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Instructions For Form 990 Return of Organization Exempt From Income Tax

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2019 Department of the Treasury

Internal Revenue Service

Instructions for Form 990


Return of Organization
Exempt From Income Tax
Under section 501(c), 527, or 4947(a)(1) of the Internal Revenue Code
(except private foundations)
(For use with 2019 Form 990 (Rev. January 2020))
Section references are to the Internal Revenue Code unless Contents Page
otherwise noted. Appendix of Special Instructions to Form 990
Contents Page Contents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 76
Purpose of Form . . . . . . . . . . . . . . . . . . . . . . . . . ... 2 Appendix A. Exempt Organizations Reference
Phone Help . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... 2 Chart . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 77
Email Subscription . . . . . . . . . . . . . . . . . . . . . . . ... 2 Appendix B. How To Determine Whether an
Organization's Gross Receipts Are Normally
General Instructions . . . . . . . . . . . . . . . . . . . . . . ... 2
$50,000 (or $5,000) or Less . . . . . . . . . . . . . . . . 78
A. Who Must File . . . . . . . . . . . . . . . . . . . . . ... 2
Appendix C. Special Gross Receipts Tests for
B. Organizations Not Required To File Form Determining Exempt Status of Section 501(c)
990 or 990-EZ . . . . . . . . . . . . . . . . . . . . .... 4 (7) and 501(c)(15) Organizations . . . . . . . . . . . . 78
C. Sequencing List To Complete the Form Appendix D. Public Inspection of Returns . . . . . . . . . 79
and Schedules . . . . . . . . . . . . . . . . . . . . . . . . 4
Appendix E. Group Returns—Reporting
D. Accounting Periods and Methods . . . . . . . . . . 5 Information on Behalf of the Group . . . . . . . . . . . 83
E. When, Where, and How To File . . . . . . . . . . . . 6 Appendix F. Disregarded Entities and Joint
F. Extension of Time To File . . . . . . . . . . . . . . . . 6 Ventures—Inclusion of Activities and Items . . . . . 84
G. Amended Return/Final Return . . . . . . . . . . . . . 6 Appendix G. Section 4958 Excess Benefit
H. Failure-to-File Penalties . . . . . . . . . . . . . . . . . 7 Transactions . . . . . . . . . . . . . . . . . . . . . . . . . . 86
I. Group Return . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Appendix H. Forms and Publications To File or
J. Requirements for a Properly Completed Use . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 91
Form 990 . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Appendix I. Use of Form 990 or 990-EZ To Satisfy
Specific Instructions . . . . . . . . . . . . . . . . . . . . . . . . . 8 State Reporting Requirements . . . . . . . . . . . . . . 93
Heading. Items A–M . . . . . . . . . . . . . . . . . . . . . . 8 Appendix J. Contributions . . . . . . . . . . . . . . . . . . . . 94
Part I. Summary . . . . . . . . . . . . . . . . . . . . . . . . 10 Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 98
Part II. Signature Block . . . . . . . . . . . . . . . . . . . 10 Future Developments
Part III. Statement of Program Service For the latest information about developments related to Form
Accomplishments . . . . . . . . . . . . . . . . . . . . . 11 990 and its instructions, such as legislation enacted after they
Part IV. Checklist of Required Schedules . . . . . . 12 were published, go to IRS.gov/Form990.
Part V. Statements Regarding Other IRS
Filings and Tax Compliance . . . . . . . . . . . . . 15
What’s New
Part VI. Governance, Management, and Required electronic filing by exempt organizations. For tax
Disclosure . . . . . . . . . . . . . . . . . . . . . . . . . . 19 years beginning on or after July 2, 2019, section 3101 of P.L.
Part VII. Compensation of Officers, Directors, 116-25 requires that returns by exempt organizations be filed
electronically. If you are filing Form 990 for a tax year beginning
Trustees, Key Employees, Highest
on or after July 2, 2019, you must file the return electronically.
Compensated Employees, and Limited exceptions apply. See When, Where, and How To File,
Independent Contractors . . . . . . . . . . . . . . . . 26 later, for more information.
Part VIII. Statement of Revenue . . . . . . . . . . . . . 38 Electronic filing requirements have not changed for Form 990
Part IX. Statement of Functional Expenses . . . . . 43 filers with tax years beginning before July 2, 2019 (which
Part X. Balance Sheet . . . . . . . . . . . . . . . . . . . . 48 includes calendar year 2019 Forms 990). Required electronic
Part XI. Reconciliation of Net Assets . . . . . . . . . 51 filing for calendar year filers will apply for tax years beginning in
2020 and later.
Part XII. Financial Statements and Reporting . . . 51
Business Activity Codes . . . . . . . . . . . . . . . . . . . . . 53 Reminders
Glossary . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 54 Excise tax on executive compensation, Part V. New section
4960 imposes an excise tax on an organization that pays to any

Jan 15, 2020 Cat. No. 11283J


covered employee more than $1 million in remuneration or pays section 501(a), and certain political organizations and
an excess parachute payment during the year starting in 2018. nonexempt charitable trusts. Parts I through XII of the form
See section 4960 and Form 4720, Return of Certain Excise must be completed by all filing organizations and require
Taxes Under Chapters 41 and 42 of the Internal Revenue Code, reporting on the organization's exempt and other activities,
and IRS Notice 2019-09, for more information. finances, governance, compliance with certain federal tax filings
and requirements, and compensation paid to certain persons.
Excise tax on net investment income of certain colleges Additional schedules are required to be completed depending
and universities, Part V. New section 4968 imposes an excise upon the activities and type of the organization. By completing
tax on the net investment income of certain private colleges and Part IV, the organization determines which schedules are
universities. See section 4968 and Form 4720, Return of Certain required. The entire completed Form 990 filed with the IRS,
Excise Taxes Under Chapters 41 and 42 of the Internal Revenue except for certain contributor information on Schedule B (Form
Code, and the interim guidance listed in IRS Notice 2019-09, for 990, 990-EZ, or 990-PF), is required to be made available to the
more information. public by the IRS and the filing organization (see Appendix D.
FASB changes, Part X. Instructions to Form 990 reflect the Public Inspection of Returns), and can be required to be filed
financial statement reporting changes under the Accounting with state governments to satisfy state reporting requirements.
Standards Update (ASU) 2016-14 (ASU 2016-14), Presentation See Appendix I. Use of Form 990 and 990-EZ to Satisfy State
of Financial Statements of Not-for-Profit Entities, issued by the Reporting Requirements.
Financial Accounting Standards Board (FASB). ASU 2016-14 Reminder: Don't Include Social Security Numbers
changes the way not-for-profit organizations classify net assets. on Publicly Disclosed Forms. Because the filing
!
CAUTION organization and the IRS are required to publicly
Purpose of Form disclose the organization's annual information returns, social
Forms 990 and 990-EZ are used by tax-exempt organizations, security numbers shouldn't be included on this form. By law, with
nonexempt charitable trusts, and section 527 political limited exceptions, neither the organization nor the IRS may
organizations to provide the IRS with the information required by remove that information before making the form publicly
section 6033. available. Documents subject to disclosure include statements
An organization's completed Form 990 or 990-EZ, and a and attachments filed with the form. For more information, see
section 501(c)(3) organization's Form 990-T, Exempt Appendix D. Public Inspection of Returns.
Organization Business Income Tax Return, generally are
Helpful hints. The following hints can help you more efficiently
available for public inspection as required by section 6104.
review these instructions and complete the form.
Schedule B (Form 990, 990-EZ, or 990-PF), Schedule of
Contributors, is available for public inspection for section 527 • See General Instructions, Section C. Sequencing List to
Complete the Form and Schedules, later, which provides
organizations filing Form 990 or 990-EZ. For other organizations
guidance on the recommended order for completing the form
that file Form 990 or Form 990-EZ, parts of Schedule B (Form
and applicable statements.
990, 990-EZ, or 990-PF), can be open to public inspection. See
Appendix D and the Instructions for Schedule B (Form 990, • Throughout these instructions, “the organization” and the
“filing organization” both refer to the organization filing Form 990.
990-EZ, or 990-PF) for more details.
• Unless otherwise specified, information should be provided
Some members of the public rely on Form 990 or Form for the organization's tax year. For instance, an organization
990-EZ as their primary or sole source of information about a should answer “Yes” to a question asking whether it conducted a
particular organization. How the public perceives an organization certain type of activity only if it conducted that activity during the
in such cases can be determined by information presented on its tax year.
return. • The examples appearing throughout the instructions on Form
990 are illustrative only. They are for the purpose of completing
Phone Help this form and aren't all-inclusive.
If you have questions and/or need help completing Form 990, • Instructions to the Form 990 schedules are published
please call 877-829-5500. This toll-free telephone service is separately from these instructions.
available Monday through Friday. Organizations that have $1,000 or more for the tax year
Email Subscription ! of total gross income from all unrelated trades or
CAUTION businesses must file Form 990-T, to report and pay tax
The IRS has established a subscription-based email service for on the resulting UBTI, in addition to any required Form 990,
tax professionals and representatives of tax-exempt 990-EZ, or 990-N.
organizations. Subscribers will receive periodic updates from the
IRS regarding exempt organization tax law and regulations,
available services, and other information. To subscribe, visit
A. Who Must File
IRS.gov/Charities-&-Non-Profits/Subscribe-to-Exempt- Most organizations exempt from income tax under section
Organization-Update. 501(a) must file an annual information return (Form 990 or
990-EZ) or submit an annual electronic notice (Form 990-N),

General Instructions
depending upon the organization's gross receipts and total
assets.

Overview of Form 990 An organization may not file a “consolidated” Form 990
TIP to aggregate information from another organization that
Note. Terms in bold are defined in the Glossary of the has a different EIN, unless it is filing a group return and
Instructions for Form 990. reporting information from a subordinate organization or
Certain Form 990 filers must file electronically. See organizations, reporting information from a joint venture or
General Instructions, Section E. When, Where, and How disregarded entity (see Appendices E and F, later), or as
!
CAUTION to File, later, for who must file electronically. otherwise provided for in the Code, regulations, or official IRS
guidance. A parent-exempt organization of a section 501(c)(2)
Form 990 is an annual information return required to be filed with title-holding company may file a consolidated Form 990-T with
the IRS by most organizations exempt from income tax under

-2- Instructions for Form 990


the section 501(c)(2) organization, but not a consolidated Form Section 509(a)(3) supporting organizations. A section
990. 509(a)(3) supporting organization must file Form 990 or
990-EZ, even if its gross receipts are normally $50,000 or less,
Form 990 must be filed by an organization exempt from
and even if it is described in Rev. Proc. 96-10, 1996-1 C.B. 577,
income tax under section 501(a) (including an organization that
or is an affiliate of a governmental unit described in Rev. Proc.
hasn't applied for recognition of exemption) if it has either (1)
95-48, unless it qualifies as one of the following:
gross receipts greater than or equal to $200,000 or (2) total
assets greater than or equal to $500,000 at the end of the tax 1. An integrated auxiliary of a church described in
year (with exceptions described below for organizations eligible Regulations section 1.6033-2(h),
to submit Form 990-N and for certain organizations described in 2. The exclusively religious activities of a religious order,
Section B. Organizations Not Required to File Form 990 or or
990-EZ, later). This includes: 3. An organization, the gross receipts of which are normally
• Organizations described in section 501(c)(3) (other than not more than $5,000, that supports a section 501(c)(3) religious
private foundations), and organization.
• Organizations described in other 501(c) subsections (other
than black lung benefit trusts). If the organization is described in (3) but not in (1) or (2), then it
Gross receipts are the total amounts the organization must submit Form 990-N unless it voluntarily files Form 990 or
received from all sources during its tax year, without subtracting 990-EZ.
any costs or expenses. See Appendix B for a discussion of Section 501(c)(7) and 501(c)(15) organizations. Section
gross receipts. 501(c)(7) and 501(c)(15) organizations apply the same gross
For purposes of Form 990 reporting, the term section 501(c) receipts test as other organizations to determine whether they
(3) includes organizations exempt under sections 501(e) and (f) must file Form 990, but use a different definition of gross receipts
(cooperative service organizations), 501(j) (amateur sports to determine whether they qualify as tax-exempt for the tax year.
organizations), 501(k) (child care organizations), and 501(n) See Appendix C for more information.
(charitable risk pools). In addition, any organization described in Section 527 political organizations. A tax-exempt political
one of these sections is also subject to section 4958 if it obtains organization must file Form 990 or 990-EZ if it had $25,000 or
a determination letter from the IRS stating that it is described in more in gross receipts during its tax year, even if its gross
section 501(c)(3). receipts are normally $50,000 or less, unless it meets one of the
Form 990-N. If an organization normally has gross receipts of exceptions for certain political organizations under Section B.
$50,000 or less, it must submit Form 990-N, Electronic Notice Organizations Not Required To File Form 990 or 990-EZ, later. A
(e-Postcard) for Tax-Exempt Organizations Not Required To File qualified state or local political organization must file Form 990 or
Form 990 or 990-EZ, if it chooses not to file Form 990 or Form 990-EZ only if it has gross receipts of $100,000 or more. Political
990-EZ (with exceptions described below for certain section organizations aren't required to submit Form 990-N.
509(a)(3) supporting organizations and for certain Section 4947(a)(1) nonexempt charitable trusts. A
organizations described in Section B. Organizations Not nonexempt charitable trust described under section 4947(a)
Required To File Form 990 or 990-EZ, later). See Appendix B for (1) (if it isn't treated as a private foundation) is required to file
a discussion of gross receipts. Form 990 or 990-EZ, unless excepted under Section B.
Form 990-EZ. If an organization has gross receipts less than Organizations Not Required To File Form 990 or 990-EZ, later.
$200,000 and total assets at the end of the tax year less than Such a trust is treated like an exempt section 501(c)(3)
$500,000, it can choose to file Form 990-EZ, Short Form Return organization for purposes of completing the form. Section
of Organization Exempt From Income Tax, instead of Form 990. 4947(a)(1) trusts must complete all sections of the Form 990 and
See the Instructions for Form 990-EZ for more information. See schedules that section 501(c)(3) organizations must complete.
the special rules below regarding controlling organizations All references to a section 501(c)(3) organization in the Form
under section 512(b)(13) and sponsoring organizations of 990, schedules, and instructions include a section 4947(a)(1)
donor advised funds. trust (for instance, such a trust must complete Schedule A (Form
If an organization eligible to submit the Form 990-N or file the 990 or 990-EZ)), unless otherwise specified. If such a trust
Form 990-EZ chooses to file the Form 990, it must file a doesn't have any taxable income under Subtitle A of the Code, it
complete return. can file Form 990 or 990-EZ to meet its section 6012 filing
requirement and doesn't have to file Form 1041, U.S. Income
Foreign and U.S. possession organizations. Foreign Tax Return for Estates and Trusts.
organizations and U.S. possession organizations as well as
domestic organizations must file Form 990 or 990-EZ unless Returns when exempt status not yet established. An
specifically excepted under Section B. Organizations Not organization is required to file Form 990 under these instructions
Required To File Form 990 or 990-EZ, later. Report amounts in if the organization claims exempt status under section 501(a) but
U.S. dollars and state what conversion rate the organization hasn't established such exempt status by filing Form 1023,
uses. Combine amounts from inside and outside the United Application for Recognition of Exemption Under Section 501(c)
States and report the total for each item. All information must be (3) of the Internal Revenue Code, Form 1023-EZ, Streamlined
written in English. Application for Recognition of Exemption Under Section 501(c)
(3) of the Internal Revenue Code, Form 1024, Application for
Sponsoring organizations of donor advised funds. If Recognition of Exemption Under Section 501(a), or Form
required to file an annual information return for the year, 1024-A, Application for Recognition of Exemption under Section
sponsoring organizations of donor advised funds must file 501(c)(4) of the Internal Revenue Code, and receiving an IRS
Form 990 and not Form 990-EZ. determination letter recognizing tax-exempt status. In such a
Controlling organizations described in section 512(b)(13). case, the organization must check the “Application pending”
A controlling organization of one or more controlled entities, checkbox on Form 990, Item B, Heading, page 1 (whether or not
as described in section 512(b)(13), must file Form 990 and not a Form 1023, 1023-EZ, 1024, or 1024-A, has been filed) to
Form 990-EZ if it is required to file an annual information return indicate that Form 990 is being filed in the belief that the
for the year and if there was any transfer of funds between the organization is exempt under section 501(a), but that the IRS
controlling organization and any controlled entity during the year. hasn't yet recognized such exemption.

