tax refund—including a refund of $1 million or more—into a U.S. bank or other financial institution that accepts direct deposits. The form attaches to Form 990-PF, 990-T, 1120-POL, or 4720 and may be filed only with an original return. It asks for a nine-digit routing number (first two digits between 01 and 12 or 21 through 32), an account number, and checking or savings. The filer is ineligible if the receiving institution is a foreign bank or a foreign branch of a U.S. bank, or if the filer has applied for an EIN but is filing before receiving one. The form’s Paperwork Reduction Act notice reminds readers that returns are generally confidential under §6103—which is why §6104 public inspection creates friction when banking fields ride with a public return.

§6104(d) vs §6103: why EO returns are different

Individual and most business returns stay confidential under 26 U.S.C. §6103. Exempt organizations live under a different statute. 26 U.S.C. §6104(d) requires public inspection of certain annual returns, exemption applications, and related materials. The IRS page on documents subject to public disclosure states that an exempt organization must make available its exemption application (Form 1023 or 1023-EZ for §501(c)(3) recognition; Form 1024 or 1024-A as applicable for most other §501(c) paragraphs; plus supporting documents and IRS letters) and its annual return—including Form 990, 990-EZ, 990-PF, and Form 990-T filed after August 17, 2006 (among other listed returns).

Those returns must be available for a three-year period beginning with the due date (including extensions) or the date actually filed, whichever is later. An annual information return includes an exact copy, any amended return, and all schedules, attachments, and supporting documents filed with the IRS. That “attachments” rule is why Form 8050’s silence matters: if bank-data attachments are treated like any other attachment to a 990-PF or 990-T, preparers need a documented public-copy workflow.

How copies must be provided—and what can stay off the public set

The IRS overview of public disclosure requirements in general (and the IRS EO disclosure FAQs) says copies usually must be provided immediately for in-person requests and within 30 days for written requests. The organization may charge a reasonable copying fee plus actual postage. Other than private foundations, an exempt organization need not disclose the name and address of any contributor. Political organizations exempt under §527 must make Form 8871 (notice of status) and Form 8872 (contributions and expenditures) available—but are not required to make Form 1120-POL available. Form 8050 can attach to 1120-POL too, so firms should not assume every host form is equally public.

Form 990-T, UBIT, and which attachments must be shown

Form 990-T is where unrelated business income tax (UBIT) shows up. The IRS unrelated business income defined page says that for most organizations an activity is an unrelated business if it is a trade or business, is regularly carried on, and is not substantially related to furthering the exempt purpose—subject to modifications and exceptions. For disclosure, the IRS public inspection and disclosure of Form 990-T page states that §501(c)(3) charities must make Forms 990-T filed after August 17, 2006 available, and that the return for this purpose includes schedules, attachments, and supporting documents that relate to the imposition of tax on unrelated business income. Attachments that do not relate to UBIT need not be made available. That UBIT-related-attachments rule is where firms ask whether a pure refund-routing form belongs in the public 990-T set—the certainty the AICPA seeks.

Preparer checklist when Form 8050 meets §6104(d)

• Separate the IRS filing set from the public-inspection set — build a public copy that follows IRS rules on contributor names (non-PFs), 990-T UBIT-only attachments, and 1120-POL non-disclosure; do not blindly photocopy every attachment.
• Treat Form 8050 as sensitive bank data — routing, account number, and account type sit on the form; until the IRS answers the AICPA’s request, document whether the public copy includes or excludes it and why.
• Confirm eligibility before attaching — original return only; U.S. bank/FI (not foreign bank or foreign branch); EIN already issued.
• Calendar the three-year window — from due date including extensions (or later actual filing date) for annual returns; same discipline for charity 990-T.
• Honor request timing — immediate for in-person; 30 days for written; reasonable copy fee + postage; train staff who answer the front desk.
• Match host form to disclosure rules — 990-PF and charity 990-T are public in the ways IRS describes; 1120-POL is not; Form 8872 is. Form 4720 work often sits next to excess-benefit and Chapter 42 issues—see our intermediate sanctions / Form 4720 note.
• Keep charitable substantiation files separate — public 990 packages are not a substitute for contemporaneous written acknowledgments and Form 8283 workpapers; see charitable contribution substantiation after Williams and planning around charitable bunching and DAFs under OBBBA’s 0.5% AGI floor.

Where Tax Brew fits

Exempt-organization seasons stack Form 990-series assembly, UBIT schedules, refund packaging and public-copy hygiene. Tax Brew provides bookkeeping, cleanup and tax prep support for US CPA firms, including filed-set versus inspection-set workpapers, with the first 20 hours free for qualifying engagements. Your firm keeps the advice and the sign-off. See our services, or email info@taxbrewglobal.com.

Sources: Journal of Accountancy (Martha Waggoner, Oct. 13, 2026), AICPA recommends IRS clarification of Form 8050; Form 8050 (Rev. December 2025); IRS About Form 8050; IRS documents subject to public disclosure; IRS public disclosure requirements in general; IRS public inspection and disclosure of Form 990-T; IRS unrelated business income defined; IRS EO disclosure FAQs; 26 U.S.C. §6104; 26 U.S.C. §6103. General information, not tax or legal advice.