Given the complexities of Bingo reporting, it is most efficient for a non-profit to match their IRS reporting year to their Bingo year.  It appears that the annual reporting in the proposed regulations is moving to a calendar year.  This will create a mismatch between the two reporting periods for organizations whose IRS years are now September 30.  The result will be increased administrative costs for the entity in a having to prepare two annual reports instead of one.

To avoid the continuing structure of two annual reports, one for IRS, one for VA, they will be forced to move their year-end, and incur the necessary costs to do so.

Also, moving the reporting period to a calendar year will move the reporting preparation period into the busiest time of the year for accountants and preparers.  That will likely increase costs as nonprofits are frequently given some break in costs for work that is performed outside of tax season.

If a move in reporting period is to be made, it would be better to move it to an annual reporting period of June 30.  That would match the state fiscal year.  It would keep the work outside of the preparer busy season.

Regardless of which annual reporting period is selected, there should be a one-time reduction in Bingo fees of say $1,000 to subsidized the administrative costs for organizations that wish to continue to match their IRS reporting years to their Bingo years.