Instructions for Form 990 -3-


To be recognized as exempt retroactive to the date of its Certain organizations with limited gross receipts.
organization or formation, an organization claiming tax-exempt 10. An organization whose gross receipts are normally
status under section 501(c) (other than 501(c)(29)) generally $50,000 or less. Such organizations generally are required to
must file an application for recognition of exemption (Form 1023, submit Form 990-N if they choose not to file Form 990 or Form
1023-EZ, 1024, or 1024-A) within 27 months of the end of the 990-EZ. To determine what an organization's gross receipts
month in which it was legally organized or formed. “normally” are, see Appendix B. How To Determine Whether an
An organization that has filed a letter application for Organization's Gross Receipts Are Normally $50,000 (or $5,000)
recognition of exemption as a qualified nonprofit health or Less.
!
CAUTION insurance issuer under section 501(c)(29), or plans to do 11. Foreign organizations and organizations located in U.S.
so, but hasn't yet received an IRS determination letter possessions, whose gross receipts from sources within the
recognizing exempt status, must check the “Application United States are normally $50,000 or less and which didn't
pending” checkbox on the Form 990, Heading, Item B. engage in significant activity in the United States (other than
investment activity). Such organizations, if they claim U.S. tax
B. Organizations Not Required To File exemption or are recognized by the IRS as tax-exempt,
generally are required to submit Form 990-N if they choose not
Form 990 or 990-EZ to file Form 990 or 990-EZ.
An organization doesn't have to file Form 990 or 990-EZ even if it
has at least $200,000 of gross receipts for the tax year or If a foreign organization or U.S. possession organization is
$500,000 of total assets at the end of the tax year if it is required to file Form 990 or Form 990-EZ, then its worldwide
described below (except for section 509(a)(3) supporting gross receipts, as well as assets, are taken into account in
organizations, which are described earlier). See Section A. Who determining whether it qualifies to file Form 990-EZ.
Must File to determine if the organization can file Form 990-EZ Certain organizations that file different kinds of annual
instead of Form 990. An organization described in paragraph 10, information returns.
11, or 13 of this Section B is required to submit Form 990-N 12. A private foundation (including a private operating
unless it voluntarily files Form 990, 990-EZ, or 990-BL, as foundation) exempt under section 501(c)(3) and described in
applicable. section 509(a). Use Form 990-PF, Return of Private Foundation.
Also use Form 990-PF for a taxable private foundation, a section
Certain religious organizations.
4947(a)(1) nonexempt charitable trust treated as a private
1. A church, an interchurch organization of local units of a foundation, and a private foundation terminating its status by
church, a convention or association of churches, or an becoming a public charity under section 507(b)(1)(B) (for tax
integrated auxiliary of a church as described in Regulations years within its 60-month termination period). If the organization
section 1.6033-2(h) (such as a men's or women's organization, successfully terminates, then it files Form 990 or 990-EZ in its
religious school, mission society, or youth group). final year of termination.
2. A church-affiliated organization that is exclusively 13. A black lung benefit trust described in section 501(c)(21).
engaged in managing funds or maintaining retirement programs Use Form 990-BL, Information and Initial Excise Tax Return for
and is described in Rev. Proc. 96-10, 1996-1 C.B. 577. But see Black Lung Benefit Trusts and Certain Related Persons.
the filing requirements for section 509(a)(3) supporting
14. A religious or apostolic organization described in section
organizations in A. Who Must File.
501(d). Use Form 1065, U.S. Return of Partnership Income.
3. A school below college level affiliated with a church or
15. A stock bonus, pension, or profit-sharing trust that
operated by a religious order described in Regulations section
qualifies under section 401. Use Form 5500, Annual Return/
1.6033-2(g)(1)(vii).
Report of Employee Benefit Plan.
4. A mission society sponsored by, or affiliated with, one or
more churches or church denominations, if more than half of the Subordinate organizations in a group exemption
society's activities are conducted in, or directed at, persons in TIP which are included in a group return filed by the
foreign countries. central organization for the tax year shouldn't file a
separate Form 990, Form 990-EZ, or Form 990–N for the tax
5. An exclusively religious activity of any religious order
year.
described in Rev. Proc. 91-20, 1991-1 C.B. 524.
Certain governmental organizations.
C. Sequencing List To Complete the
6. A state institution whose income is excluded from gross
income under section 115. Form and Schedules
7. A governmental unit or affiliate of a governmental unit You may find the following list helpful. It limits jumping from one
described in Rev. Proc. 95-48, 1995-2 C.B. 418. But see the part of the form to another to make a calculation or determination
filing requirements for section 509(a)(3) supporting needed to complete an earlier part. Certain later parts of the
organizations in A. Who Must File. form must first be completed in order to complete earlier parts. In
8. An organization described in section 501(c)(1). A section general, first complete the core form, and then complete
501(c)(1) organization is a corporation organized under an Act of alphabetically Schedules A–N and Schedule R, except as
Congress that is an instrumentality of the United States, and provided below. Schedule O (Form 990 or 990-EZ),
exempt from federal income taxes. Supplemental Information to Form 990, should be completed as
the core form and schedules are completed. Note that all
Certain political organizations. organizations filing Form 990 must file Schedule O.
9. A political organization that is:
A public charity described in section 170(b)(1)(A)(iv),
• A state or local committee of a political party;
• A political committee of a state or local candidate; TIP 170(b)(1)(A)(vi), or 509(a)(2) that isn't within its initial 5
years of existence should first complete Part II or III of
• A caucus or association of state or local officials; or Schedule A (Form 990 or 990-EZ) to ensure that it continues to
• Required to report under the Federal Election Campaign Act qualify as a public charity for the tax year. If it fails to qualify as a
of 1971 as a political committee (as defined in section 301(4) of
public charity, then it must file Form 990-PF rather than Form
such Act).

-4- Instructions for Form 990


990 or Form 990-EZ, and check the box for “Initial return of a is an initial return for which the “Initial return” box is checked in
former public charity” on page 1 of Form 990-PF. Item B of the Heading or a final return for which the “Final return/
terminated” box is checked in Item B of the Heading.
1. Complete Items A through F and H(a) through M in the
Accounting period change. If the organization changes its
Heading of Form 990, on page 1.
accounting period, it must file a Form 990 for the short period
2. See the instructions for definitions of related resulting from the change. Write “Change of Accounting Period”
organization and control and determine the organization's at the top of this short-period return.
related organizations required to be listed on Schedule R (Form
If the organization has previously changed its annual
990).
accounting period at any time within the 10-calendar-year period
3. Determine the organization's officers, directors, trustees, that includes the beginning of the short period resulting from
key employees, and five highest compensated employees the current change in accounting period, and it had a Form
required to be listed on Form 990, Part VII, Section A. 990-series filing requirement or income tax return filing
4. Complete Parts VIII, IX, and X of Form 990. requirement at any time during that 10-year period, it must also
5. Complete Item G in the Heading section of Form 990, on file a Form 1128, Application To Adopt, Change, or Retain a Tax
page 1. Year, with the short-period return. See Rev. Proc. 85-58, 1985-2
C.B. 740.
6. Complete Parts III, V, VII, XI, and XII of Form 990.
If an organization that submits Form 990-N changes its
7. See the Instructions for Schedule L (Form 990 or accounting period, it must report this change on Form 990, Form
990-EZ), Transactions With Interested Persons, and complete 990-EZ, or Form 1128, or by sending a letter to Internal Revenue
Schedule L (Form 990 or 990-EZ) (if required). Service, 1973 Rulon White Blvd., Ogden, UT 84201.
8. Complete Part VI of Form 990. Transactions reported on
Schedule L (Form 990 or 990-EZ) are relevant to determining Accounting Methods
independence of members of the governing body under Form Unless instructed otherwise, the organization generally should
990, Part VI, line 1b. use the same accounting method on the return (including the
9. Complete Part I of Form 990 based on information Form 990 and all schedules) to report revenue and expenses
derived from other parts of the form. that it regularly uses to keep its books and records. To be
10. Complete Part IV of Form 990 to determine which acceptable for Form 990 reporting purposes, however, the
schedules must be completed by the organization. method of accounting must clearly reflect income.
11. Complete Schedule O (Form 990 or 990-EZ) and any Accounting method change. Generally, the organization must
other applicable schedules (for “Yes” boxes that were checked file Form 3115, Application for Change in Accounting Method, to
in Part IV). Use Schedule O (Form 990 or 990-EZ) to provide change its accounting method. An exception applies where a
required supplemental information and other narrative section 501(c) organization changes its accounting method to
explanations for questions on the core Form 990. For questions comply with the Financial Accounting Standards Board (FASB)
on Form 990 schedules, use the narrative part of each schedule Accounting Standards Codification 958, Not-for-Profit Entities
to provide supplemental narrative. (ASC 958). See Notice 96-30, 1996-1 C.B. 378. An organization
12. Complete Part II, Signature Block, of Form 990. that makes a change in accounting method, regardless of
whether it files Form 3115, must report any adjustment required
D. Accounting Periods and Methods by section 481(a) in Parts VIII through XI and on Schedule D
(Form 990), Supplemental Financial Statements, Parts XI and
These are the accounting periods covered under the law. XII, as applicable.
Accounting Periods State reporting. Many states that accept Form 990 in place of
their own forms require that all amounts be reported based on
Calendar year. Use the 2019 Form 990 to report on the 2019 the accrual method of accounting. If the organization prepares
calendar year accounting period. A calendar year accounting Form 990 for state reporting purposes, it can file an identical
period begins on January 1 and ends on December 31. return with the IRS even though the return doesn't agree with the
Fiscal year. If the organization has established a fiscal year books of account, unless the way one or more items are
accounting period, use the 2019 Form 990 to report on the reported on the state return conflicts with the instructions for
organization's fiscal year that began in 2019 and ended 12 preparing Form 990 for filing with the IRS.
months later. A fiscal year accounting period should normally Example 1. The organization maintains its books on the
coincide with the natural operating cycle of the organization. Be cash receipts and disbursements method of accounting but
certain to indicate in Item A of the Heading of Form 990 the date prepares a Form 990 return for the state based on the accrual
the organization's fiscal year began in 2019 and the date the method. It could use that return for reporting to the IRS.
fiscal year ended in 2020.
Example 2. A state reporting requirement requires the
Short period. A short accounting period is a period of less than organization to report certain revenue, expense, or balance
12 months, which exists when an organization first commences sheet items differently from the way it normally accounts for
operations, changes its accounting period, or terminates. If the them on its books. A Form 990 prepared for that state is
organization's short year began in 2019, and ended before acceptable for the IRS reporting purposes if the state reporting
December 31, 2019 (not on or after December 31, 2019), it may requirement doesn't conflict with the Instructions for Form 990.
use either 2018 Form 990 or 2019 Form 990 to file for the short
year. The 2019 form also may be used for a short period An organization should keep a reconciliation of any
beginning in 2020 and ending before December 31, 2020 (not differences between its books of account and the Form 990 that
on or after December 31, 2020). When doing so, provide the is filed. Organizations with audited financial statements are
information for designated years listed on the return, other than required to provide such reconciliations on Schedule D (Form
the tax year being reported, as if they were updated on the 2020 990), Parts XI through XII.
form. For example, provide the information on Schedule A, Part
II, for the tax years 2016–2020, rather than for tax years 2015–
2019. A short period return can't be filed electronically unless it

Instructions for Form 990 -5-


See Pub. 538, Accounting Periods and Methods, and hardship. For information on filing a waiver, see Notice 2010-13,
TIP the Instructions for Forms 1128 and 3115, about 2010-4 I.R.B. 327, available at
reporting changes to accounting periods and methods. IRS.gov/irb/2010-04_IRB/ar14.html.
Electronic filing for tax years beginning on or after July 2,
E. When, Where, and How To File 2019. If you are filing a 2019 Form 990 for a tax year beginning
File Form 990 by the 15th day of the 5th month after the on or after July 2, 2019, you are required to file electronically
organization's accounting period ends (May 15th for a unless one or more of the following exceptions apply.
calendar-year filer). If the due date falls on a Saturday, Sunday, 1. The name of the organization has changed, the new
or legal holiday, file on the next business day. A business day is name is entered on Form 990, and the “Name change” box is
any day that isn't a Saturday, Sunday, or legal holiday. checked in Item B.
If the organization is liquidated, dissolved, or terminated, file 2. Form 990 is for a short period because of an accounting
the return by the 15th day of the 5th month after liquidation, period change. This does not apply if (a) the short period is an
dissolution, or termination. initial return and the “Initial return” box is checked in Item B; or
(b) the short period is for a final return, and the “Final return/
If the return isn't filed by the due date (including any extension terminated” box is checked in Item B.
granted), explain in a separate attachment, giving the reasons
3. An application for exemption is pending, and the
for not filing on time.
“Application pending” box is checked in Item B.
Send the return to: 4. Form 990 is being filed before the end of the tax year.
This does not apply if the return is a final return, and the “Final
Department of the Treasury return/terminated” box is checked in Item B.
Internal Revenue Service Center
Ogden, UT 84201-0027 5. You attempted to file Form 990 electronically, but the
return was rejected (even after you contacted your e-file
provider).
Foreign and U.S. possession organizations. If the
organization's principal business, office, or agency is located in a For exceptions 1 through 4 above, file a paper Form 990. For
foreign country or U.S. possession, send the return to: exception 5, file a paper Form 990 as prescribed in section 5.7 of
Publication 4163, Modernized e-File (MeF) Information for
Department of the Treasury Authorized IRS e-File Providers for Business Returns.
Internal Revenue Service Center For additional information on the electronic filing requirement,
P.O. Box 409101 visit IRS.gov/Filing.
Ogden, UT 84409
F. Extension of Time To File
Private delivery services. Tax-exempt organizations can use Use Form 8868, Application for Automatic Extension of Time To
certain private delivery services (PDS) designated by the IRS to File an Exempt Organization Return, to request an automatic
meet the “timely mailing as timely filing” rule for tax returns. Go to extension of time to file.
IRS.gov/PDS for the current list of designated services.
The PDS can tell you how to get written proof of the mailing
G. Amended Return/Final Return
date. To amend the organization's return for any year, file a new return
including any required schedules. Use the version of Form 990
For the IRS mailing address to use if you’re using PDS, go to applicable to the year being amended. The amended return
IRS.gov/PDSstreetAddresses. must provide all the information called for by the form and
Private delivery services can't deliver items to P.O. instructions, not just the new or corrected information. Check the
! boxes. You must use the U.S. Postal Service to mail any “Amended return” box in Item B of the Heading of the return on
CAUTION item to an IRS P.O. box address. page 1 of the form. Also, enter in Schedule O (Form 990 or
990-EZ) which parts and schedules of the Form 990 were
Electronic filing for tax years beginning before July 2, amended and describe the amendments.
2019. The organization can file Form 990 and related forms, The organization can file an amended return at any time to
schedules, and attachments electronically. However, if an change or add to the information reported on a previously filed
organization files at least 250 returns of any type during the return for the same period. It must make the amended return
calendar year ending with or within the organization's tax year available for inspection for 3 years from the date of filing or 3
and has total assets of $10 million or more at the end of the tax years from the date the original return was due, whichever is
year, it must file Form 990 electronically. “Returns” for this later.
purpose include information returns (for example, Forms W-2
and Forms 1099), income tax returns, employment tax returns If the organization needs a complete copy of its previously
(including quarterly Forms 941, Employer's Quarterly Federal filed return, it can file Form 4506, Request for Copy of Tax
Tax Return), and excise tax returns. Return.
If an organization is required to file a return electronically but If the return is a final return, the organization must check the
doesn't, the organization is considered not to have filed its “Final return/terminated” box in Item B of the Heading on page 1
return, even if a paper return is submitted, unless it is reporting a of the form, and complete Schedule N (Form 990 or 990-EZ),
name change, in which case it must file by paper and attach the Liquidation, Termination, Dissolution, or Significant Disposition
documents described in Specific Instructions, Item B. of Assets.
Checkboxes, later. See Regulations section 301.6033-4 for
more information on mandatory electronic filing of Form 990. Amended returns and state filing considerations. State law
may require that the organization send a copy of an amended
For additional information on the electronic filing requirement, Form 990 return (or information provided to the IRS
visit IRS.gov/Filing. supplementing the return) to the state with which it filed a copy of
For tax years beginning before July 2, 2019, the IRS may Form 990 to meet that state's reporting requirement. A state may
waive the requirements to file electronically in cases of undue require an organization to file an amended Form 990 to satisfy

-6- Instructions for Form 990


state reporting requirements, even if the original return was • Exempt from tax under a group exemption letter that is still
accepted by the IRS. in effect, and
• Using the same tax year as the central organization.
H. Failure-to-File Penalties
The central organization can't use a Form 990-EZ for the
Against the organization. Under section 6652(c)(1)(A), a group return.
penalty of $20 a day, not to exceed the lesser of $10,500 or 5%
of the gross receipts of the organization for the year, can be A subordinate organization may choose to file a separate
charged when a return is filed late, unless the organization annual information return instead of being included in the group
shows that the late filing was due to reasonable cause. return.
Organizations with annual gross receipts exceeding
$1,067,000 are subject to a penalty of $105 for each day failure If the central organization is required to file a return for
continues (with a maximum penalty for any one return of itself, it must file a separate return and can't be included in the
$53,000). The penalty applies on each day after the due date group return. See Regulations section 1.6033-2(d)(1). See
that the return isn't filed. Section B. Organizations Not Required To File Form 990 or
990-EZ, earlier, for a list of organizations not required to file.
Tax-exempt organizations that are required to file
electronically but don't are deemed to have failed to file the Every year, each subordinate organization must authorize the
return. This is true even if a paper return is submitted, unless the central organization in writing to include it in the group return and
organization files by paper to report a name change. must declare, under penalties of perjury, that the authorization
The penalty also can be charged if the organization files an and the information it submits to be included in the group return
incomplete return, such as by failing to complete a required line are true and complete.
item or a required part of a schedule. To avoid penalties and
having to supply missing information later: The central organization should send the annual information
• Complete all applicable line items, update required to maintain a group exemption ruling (a
• Unless instructed to skip a line, answer each question on the separate requirement from the annual return) to:
return,
Department of the Treasury
• Make an entry (including a zero when appropriate) on all lines Internal Revenue Service Center
requiring an amount or other information to be reported, and
Ogden, UT 84201-0027
• Provide required explanations as instructed.
Also, this penalty can be imposed if the organization's return For special instructions regarding answering certain Form
contains incorrect information. For example, an organization that 990 questions about parts or schedules in the context of a group
reports contributions net of related fundraising expenses can be return, see Appendix E. Group Returns–Reporting Information
subject to this penalty. on Behalf of the Group.
Use of a paid preparer doesn't relieve the organization of its
responsibility to file a complete and accurate return. J. Requirements for a Properly
Against responsible person(s). If the organization doesn't file Completed Form 990
a complete return or doesn't furnish correct information, the IRS All organizations filing Form 990 must complete Parts I through
will send the organization a letter that includes a fixed time to XII, Schedule O (Form 990 or 990-EZ), and any schedules for
fulfill these requirements. After that period expires, the person which a “Yes” response is indicated in Part IV. If an organization
failing to comply will be charged a penalty of $10 a day. The isn't required to file Form 990 but chooses to do so, it must file a
maximum penalty on all persons for failures for any one return complete return and provide all of the information requested,
shall not exceed $5,000. including the required schedules.
There are also penalties (fines and imprisonment) for willfully
not filing returns and for filing fraudulent returns and statements Public inspection. In general, all information the organization
with the IRS (see sections 7203, 7206, and 7207). States can reports on or with its Form 990, including schedules and
impose additional penalties for failure to meet their separate attachments, will be available for public inspection. Note,
filing requirements. however, the special rules for Schedule B (Form 990, 990-EZ, or
990-PF), Schedule of Contributors, a required schedule for
Automatic revocation for nonfiling for three consecutive certain organizations that file Form 990. Make sure the forms
years. The law requires most tax-exempt organizations, other and schedules are clear enough to photocopy legibly. For more
than churches, to file an annual Form 990, 990-EZ, or 990-PF information on public inspection requirements, see Appendix D.
with the IRS, or to submit a Form 990-N e-Postcard to the IRS. If Public Inspection of Returns, and Pub. 557, Tax-Exempt Status
an organization fails to file an annual return or submit a notice as for Your Organization.
required for 3 consecutive years, its tax-exempt status is
automatically revoked on and after the due date for filing its third Signature. A Form 990 isn't complete without a proper
annual return or notice. Organizations that lose their tax-exempt signature. For details, see the instructions for Part II, Signature
status may need to file income tax returns and pay income tax, Block, later.
but may apply for reinstatement of exemption. For details, go to Recordkeeping. The organization's records should be kept for
IRS.gov/EO. as long as they may be needed for the administration of any
provision of the Internal Revenue Code. Usually, records that
I. Group Return support an item of income, deduction, or credit must be kept for
A central, parent, or similar organization can file a group return a minimum of 3 years from the date the return is due or filed,
on Form 990 for two or more subordinate or local organizations whichever is later. Keep records that verify the organization's
that are: basis in property for as long as they are needed to figure the
• Affiliated with the central organization at the time its tax year basis of the original or replacement property. Applicable law and
ends, an organization's policies can require that the organization retain
• Subject to the central organization's general supervision or records longer than 3 years. Form 990, Part VI, line 14, asks
control, whether the organization has a document retention and
destruction policy.

Instructions for Form 990 -7-


The organization also should keep copies of any returns it it should file Form(s) 8868 to request a filing extension. See
has filed. They help in preparing future returns and in making Section F. Extension of Time To File, earlier. If the organization
computations when filing an amended return. is unable to obtain this information by the extended due date
after making reasonable efforts, and isn't certain of the answer to
Rounding off to whole dollars. The organization must round
a particular question, it may make a reasonable estimate, where
off cents to whole dollars on the returns and schedules, unless
applicable, and explain in Schedule O.
otherwise noted for particular questions. To round, drop
amounts under 50 cents and increase amounts from 50 to 99
cents to the next dollar. For example, $1.49 becomes $1 and
Assembling Form 990, Schedules, and
$2.50 becomes $3. If the organization has to add two or more Attachments
amounts to figure the amount to enter on a line, include cents Before filing Form 990, assemble the package of forms,
when adding the amounts and round off only the total. schedules, and attachments in the following order.
Completing all lines. Make an entry (including -0- when 1. Core form with Parts I through XII completed, filed in
appropriate) on all lines requiring an amount or other information numerical order.
to be reported. Don't leave any applicable lines blank, unless 2. Schedules, completed as applicable, filed in alphabetical
expressly instructed to skip that line. If answering a line is order (see Form 990, Part IV, for required schedules). All pages
predicated on a “Yes” answer to the preceding line, and if the of a required schedule must be submitted by Form 990 paper
organization's answer to the preceding line was “No,” then leave filers, even if the filer is only required to complete certain parts
the “If Yes” line blank. but not all of the schedule.
All filers must file Schedule O (Form 990 or 990-EZ). Certain 3. Attachments, completed as applicable. These include (a)
questions require all filers to provide an explanation in name change amendment to organizing document required by
Schedule O (Form 990 or 990-EZ). In general, answers can be Item B under Heading; (b) list of subordinate organizations
explained or supplemented in Schedule O (Form 990 or 990-EZ) included in a group return required by Item H under Heading;
if the allotted space in the form or other schedule is insufficient, (c) articles of merger or dissolution, resolutions, and plans of
or if a “Yes” or “No” answer is required but the organization liquidation or merger required by Schedule N (Form 990 or
wishes to explain its answer. 990-EZ); (d) reasonable cause explanation for a late-filed return;
Missing or incomplete parts of the form and/or required and (e) for hospital organizations only, a copy of the most
schedules may result in the IRS contacting you to obtain the recent audited financial statements.
missing information. Failure to supply the information may result Don't attach materials not authorized in the instructions or not
in a penalty being assessed to your account. For tips on filing otherwise authorized by the IRS.
complete returns, go to IRS.gov/Charities.
To facilitate the processing of your return, don't
Reporting proper amounts. Some lines request information password protect or encrypt PDF attachments.
reported on other forms filed by the organization (such as Forms !
CAUTION Password protecting or encrypting a PDF file that is
W-2, 1099, and 990-T). If the organization is aware that the attached to an e-filed return prevents the IRS from opening the
amount actually reported on the other form is incorrect, it must attachment.
report on Form 990 the information that should have been
reported on the other form (in addition to filing an amended form
with the proper amount).
In general, don't report negative numbers, but use -0- instead
Specific Instructions
of a negative number, unless the instructions otherwise provide.
Report revenue and expenses separately and don't net related
items, unless otherwise provided. Heading. Items A–M
Inclusion of activities and items of disregarded entities Complete items A through M.
and joint ventures. An organization must report on its Form Item A. Accounting period. File the 2019 return for calendar
990 all of the revenues, expenses, assets, liabilities, and net year 2019 and fiscal years that began in 2019 and ended in
assets or funds of a disregarded entity of which it is the sole 2020. For a fiscal year return, fill in the tax year space at the top
member, and must report on its Form 990 its share of all such of page 1. See General Instructions, Section D. Accounting
items of a joint venture or other investment or arrangement Periods and Methods, earlier, for additional information about
treated as a partnership for federal income tax purposes. This accounting periods.
includes passive investments. In addition, the organization
generally must report activities of a disregarded entity or a joint Item B. Checkboxes. The following checkboxes are under
venture on the appropriate parts or schedules of Form 990. For Item B.
special instructions about the treatment of disregarded entities Address change. Check this box if the organization changed
and joint ventures for various parts of the form, see Appendix F. its address and hasn't reported the change on its most recently
Disregarded Entities and Joint Ventures—Inclusion of Activities filed Form 990, 990-EZ, 990-N, or 8822-B or in correspondence
and Items. to the IRS.
Reporting information from third parties. Some lines If a change in address occurs after the return is filed, use
request information that the organization may need to obtain TIP Form 8822-B, Change of Address or Responsible
from third parties, such as compensation paid by related Party—Business, to notify the IRS of the new address.
organizations; family and business relationships between
officers, directors, trustees, key employees, and certain Name change. Check this box if the organization changed its
businesses they own or control; the organization's share of the legal name (not its “doing business as” name) and if the
income and assets of a partnership or joint venture in which it organization hasn't reported the change on its most recently filed
has an ownership interest; and certain transactions between the Form 990 or 990-EZ or in correspondence to the IRS. If the
organization and interested persons. The organization should organization changed its name, file Form 990 by paper and
make reasonable efforts to obtain this information. If it is unable attach the following documents:
to obtain certain information by the due date for filing the return,

-8- Instructions for Form 990


IF the organization is . . . THEN attach . . .
operates under a name different from its legal name, enter the
alternate name on the “Doing Business As” (DBA) line. If multiple
A corporation A copy of the amendment to the DBA names won't fit on the line, enter one on the line and enter
articles of incorporation and proof of the others on Schedule O (Form 990 or 990-EZ).
filing with the appropriate state
authority.
If the organization receives its mail in care of a third party
(such as an accountant or an attorney), enter on the street
A trust A copy of the amendment to the trust address line “C/O” followed by the third party's name and street
instrument, or a resolution to amend address or P.O. box.
the trust instrument, showing the
effective date of the change of name Include the suite, room, or other unit number after the street
and signed by at least one trustee. address. If the Post Office doesn’t deliver mail to the street
address and the organization has a P.O. box, enter the box
An unincorporated association A copy of the amendment to the
articles of association, constitution, or
number instead of the street address.
other organizing document, showing For foreign addresses, enter the information in the following
the effective date of the change of order: city or town, state or province, the name of the country,
name and signed by at least two and the postal code. Don't abbreviate the country name.
officers, trustees, or members.
If a change of address occurs after the return is filed, use
Form 8822-B, Change of Address or Responsible
Initial return. Check this box if this is the first time the Party—Business, to notify the IRS of the new address.
organization is filing a Form 990 and it hasn't previously filed a Item D. Employer identification number (EIN). Each
Form 990-EZ, 990-PF, 990-T, or 990-N. organization (including a subordinate of a central organization)
Final return/terminated. Check this box if the organization must have its own EIN. Use the EIN provided to the organization
has terminated its existence or ceased to be a section 501(a) or for filing its Form 990 and federal tax returns. An organization
section 527 organization and is filing its final return as an exempt should never use the EIN issued to another organization, even if
organization or section 4947(a)(1) trust. For example, an the organizations are related. The organization must have only
organization should check this box when it has ceased one EIN. If it has more than one and hasn't been advised which
operations and dissolved, merged into another organization, or to use, notify the:
has had its exemption revoked by the IRS. An organization that
checks this box because it has liquidated, terminated, or Department of the Treasury
dissolved during the tax year must also attach Schedule N (Form Internal Revenue Service Center
990 or 990-EZ). Ogden, UT 84201-0027
An organization must support any claim to have
liquidated, terminated, dissolved, or merged by State the numbers the organization has, the name and
!
CAUTION attaching a certified copy of its articles of dissolution or
address to which each EIN was assigned, and the address of
merger approved by the appropriate state authority. If a certified the organization's principal office. The IRS will advise the
copy of its articles of dissolution or merger isn't available, the organization which number to use.
organization must submit a copy of a resolution or resolutions of A subordinate organization that files a separate Form
its governing body approving plans of liquidation, termination, TIP 990 instead of being included in a group return must use
dissolution, or merger. its own EIN, and not that of the central organization.
Amended return. Check this box if the organization
A section 501(c)(9) voluntary employees' beneficiary
previously filed a return with the IRS for a tax year and is now
filing another return for the same tax year to amend the TIP association must use its own EIN and not the EIN of its
sponsor.
previously filed return. Enter on Schedule O (Form 990 or
990-EZ) the parts and schedules of the Form 990 that were
Item E. Telephone number. Enter a telephone number of the
amended and describe the amendments. See General
organization that members of the public and government
Instructions, Section G. Amended Return/Final Return, earlier,
personnel can use during normal business hours to obtain
for more information.
information about the organization's finances and activities. If the
Application pending. Check this box if the organization organization doesn’t have a telephone number, enter the
either has filed a Form 1023, 1023-EZ, 1024, or 1024-A, with the telephone number of an organization official who can provide
IRS and is awaiting a response, or claims tax-exempt status such information.
under section 501(a) but hasn't filed Form 1023, 1023-EZ, 1024,
or 1024-A, to be recognized by the IRS as tax-exempt. If this box Item F. Name and address of principal officer. The address
is checked, the organization must complete all parts of Form 990 provided must be a complete mailing address to enable the IRS
and any required schedules. An organization that is required to to communicate with the organization's current (as of the date
file an annual information return (Form 990 or Form 990-EZ) or this return is filed) principal officer, if necessary. If the officer
submit an annual electronic notice (Form 990-N) for a tax year prefers to be contacted at the organization's address listed in
(see General Instructions, Section A. Who Must File, earlier) Item C, enter “same as C above.” For purposes of this item,
must do so even if it hasn't yet filed a Form 1023, 1023-EZ, “principal officer” means an officer of the organization who,
1024, or 1024-A with the IRS, if it claims tax-exempt status. regardless of title, has ultimate responsibility for implementing
the decisions of the organization's governing body, or for
To qualify for tax exemption retroactive to the date of its
supervising the management, administration, or operation of the
organization or formation, an organization claiming tax-exempt
organization.
status under section 501(c) (other than 501(c)(29)) generally
must file an application for recognition of exemption (Form 1023, If a change in responsible party occurs after the return is
1023-EZ, 1024, or 1024-A) within 27 months of the end of the TIP filed, use Form 8822-B, Change of Address or
month in which it was legally organized or formed. Responsible Party—Business, to notify the IRS of the
new responsible party.
Item C. Name and address. Enter the organization's legal
name on the “Name of organization” line. If the organization

Instructions for Form 990 -9-


Item G. Gross receipts. On Form 990, Part VIII, column A, add Line 1. Describe the organization's mission or its most
line 6b (both columns (i) and (ii)), line 7b (both columns (i) and significant activities for the year, whichever the organization
(ii)), line 8b, line 9b, line 10b, and line 12, and enter the total wishes to highlight, on the summary page.
here. See the exceptions from filing Form 990 based on gross
Line 2. Check this box if the organization answered “Yes,” on
receipts and total assets as described in General Instructions,
Part IV, line 31 or 32, and complete Schedule N (Form 990 or
Sections A and B, earlier.
990-EZ), Part I or Part II.
Item H. Group returns. If the organization answers “No” to line
Line 6. Enter the number of volunteers, full-time and part-time,
H(a), it shouldn't check a box in line H(b). If the organization
including volunteer members of the organization's governing
answers “Yes” on line H(a) but “No” to line H(b), attach a list (not
body, who provided volunteer services to the organization during
on Schedule O (Form 990 or 990-EZ)) showing the name,
the reporting year. Organizations that don't keep track of this
address, and EIN of each local or subordinate organization
information in their books and records or report this information
included in the group return. Additionally, attach a list (not on
elsewhere (such as in annual reports or grant proposals) can
Schedule O) showing the name, address, and EIN of each
provide a reasonable estimate, and can use any reasonable
subordinate organization not included in the group return. See
basis for determining this estimate. Organizations can, but aren't
Regulations section 1.6033-2(d)(2)(ii). If the organization
required to, provide an explanation on Schedule O (Form 990 or
answers “Yes” on line H(a) and “Yes” to line H(b), attach a list
990-EZ) of how this number was determined, the number of
(not on Schedule O) showing the name, address, and EIN of
hours those volunteers served during the tax year, and the types
each subordinate organization included in the group return. See
of services or benefits provided by the organization's volunteers.
Regulations section 1.6033-2(d)(2)(ii). A central or subordinate
organization filing an individual return should not attach such a Line 7b. If the organization isn't required to file a Form 990-T for
list. Enter on line H(c) the four-digit group exemption number the tax year, enter “0.” If the organization hasn't yet filed Form
(GEN) if the organization is filing a group return, or if the 990-T for the tax year, provide an estimate of the amount it
organization is a central or subordinate organization in a group expects to report on Form 990-T, line 39, when it is filed.
exemption and is filing a separate return. Don't confuse the
Lines 8–19. If this is an initial return, or if the organization filed
four-digit GEN number with the nine-digit EIN number reported
Form 990-EZ or 990-PF in the prior year, leave the “Prior Year”
on Item D of the form's Heading. A central organization filing a
column blank. Use the same lines from the 2018 Form 990 to
group return must not report its own EIN in Item D, but report the
determine what to report for prior year revenue and expense
special EIN issued for use with the group return.
amounts.
If attaching a list:
• Enter the form number (“Form 990”) and tax year, Line 16a. Enter the total of (i) the fees for professional
• Enter the group exemption name and EIN, fundraising services reported in Part IX, column (A), line 11e,
• Enter the four-digit group exemption number (GEN), and and (ii) the portion of the amount reported in Part IX, column (A),
• Use the same size paper as the form. lines 5 and 6, that comprises fees for professional fundraising
services paid to officers, directors, trustees, key employees, and
Item I. Tax-exempt status. Check the applicable box. If the disqualified persons, whether or not such persons are
organization is exempt under section 501(c) (other than section employees of the organization. Exclude the latter amount from
501(c)(3)), check the second box and insert the appropriate Part I, line 15.
subsection number within the parentheses (for example, “4” for a
501(c)(4) organization). Part II. Signature Block
Item J. Website. Enter the organization's current address for its The return must be signed by the current president, vice
primary website, as of the date of filing this return. If the president, treasurer, assistant treasurer, chief accounting officer,
organization doesn’t maintain a website, enter “N/A” (not or other corporate officer (such as a tax officer) who is
applicable). authorized to sign as of the date this return is filed. A receiver,
trustee, or assignee must sign any return he or she files for a
Item K. Form of organization. Check the box describing the corporation or association. See Regulations section 1.6012-3(b)
organization's legal entity form or status under state law in its (4). For a trust, the authorized trustee(s) must sign. The
state of legal domicile. These include corporations, trusts, definition of “officer” for purposes of Part II is different from the
unincorporated associations, and other entities (for example, definition of officer (see Glossary) used to determine which
partnerships and limited liability companies). officers to report elsewhere on the form and schedules, and from
Item L. Year of formation. Enter the year in which the the definition of principal officer for purposes of the Form 990
organization was legally created under state or foreign law. If a Heading (see Glossary).
corporation, enter the year of incorporation.
Paid Preparer
Item M. State of legal domicile. For a corporation, enter the
state of incorporation (country of incorporation for a foreign Generally, anyone who is paid to prepare the return must sign
corporation formed outside the United States). For a trust or the return, list the preparer's taxpayer identification number
other entity, enter the state whose law governs the (PTIN), and fill in the other blanks in the Paid Preparer Use Only
organization's internal affairs (or the foreign country whose law area. An employee of the filing organization isn't a paid preparer.
governs for a foreign organization other than a corporation). The paid preparer must:
• Sign the return in the space provided for the preparer's
Part I. Summary signature,
Because Part I generally reports information reported • Enter the preparer information, including the preparer's PTIN,
TIP elsewhere on the form, complete Part I after the other and
parts of the form are completed. See General • Give a copy of the return to the organization.
Instructions, Section C. Sequencing List to Complete the Form Any paid preparer can apply for and obtain a PTIN online at
and Schedules, earlier. IRS.gov/PTIN or by filing Form W-12, IRS Paid Preparer Tax
Complete lines 3–5 and 7–22 by using applicable references Identification Number (PTIN) Application and Renewal.
made in Part I to other items.

-10- Instructions for Form 990


Enter the paid preparer's PTIN, not his or her social governing body, if applicable. If the organization doesn’t have
! security number (SSN), in the “PTIN” box in the paid a mission that has been adopted or ratified by its governing
CAUTION preparer's block. The IRS won't redact the paid body, enter “None.”
preparer's SSN if such SSN is entered on the paid preparer's
Line 2. Answer “Yes,” if the organization undertook any new
block. Because Form 990 is a publicly disclosable document,
significant program services prior to the end of the tax year that
any information entered in this block will be publicly disclosed
it didn’t describe in a prior year's Form 990 or 990-EZ. Describe
(see Appendix D). For more information about applying for a
these items on Schedule O (Form 990 or 990-EZ). If any are
PTIN online, visit the IRS website at IRS.gov/Taxpros.
among the activities described on Form 990, Part III, line 4, the
organization can reference the detailed description on line 4. If
Note. A paid preparer may sign original or amended returns by the organization has never filed a Form 990 or 990-EZ, answer
rubber stamp, mechanical device, or computer software “No.”
program.
Line 3. Answer “Yes,” if the organization made any significant
Paid Preparer Authorization changes prior to the end of the tax year in how it conducts its
program services to further its exempt purposes, or if the
On the last line of Part II, check “Yes” if the IRS can contact the organization ceased conducting significant program services
paid preparer who signed the return to discuss the return. This that had been conducted in a prior year. Describe these items on
authorization applies only to the individual whose signature Schedule O (Form 990 or 990-EZ).
appears in the Paid Preparer Use Only section of Form 990. It
doesn’t apply to the firm, if any, shown in that section. An organization must report new, significant program
TIP services, or significant changes in how it conducts
By checking “Yes,” to this box, the organization is authorizing program services on its Form 990, Part III, rather than in
the IRS to contact the paid preparer to answer any questions a letter to IRS Exempt Organizations Determinations (“EO
that arise during the processing of the return. The organization is Determinations”). EO Determinations no longer issues letters
also authorizing the paid preparer to: confirming the tax-exempt status of organizations that report
• Give the IRS any information missing from the return, such new services or significant changes.
• Call the IRS for information about processing the return, and
• Respond to certain IRS notices about math errors, offsets, Lines 4a–4c. All organizations must describe their
and return preparation. accomplishments for each of their three largest program
services, as measured by total expenses incurred (not including
The organization isn't authorizing the paid preparer to bind
donated services or the donated use of materials, equipment, or
the organization to anything or otherwise represent the
facilities). If there were three or fewer of such activities, describe
organization before the IRS.
each program service activity. The organization can report on
The authorization will automatically end no later than the due Schedule O (Form 990 or 990-EZ) additional activities that it
date (excluding extensions) for filing of the organization's 2020 considers of comparable or greater importance, although
Form 990. If the organization wants to expand the paid smaller in terms of expenses incurred (such as activities
preparer's authorization or revoke it before it ends, see Pub. 947, conducted with volunteer labor).
Practice Before the IRS and Power of Attorney. Code. For the 2019 tax year, leave this blank.
Expenses and grants. For each program service reported
Check “No” if the IRS should contact the organization or its
on lines 4a–4c, section 501(c)(3) and 501(c)(4) organizations
principal officer listed in Item F of the Heading rather than the
must enter total expenses included on Part IX, column (B),
paid preparer.
line 25, and total grants and allocations (if any) included within
Part III. Statement of Program Service such total expenses that were reported on Part IX, on column
(B), lines 1–3. For all other organizations, entering these
Accomplishments amounts is optional.
Check the box in the heading of Part III if Schedule O (Form 990 Revenue. For each program service, section 501(c)(3) and
or 990-EZ) contains any information pertaining to this part. Part 501(c)(4) organizations must report any revenue derived directly
III requires reporting regarding the organization's program from the activity, such as fees for services or from the sale of
service accomplishments. A program service is an activity of an goods that directly relate to the listed activity. This revenue
organization that accomplishes its exempt purpose. Examples of includes program service revenue reported on Part VIII, column
program service accomplishments can include: (A), line 2, and includes other amounts reported on Part VIII,
• A section 501(c)(3) organization's charitable activities such as lines 3–11, as related or exempt function revenue. Also include
a hospital's provision of charity care under its charity care policy, unrelated business income from a business that exploits an
a college's provision of higher education to students under a exempt function, such as advertising in a journal. For this
degree program, a disaster relief organization's provision of purpose, charitable contributions and grants (including the
grants or assistance to victims of a natural disaster, or a nursing charitable contribution portion, if any, of membership dues)
home's provision of rehabilitation services to residents; reported on Part VIII, line 1, aren't considered revenue derived
• A section 501(c)(5) labor union's conduct of collective from program services. For organizations other than section
bargaining on behalf of its members; 501(c)(3) and 501(c)(4) organizations, entering these amounts is
• A section 501(c)(6) business league's conduct of meetings for optional.
members to discuss business issues; or Description of program services. For each program
• A section 501(c)(7) social club's operation of recreational and service reported, include the following.
dining facilities for its members. • Describe program service accomplishments through specific
measurements such as clients served, days of care provided,
Don't report a fundraising activity as a program service number of sessions or events held, or publications issued.
accomplishment unless it is substantially related to the • Describe the activity's objective, for both this time period and
accomplishment of the organization's exempt purposes (other the longer-term goal, if the output is intangible, such as in a
than by raising funds). research activity.
Line 1. Describe the organization's mission as articulated in its
mission statement or as otherwise adopted by the organization's

Instructions for Form 990 -11-


• Give reasonable estimates for any statistical information if during the year, contributions of the greater of $5,000 (in
exact figures aren't readily available. Indicate that this money or property) or 2% of the amount on Form 990, Part VIII,
information is estimated. line 1h. An organization filing Schedule B can limit the
• Be clear, concise, and complete in the description. Use contributors it reports on Schedule B using this
Schedule O (Form 990 or 990-EZ) if additional space is needed. greater-than-$5,000/2% threshold only if it checks the box on
Donated services or use of equipment, materials, or Schedule A (Form 990 or 990-EZ), Part II, line 13, 16a, or 16b.
facilities. The organization can report the amount of any • A section 501(c)(3) organization didn’t meet the 331/3%
donated services, or use of materials, equipment, or facilities it support test of the regulations under sections 509(a)(1)/170(b)
received or used in connection with a specific program service, (1)(A)(vi), and received during the year contributions of $5,000
on the lines for the narrative description of the appropriate or more from any one contributor.
program service. However, don't include these amounts in • A section 501(c)(7), 501(c)(8), or 501(c)(10) organization
revenue, expenses, or grants reported on Part III, lines 4a–4e, received, during the year (a) contributions of any amount for
even if prepared according to generally accepted accounting use exclusively for religious, charitable, scientific, literary, or
principles. educational purposes, or the prevention of cruelty to children or
Public interest law firm. A public interest law firm exempt animals, or (b) contributions of $5,000 or more not exclusively
under section 501(c)(3) or section 501(c)(4) must include a list of for such purposes from any one contributor.
all the cases in litigation or that have been litigated during the • Any other organization that received, during the year,
year. For each case: contributions of $5,000 or more from any one contributor.
• Describe the matter in dispute, Don't attach substitutes for Schedule B. Parts I, II, and III
• Explain how the litigation will benefit the public generally, and of Schedule B (Form 990, 990-EZ, or 990-PF) may be
• Enter the fees sought and recovered. !
CAUTION photocopied as needed to provide adequate space for
See Rev. Proc. 92-59, 1992-2 C.B. 411. listing all contributors.
Line 4d. Other program services. Enter on Schedule O (Form
990 or 990-EZ) the organization's other program services. The Line 3. All organizations must answer this question, even if they
detailed description required for the three largest program aren't subject to a prohibition against political campaign
services need not be provided for these other program services. activities. Answer “Yes,” whether the activity was conducted
Section 501(c)(3) and 501(c)(4) organizations must report on directly or indirectly through a disregarded entity or a joint
line 4d their total revenues reported on Part VIII, column (A), venture or other arrangement treated as a partnership for
line 2, and their total expenses (including grants) reported on federal income tax purposes and in which the organization is an
Part IX, column (B), that are attributable to these other program owner.
services, and must report on Part III, line 4e, their total program Line 4. Complete only if the organization is a section 501(c)(3)
service expenses from Part III, lines 4a–4d. For all other organization. Other organizations leave this line blank. Answer
organizations, entering these amounts is optional. The “Yes,” if the organization engaged in lobbying activities or had
organization may report the non-contribution portion of a section 501(h) election in effect during the tax year. All section
membership dues on line 4d or allocate that portion among lines 501(c)(3) organizations that had a section 501(h) election in
4a–4c. effect during the tax year must complete Schedule C (Form 990
or 990-EZ), Part II-A, whether or not they engaged in lobbying
Part IV. Checklist of Required activities during the tax year.
Schedules Line 5. Answer “Yes” only if the organization is a section 501(c)
For each “Yes” answer to a question on Form 990, Part IV, (4), 501(c)(5), or 501(c)(6) organization that receives
complete the applicable schedule (or part or line of the membership dues, assessments, or similar amounts as defined
schedule). See the Glossary and instructions for the pertinent in Rev. Proc. 98-19, 1998-1 C.B. 547. Other organizations
schedules for definitions of terms and explanations that are answer “No.”
relevant to questions in this part. Line 6. Answer “Yes,” if the organization maintained at any time
The organization isn't required to answer “Yes” on a question during the organization's tax year a donor advised fund or
on Form 990, Part IV, or complete the schedule (or part of a another similar fund or account (that is, any account over which
schedule) to which the question is directed if the organization the donor or a person appointed by the donor had advisory
isn't required to provide any information in the schedule (or part privileges over the use or investment of any portion of the
of the schedule). Thus, a minimum dollar threshold for reporting account, but which isn't a donor advised fund). Examples of
information on a schedule may be relevant in determining other similar funds or accounts include, but aren't limited to, the
whether the organization must answer “Yes” on a question on types of funds or accounts described as exceptions to the
Form 990, Part IV. Glossary definition of a donor advised fund.
Line 7. Answer “Yes,” if the organization received or held any
All pages of a required schedule should be filed by Form 990 conservation easement at any time during the year, regardless
paper filers, even if the filer is only required to complete certain of how the organization acquired the easement or whether a
parts but not all of the schedule. charitable deduction was claimed by a donor of the easement.
Line 1. Answer “Yes,” if the organization is a section 501(c)(3) Line 8. Answer “Yes,” if at any time during the year the
organization that isn't a private foundation. Answer “Yes,” if the organization maintained collections of works of art,historical
organization claims section 501(c)(3) status but hasn't yet filed a treasures, and other similar assets as described in ASC
Form 1023 or Form 1023-EZ application or received a 958-360-45, whether or not the organization reported revenue
determination letter recognizing its section 501(c)(3) status. All and assets related to such collections in its financial statements.
other organizations answer “No.”
Organizations that answer “Yes” on line 8 often will
Line 2. Answer “Yes,” if any of the following are satisfied. TIP answer “Yes” on Part IV, line 30, which addresses
• A section 501(c)(3) organization met the 331/3% support test current-year noncash contributions of such items.
of the regulations under sections 509(a)(1) and 170(b)(1)(A)(vi),
checks the box on Schedule A (Form 990 or 990-EZ), Part II,
line 13, 16a, or 16b, and received from any one contributor,

-12- Instructions for Form 990


Line 9. Answer “Yes,” if at any time during the organization's tax In the case of indirect investments made through investment
year the organization (1) had an escrow or custodial account, entities, the extent to which revenue or expenses are taken into
(2) provided credit counseling services and/or debt account in determining whether the $10,000 threshold is
management plan services, such as credit repair or debt exceeded will depend upon whether the investment entity is
negotiations, or (3) acted as an agent, trustee, custodian, or treated as a partnership or corporation for U.S. tax purposes. For
other intermediary for contributions or other assets not included example, an organization with an interest in a foreign partnership
in Part X. would need to take into account its share of the partnership's
revenue and expenses in determining whether the $10,000
Line 10. Answer “Yes,” if the organization, a related threshold is exceeded. An organization with an investment in a
organization, or an organization formed and maintained foreign corporation would need to take into account dividends it
exclusively to further one or more exempt purposes of the receives from the corporation, but wouldn't need to take into
organization (such as a foundation formed and maintained account or report any portion of the revenues, expenses, or
exclusively to hold endowment funds to provide scholarships expenditures of a foreign corporation in which it holds an
and other funds for a college or university described within investment, provided that the corporation is treated as a
section 501(c)(3)), held assets in donor-restricted endowment separate corporation for U.S. tax purposes.
funds, board designated (quasi), or endowment funds at any
time during the year, whether or not the organization follows Line 15. Answer “Yes,” if the organization reported on Part IX,
ASC 958, or reports endowment fund in Part X, line 31. See column (A), line 3, more than $5,000 of grants and other
the instructions for Schedule D (Form 990), Part V, for the assistance to any foreign organization or entity (including a
definitions of these types of endowment funds. foreign government), or to a domestic organization or
domestic individual for the purpose of providing grants or other
Line 11. Answer “Yes,” if the organization reported an amount assistance to a designated foreign organization or
for land, buildings, equipment, or leasehold improvements, on organizations.
Part X, line 10; an amount for other liabilities on Part X, line 25;
or if its financial statements for the tax year included a footnote Line 16. Answer “Yes,” if the organization reported on Part IX,
that addresses its liability for uncertain tax positions under FIN column (A), line 3, more than $5,000 of aggregate grants and
48 (FASB ASC 740) (including a statement that the organization other assistance to foreign individuals, or to domestic
had no liability for uncertain tax positions). Also, answer “Yes,” if organizations or domestic individuals for the purpose of
the organization reported in Part X an amount for providing grants or other assistance to a designated foreign
investments-other securities, investments-program related, or individual or individuals.
other assets, on any of line 12,13, or 15, that is 5% or more of Lines 17–19. Answer “Yes” on line 17 if the total amount
the total assets reported on Part X, line 16. reported for professional fundraising services in Part IX
Line 12a. Answer “Yes,” if the organization received separate, (line 11e, plus the portion of the line 6 amount attributable to
independent audited financial statements for the year for professional fundraising services) exceeds $15,000.
which it is completing this return, or if the organization is Answer “Yes” on line 18 if the sum of the amounts reported
reporting for a short year that is included in, but not identical to, on lines 1c and 8a of Form 990, Part VIII, exceeds $15,000. An
the period for which the audited financial statements were organization that answers “No” should consider whether to
obtained. All other organizations answer “No.” Answer “No” if the complete Schedule G (Form 990 or 990-EZ) in order to report its
organization was included in consolidated audited financial fundraising activities or gaming activities for state or other
statements, unless the organization also received separate reporting purposes.
audited financial statements.
Line 20a. Answer “Yes,” if the organization, directly or indirectly
An accountant's compilation or review of financial through a disregarded entity or joint venture treated as a
statements isn't considered to be an audit and doesn't produce partnership for federal income tax purposes, operated one or
audited financial statements. If the organization answers “No,” more hospital facilities at any time during the tax year. Except
but has prepared, for the year for which it is completing this in the case of a group return, don't include hospital facilities
return, a financial statement that wasn't audited, the organization operated by another organization that is treated as a separate
can (but isn't required to) provide the reconciliations contained taxable or tax-exempt corporation for federal income tax
on Schedule D (Form 990), Parts XI-XII. purposes. For group returns, answer “Yes” if any subordinate
Line b. Answer “Yes,” if the organization was included in included in the group return operated such a hospital facility.
consolidated, independent audited financial statements for Line 20b. If the organization operated one or more hospital
the year for which it is completing this return. All other facilities at any time during the tax year, then it must attach a
organizations answer “No.” Answer “Yes,” if the organization is copy of its most recent audited financial statements. If the
reporting for a short year that is included in, but not identical to, organization was included in consolidated audited financial
the period for which the audited financial statements were statements but not separate audited financial statements for the
obtained. tax year, then it must attach a copy of the consolidated financial
Line 13. Answer “Yes,” if the organization checked the box on statements, including details of consolidation (whether or not
Schedule A (Form 990 or 990-EZ), Part I, line 2, indicating that it audited).
is a school. Line 21. Answer “Yes,” if the organization reported on Part IX,
Lines 14a–14b. Answer “Yes” on line 14a if the organization column (A), line 1, more than $5,000 of grants and other
maintained an office, or had employees or agents, or assistance to any domestic organization, or to any domestic
independent contractors outside the United States. Answer government. For instance, answer “No” if the organization made
“Yes,” on line 14b if the organization had aggregate revenue or a $4,000 grant to each of two domestic organizations and no
expenses of more than $10,000 from or attributable to other grants. Don't report grants or other assistance provided to
grantmaking, fundraising activities, business, investment, and domestic organizations or domestic governments for the
program service activities outside the United States, or if the purpose of providing grants or other assistance to designated
book value of the organization's aggregate investments in foreign organizations or foreign individuals.
foreign partnerships, foreign corporations, and other foreign Line 22. Answer “Yes,” if the organization reported on Part IX,
entities was $100,000 or more at any time during the tax year. column (A), line 2, more than $5,000 of aggregate grants and

Instructions for Form 990 -13-


other assistance to or for domestic individuals. Don't report prior year, and if the transaction hasn’t been reported on any of
grants or other assistance provided to or for domestic individuals the organization’s prior Forms 990 or 990-EZ.
for the purpose of providing grants or other assistance to
An excess benefit transaction can have serious
designated foreign organizations or foreign individuals.
TIP implications for the disqualified person that entered
Line 23. Answer “Yes,” if the organization: into the transaction with the organization, any
• Listed in Part VII a former officer, director, trustee, key organization managers that knowingly approved of the
employee, or highest compensated employee; or transaction, and the organization itself. A section 501(c)(3),
• Reported for any person listed in Part VII more than $150,000 501(c)(4), or 501(c)(29) organization that becomes aware that it
of reportable compensation and other compensation. may have engaged in an excess benefit transaction should
Also answer “Yes,” if, under the circumstances described in obtain competent advice regarding section 4958, pursue
the instructions to Part VII, Section A, line 5, the filing correction of any excess benefit, and take other appropriate
organization had knowledge that any person listed in Part VII, steps to protect its interests with regard to such transaction and
Section A, received or accrued compensation from an the potential impact it could have on the organization's continued
unrelated organization for services rendered to the filing exempt status. See Appendix G. Section 4958 Excess Benefit
organization. Transactions, for a discussion of section 4958, Schedule L
(Form 990 or 990-EZ), Transactions With Interested Persons,
Line 24. Lines 24a–24d involve questions regarding Part I, and Form 4720, Schedule I, regarding reporting of excess
tax-exempt bonds. All organizations must answer “Yes” or “No” benefit transactions.
on line 24a. Those organizations that answer “Yes” on line 24a
must also answer lines 24b through 24d and complete Lines 26–28. Lines 26 through 28 ask questions about loans
Schedule K (Form 990), Supplemental Information on and other receivables and payables between the organization
Tax-Exempt Bonds. Those that answer “No” to line 24a can skip and certain interested persons, and certain direct and indirect
to line 25a. business transactions between the organization and governance
Line 24a. Answer “Yes” and complete Schedule K (Form and management officials of the organization or their associated
990) for each tax-exempt bond issued by or for the benefit of businesses or family members. All organizations must answer
the organization after December 31, 2002 (including refunding these questions. The organization should review carefully the
bonds) with an outstanding principal amount of more than Instructions for Schedule L (Form 990 or 990-EZ), Parts II–IV,
$100,000 as of the last day of the organization's tax year. For before answering these questions and completing Schedule L
this purpose, bonds that have been legally defeased, and as a (Form 990 or 990-EZ).
result are no longer treated as a liability of the organization,
Line 29. The organization is required to answer “Yes” on line 29
aren't considered outstanding.
if it received during the year more than $25,000 in fair market
Line 24b. For purposes of line 24b, the organization need not value (FMV) of donations, gifts, grants, or other contributions
include the following as investments of proceeds. of property other than cash, regardless of the manner received
• Any investment of proceeds relating to a reasonably required (such as for use in a charity auction). Don't include
reserve or replacement fund as described in section 148(d). contributions of services or use of facilities.
• Any investment of proceeds properly characterized as
replacement proceeds as defined in Regulations section Line 30. The organization is required to answer “Yes” on line 30
1.148-1(c). if during the year it received as a donation, gift, grant, or other
• Any investment of net proceeds relating to a refunding contribution:
escrow as defined in Regulations section 1.148-1(b). • Any work of art, historical treasure, historical artifact,
Temporary period exceptions are described in section 148(c) scientific specimen, archeological artifact, or similar asset,
and Regulations section 1.148-2(e). For example, there is a including a fractional interest, regardless of amount or whether
3-year temporary period applicable to proceeds spent on the organization maintains collections of such items; or
expenditures for capital projects and a 13-month temporary • Any qualified conservation contributions regardless of
period applicable to proceeds spent on working capital whether the contributor claimed a charitable contribution
expenditures. deduction for such contribution.
Line 24c. For purposes of line 24c, the organization is treated
as maintaining an escrow account if such account is maintained See the Instructions for Schedule M (Form 990), Noncash
by a trustee for tax-exempt bonds issued for the benefit of the Contributions, for definitions of these terms.
organization. Lines 31–32. The organization must answer “Yes,” if it
Line 24d. Answer “Yes,” if the organization has received a liquidated, terminated, dissolved, ceased operations, or
letter ruling that its obligations were issued on behalf of a state or engaged in a significant disposition of net assets during the
local governmental unit; meets the conditions for issuing year. See the Instructions for Schedule N (Form 990 or 990-EZ)
tax-exempt bonds as set forth in Rev. Rul. 63-20, 1963-1 C.B. for definitions and explanations of these terms and transactions
24 (see Rev. Proc. 82-26, 1982-1 C.B. 476); or is a constituted or events, and a description of articles of dissolution and other
authority organized by a state or local governmental unit to issue information that must be filed with Form 990.
tax-exempt bonds in order to further public purposes (see Rev.
Note that a significant disposition of net assets may result
Rul. 57-187, 1957-1 C.B. 65). Also answer “Yes,” if the
from either an expansion or contraction of operations.
organization has outstanding qualified scholarship funding
Organizations that answer “Yes” on either of these questions
bonds under section 150(d) or bonds of a qualified volunteer fire
must also check the box in Part I, line 2, and complete
department under section 150(e).
Schedule N (Form 990 or 990-EZ), Part I or Part II.
Lines 25a–25b. Complete lines 25a and 25b only if the
Lines 33–34. The organization is required to report on
organization is a section 501(c)(3), 501(c)(4), or 501(c)(29)
Schedule R (Form 990), Related Organizations and Unrelated
organization. If the organization isn't described in section 501(c)
Partnerships, certain information regarding ownership or control
(3), 501(c)(4), or 501(c)(29), skip lines 25a and 25b and leave
of, and transactions with, its disregarded entities and
them blank. On line 25b, answer “Yes,” if the organization
tax-exempt and taxable related organizations. An organization
became aware, prior to filing this return, that it engaged in an
that answers “Yes” on line 33 or 34 must enter its disregarded
excess benefit transaction with a disqualified person in a

-14- Instructions for Form 990


entities and related organizations on Schedule R (Form 990) and can supplement their answers on other Form 990 questions on
provide specified information regarding such organizations. Schedule O.
Report disregarded entities on Schedule R, Part I; related
tax-exempt organizations on Part II; related organizations Part V. Statements Regarding Other
taxable as partnerships on Part III; and any related organizations
taxable as C or S corporations or trusts on Part IV. IRS Filings and Tax Compliance
Check the box in the heading of Part V if Schedule O (Form 990
Lines 35a–35b. If an organization was a controlled entity of
or 990-EZ) contains any information pertaining to this part.
the filing organization under section 512(b)(13) during the tax
year, the filing organization must answer “Yes” on line 35a. It See Glossary for definition of terms used in the
must answer “Yes” on line 35b and complete Schedule R, Part TIP questions in this section.
V, line 2, if it either (1) received or accrued from its controlled
entity any interest, annuities, royalties, or rent, regardless of
Some questions in this part pertain to other IRS forms.
amount, during the tax year; or (2) engaged in another type of
transaction (see Schedule R for a list of transactions) with the TIP Forms are available by downloading from the IRS
website at IRS.gov/OrderForms. Also see Appendix H.
controlled entity, if the amounts involved during the tax year for
Forms and Publications To File or Use.
that type of transaction exceeded $50,000. See the Glossary
and the Instructions for Schedule R (Form 990).
Line 1a. The organization must use Form 1096, Annual
Controlled entities are a subset of related organizations. Summary and Transmittal of U.S. Information Returns, to
Answer “No” to line 35a if the organization had no related transmit to the IRS paper Forms 1099, 1098, 5498, and W-2G,
organizations during the tax year. If the answer to line 35a is which are information returns reporting certain amounts paid or
“No,” leave line 35b blank. received by the organization. Report all such returns filed for the
Line 36. Complete line 36 only if the organization is a section calendar year ending with or within the organization's tax year. If
501(c)(3) organization and engaged in a transaction over the organization transmits any of these forms electronically, add
$50,000 during the tax year with a related organization that this number to the total reported. Examples of payments
was tax-exempt under a section other than section 501(c)(3). All requiring Form 1099 reporting include certain payments to
other organizations leave this line blank and go to line 37. See independent contractors for services rendered. Report on this
the Instructions for Schedule R (Form 990) for more information line Forms 1099, 1098, 5498, and W-2G filed by reporting
on what needs to be reported on Schedule R (Form 990), Part V, agents of the filing organization, including common paymasters
line 2. and payroll agents, for the calendar year ending with or within
the organization's tax year. Enter -0- if the organization didn't file
Line 37. Answer “Yes,” if at any time during the year the any such forms for the calendar year ending with or within its tax
organization conducted more than 5% of its activities, measured year, or if the organization is filing for a short year and no
by total gross revenue for the tax year or total assets of the calendar year ended within its tax year.
organization at the end of its tax year, whichever is greater,
through an unrelated organization that is treated as a Line 1b. Form W-2G pertains to certain gambling winnings.
partnership for federal income tax purposes, and in which the Line 1c. For more information on backup withholding for
organization was a partner or member at any time during the tax missing or incorrect names or taxpayer identification numbers,
year. The 5% test is applied on a partnership by partnership see Pub. 1281, Backup Withholding for Missing and Incorrect
basis, although direct ownership by the organization and indirect Name/TIN(s). If backup withholding rules didn't apply to the
ownership through disregarded entities or tiered entities treated organization because it didn't make a reportable payment to a
as partnerships are aggregated for this purpose. The vendor or provide reportable gaming (gambling) winnings to a
organization need not report on Schedule R (Form 990), Part VI, prize winner, then leave line 1c blank.
either (1) the conduct of activities through an organization
treated as a taxable or tax-exempt corporation for federal Line 2a. Include on this line the number of the organization's
income tax purposes, or (2) unrelated partnerships that meet employees (not the number of Forms W-2) reported on a Form
both of the following conditions. W-3 by both the filing organization and reporting agents of the
• 95% or more of the filing organization's gross revenue from filing organization, including common paymasters and payroll
the partnership for the partnership's tax year ending with or agents, for the calendar year ending with or within the filing
within the organization's tax year is described in sections 512(b) organization's tax year. Enter -0- if the organization didn't have
(1), 512(b)(2), 512(b)(3), and 512(b)(5), such as interest, any employees during the calendar year ending with or within its
dividends, royalties, rents, and capital gains (including unrelated tax year, or if the organization is filing for a short year and no
debt-financed income); and calendar year ended within its tax year.
• The primary purpose of the filing organization's investment in Line 2b. If the organization reported at least one employee on
the partnership is the production of income or appreciation of line 2a, answer whether the organization or reporting agents of
property and not the conduct of a section 501(c)(3) charitable the organization filed all required federal employment tax returns
activity such as program-related investing. (which include Form 940, Employer's Annual Federal
Line 38. Answer “Yes,” if the organization completed Unemployment (FUTA) Tax Return, and Form 941, Employer's
Schedule O (Form 990). QUARTERLY Federal Tax Return) relating to such employees.
For more information, see the discussion of employment taxes in
Schedule O (Form 990 or 990-EZ) must be completed Pub. 557. The organization may leave line 2b blank if it didn't
TIP and filed by all organizations that file Form 990. All filers report any employees on line 2a.
must provide narrative responses to certain questions
(for example, Part VI, lines 11b and 19) on Schedule O. Certain Line 3a. Check “Yes” on line 3a if the organization's total gross
filers must provide narrative responses to other questions (for income from all of its unrelated trades or businesses is
example, Part III, line 4d; Part V, line 3b; Part VI, lines 2–7b, 9, $1,000 or more for the tax year. See Pub. 598, Tax on Unrelated
12c, and 15a–b for “Yes” responses; Part VI, lines 8a–b and 10b Business Income of Exempt Organizations, for a description of
for “No” responses; Part XII, line 3b for “No” response). All filers unrelated business income and the Form 990-T filing
requirements for organizations having such income.

Instructions for Form 990 -15-


Neither Form 990-T nor Form 990 is a substitute for the charitable contributions for federal income tax purposes must
! other. Report on Form 990 items of income and expense include an explicit statement that contributions or gifts to it aren't
CAUTION that are also required to be reported on Form 990-T deductible as charitable contributions. The statement must be in
when the organization is required to file both forms. an easily recognizable format whether the solicitation is made in
written or printed form, by television or radio, or by telephone.
Line 3b. Answer “Yes,” if the organization checked “Yes” on Failure to disclose that contributions aren't deductible could
line 3a and filed Form 990-T by the time this Form 990 is filed. result in a penalty of $1,000 for each day on which a failure
Check “No” if the organization answered “Yes” on line 3a but occurs. The maximum penalty for failures by any organization,
hasn’t filed Form 990-T by the time this Form 990 is filed, even if during any calendar year, shall not exceed $10,000. See section
the organization has applied for an extension to file Form 990-T. 6710 for details. In cases where the failure to make the
If “No” on line 3b, provide an explanation on Schedule O (Form disclosure is due to intentional disregard of the law, more severe
990 or 990-EZ). penalties apply. No penalty will be imposed if the failure is due to
All tax-exempt organizations must pay estimated taxes reasonable cause.
! for their unrelated business income if they expect All organizations that qualify under section 170(c) to receive
CAUTION their tax liability to be $500 or more. Use Form 990-W,
contributions that are deductible as charitable contributions for
Estimated Tax on Unrelated Business Taxable Income for federal income tax purposes (such as domestic section 501(c)
Tax-Exempt Organizations, to compute these amounts. (3) organizations other than organizations that test for public
safety) should answer “No” on line 6a.
Line 4a. Answer “Yes,” if either (1) or (2) below applies.
Line 7. Line 7 is directed only to organizations that can receive
1. At any time during the calendar year ending with or within deductible charitable contributions under section 170(c). See
the organization's tax year, the organization had an interest in, Pub. 526, Charitable Contributions, for a description of such
or signature or other authority over, a financial account in a organizations. All other organizations should leave lines 7a
foreign country (such as a bank account, securities account, or through 7h blank and go to line 8.
other financial account); and
Lines 7a and 7b. If a donor makes a payment in excess of
a. The combined value of all such accounts was more than $75 partly as a contribution and partly in consideration for goods
$10,000 at any time during the calendar year; and or services provided by the organization, the organization
b. The accounts weren't with a U.S. military banking facility generally must notify the donor of the value of goods and
operated by a U.S. financial institution. services provided.
2. The organization owns more than 50% of the stock in any Example. A donor gives a charity $100 in consideration for a
corporation that would answer “Yes” to item 1 above. concert ticket valued at $40 (a quid pro quo contribution). In
this example, $60 would be deductible. Because the donor's
If “Yes,” electronically file FinCEN Form 114, Report of Foreign
payment exceeds $75, the organization must furnish a
Bank and Financial Accounts (FBAR) with the Department of the
disclosure statement even though the taxpayer's deductible
Treasury using the FinCEN's BSA E-Filing System. Because
amount doesn't exceed $75. Separate payments of $75 or less
FinCEN isn't a tax form, don't file it with Form 990.
made at different times of the year for separate fundraising
See www.fincen.gov for more information. events won't be aggregated for purposes of the $75 threshold.
Line 4b. Enter the name of each foreign country in which a See section 6113 and Notice 88-120, 1988-2 C.B. 454.
foreign account described on line 4a is located. Use Schedule O TIP
if more space is needed.
Line 5. Answer “Yes” on line 5a if the organization was party to Lines 7c and 7d. If the organization is required to file Form
a prohibited tax shelter transaction as described in section 8282, Donee Information Return, to report information to the IRS
4965(e) at any time during the organization's tax year. A and to donors about dispositions of certain donated property
prohibited tax shelter transaction is any listed transaction, within made within 3 years after the donor contributed the property, it
the meaning of section 6707A(c)(2), and any prohibited must answer “Yes” and indicate the number of Forms 8282 filed.
reportable transaction. A prohibited reportable transaction is a Lines 7e and 7f. If, in connection with a transfer to or for the
confidential transaction within the meaning of Regulations use of the organization, the organization directly or indirectly
section 1.6011-4(b)(3), and a transaction with contractual pays premiums on any personal benefit contract, or there is an
protection within the meaning of Regulations section 1.6011-4(b) understanding or expectation that any person will directly or
(4). For more information on prohibited tax shelter transactions, indirectly pay such premiums, the organization must report on
see IRS.gov. Form 8870, Information Return for Transfers Associated With
An organization that files Form 990 (other than a section 527 Certain Personal Benefit Contracts, the premiums it paid, and
political organization) and that is a party to a prohibited tax the premiums paid by others but treated as paid by the
shelter transaction must file Form 8886-T, Disclosure by organization. The organization must report and pay an excise
Tax-Exempt Entity Regarding Prohibited Tax Shelter tax, equal to premiums paid, on Form 4720. A personal benefit
Transaction, and also may have to file Form 4720, Return of contract generally is any life insurance, annuity, or endowment
Certain Excise Taxes Under Chapters 41 and 42 of the Internal contract that benefits, directly or indirectly, the transferor, a
Revenue Code, and pay an excise tax imposed by section 4965. member of the transferor's family, or any other person
For more information, see the Instructions for Forms 8886-T and designated by the transferor (other than an organization
4720. described in section 170(c)).
Line 7g. Form 8899, Notice of Income From Donated
Line 6. Answer “Yes” on line 6a only if the organization has Intellectual Property, must be filed by certain organizations that
annual gross receipts that are normally greater than $100,000 received a charitable gift of qualified intellectual property that
and if it solicited contributions not deductible under section 170 produces net income. The organization should check “Yes,” if it
during the tax year. provided all required Forms 8899 for the year for net income
Any fundraising solicitation (including solicitation of member produced by donated qualified intellectual property. Qualified
dues) by or on behalf of any section 501(c) or 527 organization intellectual property is any patent, copyright (other than certain
that isn't eligible to receive contributions deductible as self-created copyrights), trademark, trade name, trade secret,

-16- Instructions for Form 990


know-how, software (other than certain “canned” or If an organization makes a distribution from a donor
“off-the-shelf” software or self-created software), or similar advised fund to a donor, donor advisor, family member, or
property, or applications or registrations of such property. If the 35% controlled entity of these persons, then the
organization didn't receive a contribution of qualified intellectual transaction might be a section 4958 transaction. Such
property, leave line 7g blank. transactions include any grant, loan, compensation, or
Line 7h. A donor of (1) a motor vehicle for use on public other similar payment to these persons, as well as any
roads, (2) a boat, or (3) an airplane can't claim a charitable other payment resulting in excess benefit.
contribution deduction in excess of $500 unless the donee
organization provides the donor with a Form 1098-C, Line 10. Answer lines 10a and 10b only if the organization is
Contributions of Motor Vehicles, Boats, and Airplanes, for the exempt under section 501(c)(7).
donation (or a written acknowledgment with the same A section 501(c)(7) organization isn't exempt from
information). See the Instructions for Form 1098-C for more TIP income tax if any written policy statement, including the
information. If the organization didn't receive a contribution of a governing instrument and bylaws, allows discrimination
car, boat, airplane, or other vehicle, leave line 7h blank. on the basis of race, color, or religion.
Line 8. A sponsoring organization of a donor advised fund
must answer “Yes” if any one of its donor advised funds had However, section 501(i) allows social clubs to retain their
excess business holdings at any time during the organization's exemption under section 501(c)(7) even though their
tax year. All other organizations should leave this line blank and membership is limited (in writing) to members of a particular
go to line 9. If “Yes,” see the Instructions for Schedule C of Form religion if the social club:
4720 to determine whether the organization is subject to the 1. Is an auxiliary of a fraternal beneficiary society exempt
excess business holdings tax under section 4943 and is required under section 501(c)(8), and
to file Form 4720.
2. Limits its membership to the members of a particular
For purposes of the excise tax on excess business holdings
religion; or the membership limitation is:
under section 4943, a donor advised fund is treated as a private
foundation. a. A good-faith attempt to further the teachings or principles
of that religion, and
Line 9. Line 9 is required to be completed by sponsoring
b. Not intended to exclude individuals of a particular race or
organizations maintaining a donor advised fund. All other
color.
organizations can leave this line blank and go to line 10.
Line 9a. Answer “Yes,” if the organization made any taxable Line 10a. Enter the amount of initiation fees, capital
distributions under section 4966 during the organization's tax contributions, and unusual amounts of income included in Part
year. If “Yes,” complete and file Form 4720, Schedule K, to VIII. Statement of Revenue, line 12, Total Revenue, but not
calculate and pay the tax. included in the definition of gross receipts for section 501(c)(7)
Under section 4966, a taxable distribution includes a exemption purposes as discussed in Appendix C. However, if
distribution from a donor advised fund to an individual. A the organization is a college fraternity or sorority that charges
taxable distribution also includes a distribution from a donor membership initiation fees but not annual dues, don't include
advised fund to an estate, partnership, association, company, or such initiation fees.
corporation unless: Line 10b. Enter the amount of gross receipts included in
• The distribution is for a charitable purpose (for example, a Part VIII. Statement of Revenue, line 12, Total Revenue, derived
purpose described in section 170(c)(2)(B)), and from the general public for use of the organization's facilities, that
• The organization exercises expenditure responsibility for the is, from persons other than members or their spouses,
distribution. dependents, or guests.
The above doesn't apply to distributions to any organization Include the amount entered on line 10b of Form 990 on
described in section 170(b)(1)(A) (other than a disqualified TIP the club's Form 990-T if required to be filed. Investment
supporting organization, defined in section 4966(d)(4)), to the income earned by a section 501(c)(7) organization isn't
sponsoring organization of such donor advised fund, or to any tax-exempt income unless set aside for the following purposes:
other donor advised fund. religious, charitable, scientific, literary, educational, or
Line 9b. Answer “Yes,” if the organization made a distribution prevention of cruelty to children or animals.
from a donor advised fund to a donor, donor advisor, or
related person during the organization's tax year. For purposes If the combined amount of an organization's gross investment
of this question, a related person is any family member of the income, and other gross income from unrelated trades or
donor or donor advisor and any 35% controlled entity (as businesses, is $1,000 or more for the tax year, the organization
defined in section 4958(f)) of the donor or donor advisor. If must report the investment income, and other unrelated
“Yes,” complete and file Form 4720, Schedule L. business income, on Form 990-T.
If an organization makes a distribution from a Line 11. Answer lines 11a and 11b only if the organization is
! donor advised fund resulting from the advice of a exempt under section 501(c)(12).
CAUTION donor, donor advisor, family member, or a 35%
One of the requirements that an organization must meet to
controlled entity of any of these persons, which qualify under section 501(c)(12) is that at least 85% of its gross
distribution directly or indirectly provides a more than income consists of amounts collected from members for the sole
incidental benefit to one of such persons, section 4967 purpose of meeting losses and expenses. For purposes of
imposes a tax on (1) the person upon whose advice the section 501(c)(12), the term gross income means gross
distribution was made, (2) the beneficiary of the receipts without reduction for any cost of goods sold.
distribution, and (3) the fund manager for knowingly
agreeing to make the distribution. The persons liable for Member income for purposes of this 85% Member Income
the section 4967 tax must file Form 4720 to pay the tax. No Test is income derived directly from the members to pay for
section 4967 tax will be imposed on a distribution if a tax services that form the basis for tax exemption under section
has been imposed for the distribution under section 4958. 501(c)(12), and includes payments for purchases of water,
electricity, and telephone service. Member income doesn't
include interest income, gains from asset or security sales, or

Instructions for Form 990 -17-


dividends from another cooperative (unless that cooperative Corporation Income Tax Return, in lieu of Form 990 or 990-EZ
also is a member). for the year. However, failing the 85% Member Income Test in
Members are those individuals or entities that have the right one year doesn't cause permanent loss of tax-exempt status
to elect the governing board of the organization, are involved in under section 501(c)(12). So long as the organization's member
the operations of the organization, and receive a share of its income percentage is equal to or greater than 85% in any
excess operating revenues. subsequent tax year, the organization may file Form 990 or Form
990-EZ for that year, even if Form 1120 was filed in a prior year.
When calculating the member income percentage to
determine whether an organization meets the 85% Member Line 12. All organizations that aren't section 4947(a)(1) trusts
Income Test, the organization may exclude specific sources of are to leave line 12 blank.
income from both the numerator and the denominator of the
fraction. For example, if an organization is a corporation and it If a section 4947(a)(1) nonexempt charitable trust has no
receives an amount that qualifies as a contribution to capital taxable income under Subtitle A, its filing of Form 990 can be
under section 118, then that amount isn't included in either the used to meet its income tax return filing requirement under
numerator or the denominator because it isn't considered to be section 6012. Such a trust must, if it answers “Yes” on line 12a,
income for tax purposes. However, the payment must meet the report its tax-exempt interest received or accrued (if reporting
following conditions (see Rev. Rul. 93-16, 1993-1 C.B. 26) to under the accrual method) during the tax year on line b.
qualify as a contribution to capital: Section 4947(a)(1) trusts must complete all sections of the
• It must become a permanent part of the organization’s Form 990 and schedules that section 501(c)(3) organizations
working capital; must complete. All references to a section 501(c)(3) organization
• It must not be compensation for specific quantifiable services; on the Form 990, schedules, and instructions shall include a
• It must be bargained for; section 4947(a)(1) trust (for instance, such a trust must complete
• It must benefit the organization commensurately with its value; Schedule A (Form 990 or 990-EZ), unless expressly excepted).
and
• It must ordinarily be used in or contribute to the production of Line 13. Answer lines 13a, 13b, and 13c only if the organization
additional income. has received a loan or grant under the Department of Health and
Human Services CO-OP program.
Gross income for mutual or cooperative electric companies is
figured by excluding any income received or accrued from the Line 13a. If the organization is licensed to issue qualified
following. health plans in more than one state, check “Yes.” If the
organization is licensed to issue qualified health plans in only
1. Qualified pole rentals. one state, check “No.” In either case, report on Schedule O
2. Any provision or sale of electric energy transmission (Form 990 or 990-EZ) each state in which the organization is
services or ancillary services if the services are provided on a licensed to issue qualified health plans, the dollar amount of
nondiscriminatory, open access basis under an open access reserves each state requires the organization to maintain, and
transmission tariff; approved or accepted by the Federal Energy the dollar amount of reserves the organization maintains and
Regulatory Commission (FERC) or under an independent reports to each state.
transmission provider agreement approved or accepted by Line 13b. Report the highest dollar amount of reserves the
FERC (other than income received or accrued directly or organization is required to maintain by any of the states in which
indirectly from a member). the organization is licensed to issue qualified health plans.
3. The provision or sale of electric energy distribution Line 13c. Report the highest dollar amount of reserves the
services or ancillary services, if the services are provided on a organization maintains on hand and reports to a state in which
nondiscriminatory, open-access basis to distribute electric the organization is licensed to issue qualified health plans.
energy not owned by the mutual or electric cooperative Line 14a. Answer line 14a “Yes” if the organization received
company: any payments during the year for indoor tanning services.
a. To end-users who are served by distribution facilities not “Indoor tanning services” are services employing any electronic
owned by the company or any of its members (other than product designed to incorporate one or more ultraviolet lamps
income received or accrued directly or indirectly from a and intended for the irradiation of an individual by ultraviolet
member), or radiation, with wavelengths in air between 200 and 400
nanometers, to induce skin tanning.
b. Generated by a generation facility not owned or leased by
Line 14b. If an organization received a payment for services
the company or any of its members and which is directly
for indoor tanning services during the year, it must collect from
connected to distribution facilities owned by such company or
the recipient of the services a tax equal to 10% of the amount
any of its members (other than income received or accrued
paid for such service, whether paid by insurance or otherwise,
directly or indirectly from a member).
and remit such tax quarterly to the IRS by filing Form 720. If the
4. From any nuclear decommissioning transaction. organization filed Form 720 during the year, it should check
5. From any asset exchange or conversion transaction. “Yes” on line 14b. If it answers “No” on line 14b, it should explain
on Schedule O (Form 990 or 990-EZ) why it didn't file Form 720.
For a mutual or cooperative telephone company, gross
Line 15. See the Instructions for Form 4720, Schedule N, to
income doesn't include amounts received or accrued either from
determine if you paid to any covered employee more than $1
another telephone company for completing long distance calls to
million in remuneration or paid an excess parachute payment
or from or between the telephone company's members, from
during the year. Remuneration paid to a covered employee
qualified pole rentals, from the sale of display listings in a
includes any remuneration paid by a related organization.
directory furnished to the telephone company's members, or
from prepayment of a loan under section 306A, section 306B, or Line 16. Line 16 applies to private colleges and universities
section 311 of the Rural Electrification Act of 1936 (as in effect subject to the excise tax on net investment income under section
on January 1, 1987). 4968. All other organizations, including state colleges and
universities described in the first sentence of section 511(a)(2)
If the calculated member income percentage for a (B) are not subject to this tax, and therefore check the “No” box
TIP section 501(c)(12) organization is less than 85% for the on line 16, and go to Part VI. A private college or university will
tax year, then the organization fails to qualify for be subject to the excise tax on net investment income under
tax-exempt status for that year, and it must file Form 1120, U.S. section 4968 only if four threshold tests are met.

-18- Instructions for Form 990


1. The organization must be an eligible educational 3. More than 50% of those students must have been located
institution as defined in section 25A(f)(2). Section 25A(f)(2) in the United States.
defines “eligible educational institution” as an institution that is 4. The aggregate fair market value, at the end of the
described in section 481 of the Higher Education Act of 1965 (20 preceding tax year, of the assets not used directly in carrying out
USC 1088), as in effect on August 5, 1997, and is eligible to the organization’s exempt purpose, held by the organization and
participate in a program under Title IV of such Act (20 USCS related organizations, must be at least $500,000 per student.
sections 1070 et seq.).
2. The organization must have had at least 500 Use the worksheet below to determine whether the
tuition-paying students, based upon a daily average student organization meets the last three threshold tests above. Save
count, during the preceding tax year. this worksheet with the organization’s records.

Threshold Tests for Section 4968


1. Enter the daily average number of FTE tuition-paying students in all locations. If fewer than 500, check “No” in box 16. If 500 or more, go to line 2.
2. Enter the daily average number of FTE tuition-paying students in U.S.
3. Divide line 2 by line 1. If 50% or less, check “No” on box 16. If greater than 50%, go to line 4.
4. Enter the FMV of assets held by organization but not used directly in carrying out the organization’s $
exempt purpose.
5. Enter FMV of assets held by one or more related organizations. $
6. Total. Add lines 4 and 5. $
7. Divide line 6 by daily average number of FTE students. If less than $500,000, check “No” in box 16. If $500,000 or more, check “Yes” in box 16. $

Worksheet Line 1. To calculate the number of tuition-paying that ends with or within the preceding tax year of the
students during the preceding tax year (including for purposes of organization.
determining the number of students at a particular location), Section 4968 defines “related organization” to include only
enter the daily average number of full-time equivalent (FTE) the following organizations:
tuition-paying students attending the institution, taking part-time • Organizations that control or are controlled by the educational
tuition-paying students into account on a full-time student institution;
equivalent basis. • Organizations that are controlled by one or more of the same
If Worksheet line 1 is fewer than 500, the organization is not persons who control the educational institution;
subject to the section 4968 excise tax on net investment income. • Supported organizations (as defined in section 509(f)(3)); and
The organization should answer “No,” on line 16. If Worksheet • Supporting organizations described in section 509(a)(3) that
line 1 is 500 or more, continue to line 2. support the educational institution during the tax year.
Worksheet Line 2. Enter the number of FTE tuition-paying When calculating the fair market value of such assets of a
students included in line 1 who were located in the United States related organization, exclude (1) assets of any related
during the preceding tax year and enter it on line 2. organization to the extent that such assets are taken into
account with respect to another educational institution, and (2)
Worksheet Line 3. Divide line 2 by line 1. If 50% or less, the unless the related organization is controlled by the educational
organization is not subject to the section 4968 excise tax and the institution, or unless the related organization is a supporting
organization should answer “No” on line 16. If greater than 50%, organization of the educational institution, omit assets that are
continue to Line 4. not intended, or are not available, for the use or benefit of the
Worksheet Line 4. Calculate the fair market value (FMV) of educational institution.
the organization’s assets not used directly in carrying out the Worksheet Line 6. Add lines 4 and 5.
organization’s exempt purpose as of the end of the preceding
tax year. To determine which assets are used directly in carrying Worksheet Line 7. Divide line 6 by the daily average number
out the organization’s exempt purpose, under these instructions, of FTE students.
follow the principles of section 4942(e)(1)(A) and Regulations If line 7 is less than $500,000, the organization is not subject
section 53.4942(a)-2(c)(3). To determine the fair market value of to the section 4968 excise tax on net investment income and the
the assets, use any reasonable method as long as such method organization should answer “No” on line 16. If line 7 is $500,000
is consistently used. Under these instructions, the principles of or more, the organization is subject to section 4968 excise tax on
Regulation section 53.4942(a)-2(c)(4) will be considered to net investment income and the organization should answer
provide a reasonable method. “Yes” on line 16.
Assets held for the production of income or for
investment aren't considered to be used directly for
Part VI. Governance, Management,
!
CAUTION charitable functions even though the income from the and Disclosure
assets is used for charitable functions. It is a factual question Check the box in the heading of Part VI if Schedule O (Form 990
whether an asset is held for the production of income or for or 990-EZ) contains any information pertaining to this part. All
investment rather than used directly by the organization for organizations must complete Part VI. Use Schedule O (Form
charitable purposes. For example, an office building used to 990 or 990-EZ) to provide required supplemental information as
provide offices for employees engaged in managing endowment described in this part, and to provide any additional information
funds for the organization isn't considered an asset used for that the organization considers relevant to this part.
charitable purposes.
Part VI requests information regarding an organization's
Worksheet Line 5. Calculate the fair market value of the governing body and management, governance policies, and
assets of related organizations (as defined below) using the fair disclosure practices. Although federal tax law generally doesn't
market value of assets as of the end of the preceding tax year mandate particular management structures, operational policies,

Instructions for Form 990 -19-


or administrative practices, every organization is required to organization, if such compensation is required to be reported in
answer each question in Part VI. For example, all organizations Part VII, Section A.
must answer lines 11a and 11b, which ask about the 2. The member didn't receive total compensation
organization's process, if any, it uses to review Form 990, even exceeding $10,000 during the organization's tax year (including
though the governing body isn't required by federal tax law to a short year, regardless of whether such compensation is
review Form 990. reported in Part VII) from the organization and related
Even though the information on policies and procedures organizations as an independent contractor, other than
requested in Section B generally isn't required under the Code, reasonable compensation for services provided in the
the IRS considers such policies and procedures to generally capacity as a member of the governing body. For example, a
improve tax compliance. The absence of appropriate policies person who receives reasonable expense reimbursements and
and procedures can lead to opportunities for excess benefit reasonable compensation as a director of the organization
transactions, inurement, operation for non-exempt purposes, or doesn't cease to be independent merely because he or she also
other activities inconsistent with exempt status. Whether a receives payments of $7,500 from the organization for other
particular policy, procedure, or practice should be adopted by an arrangements.
organization depends on the organization's size, type, and 3. Neither the member, nor any family member of the
culture. Accordingly, it is important that each organization member, was involved in a transaction with the organization
consider the governance policies and practices that are most (whether directly or indirectly through affiliation with another
appropriate for that organization in assuring sound operations organization) that is required to be reported on Schedule L
and compliance with tax law. For more governance information (Form 990 or 990-EZ) for the organization's tax year.
relating to charities, see IRS.gov/Charities and click on Life 4. Neither the member, nor any family member of the
Cycle of an Exempt Organization. member, was involved in a transaction with a taxable or
tax-exempt related organization (whether directly or indirectly
Section A. Governing Body and Management through affiliation with another organization) of a type and
Line 1a. The governing body is the group of one or more amount that would be reportable on Schedule L (Form 990 or
persons authorized under state law to make governance 990-EZ) if required to be filed by the related organization.
decisions on behalf of the organization and its shareholders or
members, if applicable. The governing body is, generally Note. The independence standard for purposes of Part VI isn't
speaking, the board of directors (sometimes referred to as the same as the “absence of conflict of interest” standard for
board of trustees) of a corporation or association, or the trustee purposes of the rebuttable presumption under Regulations
or trustees of a trust (sometimes referred to as the board of section 53.4958-6, which focuses on conflicts with respect to a
trustees). particular transaction.
Enter the number, as of the end of the organization's tax year, A member of the governing body isn't considered to lack
of members of the governing body of the organization with independence merely because of the following circumstances.
power to vote on all matters that come before the governing 1. The member is a donor to the organization, regardless of
body (other than when a conflict of interest disqualifies the the amount of the contribution.
member from voting). If members of the governing body don't all 2. Religious exception: The member has taken a bona fide
have the same voting rights, explain material differences on vow of poverty and either (a) receives compensation as an
Schedule O (Form 990 or 990-EZ). agent of a religious order or a section 501(d) religious or
If the organization's governing body or governing documents apostolic organization, but only under circumstances in which
delegated authority to act on its behalf to an executive the member doesn't receive taxable income (see Rev. Rul.
committee or similar committee with broad authority to act on 77-290, 1977-2 C.B. 26 and Rev. Rul. 80-332, 1980-2 C.B. 34)
behalf of the governing body, and the committee held such or (b) belongs to a religious order that receives sponsorship or
authority at any time during the organization's tax year, describe payments from the organization or a related organization that
on Schedule O (Form 990 or 990-EZ) the composition of the don't constitute taxable income to the member.
committee, whether any of the committee's members aren't on 3. The member receives financial benefits from the
the governing body, and the scope of the committee's authority. organization solely in the capacity of being a member of the
The organization need not describe on Schedule O (Form 990 or charitable or other class served by the organization in the
990-EZ) delegations of authority that are limited in scope to exercise of its exempt function, such as being a member of a
particular areas or matters, such as delegations to an audit section 501(c)(6) organization, so long as the financial benefits
committee, investment committee, or compensation committee comply with the organization's terms of membership.
of the governing body.
Example 1. B is a voting member of the organization's board
Example. A voluntary employees' beneficiary association of directors. B is also a partner with a profits and capital interest
(VEBA) is a trust under state law. Bank B is the sole trustee of greater than 35% in a law firm, C, that charged $120,000 to the
the trust. In completing line 1a, the VEBA will report one voting organization for legal services in a court case. The transaction
member of the governing body. between C and the organization must be reported on Schedule L
Line 1b. Enter the number of independent voting members (Form 990 or 990-EZ) because it is a transaction between the
of the governing body as of the end of the organization's tax organization and an entity of which B is a more-than-35% owner,
year. A member of the governing body is considered and because the payment to C from the organization exceeded
“independent” only if all four of the following circumstances $100,000 (see the instructions for Schedule L (Form 990 or
applied at all times during the organization's tax year. 990-EZ), Part IV, regarding both factors). Accordingly, B isn't an
1. The member wasn't compensated as an officer or other independent member of the governing body because the
employee of the organization or of a related organization (see $120,000 payment must be reported on Schedule L (Form 990
the Instructions for Schedule R (Form 990)) except as provided or 990-EZ) as an indirect business transaction with B. If B were
in the religious exception discussed below. Nor was the member an associate attorney (an employee) rather than a partner with a
compensated by an unrelated organization or individual for greater-than–35% interest, and not an officer, director, trustee,
services provided to the filing organization or to a related or owner of the law firm, the transaction wouldn't affect B's status

-20- Instructions for Form 990


as an independent member of the organization's governing Business relationship. Business relationships between two
body. persons include any of the following.
Example 2. D is a voting member of both the organization's 1. One person is employed by the other in a sole
governing body and the governing body of C, a related proprietorship or by an organization with which the other is
organization. D's daughter, E, received $40,000 in taxable associated as a trustee, director, officer, or greater-than-35%
compensation as a part-time employee of C. D isn't an owner, even if that organization is tax-exempt. However, don't
independent member of the governing body, because E report a person’s employment by the filing organization as a
received compensation from C, a related organization to D, and business relationship.
the compensation was of a type (compensation to a family 2. One person is transacting business with the other (other
member of a member of C's governing body) and amount (over than in the ordinary course of either party's business on the
$10,000) that would be reportable on Schedule L (Form 990 or same terms as are generally offered to the public), directly or
990-EZ) if the related organization, C, were required to file indirectly, in one or more contracts of sale, lease, license, loan,
Schedule L (Form 990 or 990-EZ). performance of services, or other transaction involving transfers
Example 3. C was Board Chair of X school during the tax of cash or property valued in excess of $10,000 in the aggregate
year. X's bylaws designate the following as officer positions: during the organization's tax year. Indirect transactions are
Board Chair, Secretary, and Treasurer. C set the agenda for transactions with an organization with which the one person is
board of directors meetings, officiated board meetings, associated as a trustee, director, officer, or greater-than-35%
coordinated development of board policy and procedure, was an owner. Such transactions don't include charitable contributions
ex-officio member of all committees of the board, conducted to tax-exempt organizations.
weekly staff meetings, and performed teacher and staff 3. The two persons are each a director, trustee, officer, or
evaluations. X compensated C during the tax year for C's greater-than-10% owner in the same business or investment
services. This compensation was attributable to C's board and entity (but not in the same tax-exempt organization).
committee activities, and to C's non-director activities involving
staff meetings and evaluations. Because X compensated C for Ownership is measured by stock ownership (either voting
services as an officer/employee, C isn't an independent member power or value, whichever is greater) of a corporation, profits or
of the governing body. See Rev. Rul. 68-597 and Rev. Rul. capital interest in a partnership or limited liability company
57-246 for a description of the distinction between director (whichever is greater), membership interest in a nonprofit
services and officer services. organization, or beneficial interest in a trust. Ownership includes
indirect ownership (for example, ownership in an entity that has
Example 4. Same facts as in Example 3, except that the ownership in the entity in question); there may be ownership
Board Chair position wasn't designated as an officer position through multiple tiers of entities.
under X's bylaws, board resolutions, or state law. Nevertheless, Privileged relationship exception. For purposes of line 2, a
because X compensated C for non-director activities involving “business relationship” doesn't include a relationship between an
staff meetings and evaluations during the tax year, C is deemed attorney and client, a medical professional (including
to have received compensation as an employee—not as a psychologist) and patient, or a priest/clergy and penitent/
governing body member— for those activities. Therefore, C isn't communicant.
an independent member of the governing body.
Example 1. B is an officer of the organization, and C is a
Example 5. Same facts as in Example 3, except that: (1) C member of the organization's governing body. B is C's sister's
conducted only director and committee activities during the tax spouse. The organization must report that B and C have a family
year; (2) C didn't conduct staff meetings and evaluations; and (3) relationship.
X compensated C a reasonable amount for C's Board Chair
services during the tax year, but didn't provide any other Example 2. D and E are officers of the organization. D is
compensation to C in any other capacity. C's independence as a also a partner in an accounting firm with 300 partners (with a
1/300 interest in the firm's profits and capital) but isn't an officer,
Board member isn't compromised by receiving compensation
from X as a Board member (and not as an officer or employee). director, or trustee of the accounting firm. D's accounting firm
Also see Examples 2 and 3 in the instructions for Part VII, provides services to E in the ordinary course of the accounting
Section A, line 5, later. firm's business, on terms generally offered to the public, and
Reasonable effort. The organization need not engage in receives $100,000 in fees during the year. The relationship
more than a reasonable effort to obtain the necessary between D and E isn't a reportable business relationship, either
information to determine the number of independent voting because (1) it is in the ordinary course of business on terms
members of its governing body and can rely on information generally offered to the public, or (2) D doesn't hold a
provided by such members. For instance, the organization can greater-than-35% interest in the accounting firm's profits or
rely on information it obtains in response to a questionnaire sent capital.
annually to each member of the governing body that includes the Example 3. F and G are trustees of the organization. F is the
member's name and title, blank lines for the member's signature owner and CEO of an automobile dealership. G purchased a
and signature date, and the pertinent instructions and definitions $45,000 car from the dealership during the organization's tax
for line 1b, to determine whether the member is or isn't year in the ordinary course of the dealership's business, on
independent. terms generally offered to the public. The relationship between F
Line 2. Answer “Yes,” if any of the organization's current and G isn't a reportable business relationship because the
officers, directors, trustees, or key employees, as reported transaction was in the ordinary course of business on terms
in Part VII, Section A, had a family relationship or business generally offered to the public.
relationship with another of the organization's current officers, Example 4. H and J are members of the organization's
directors, trustees, or key employees, as reported in Part VII, board of directors. Both are CEOs of publicly traded
Section A, at any time during the organization's tax year. For corporations and serve on each other's boards. The relationship
each family and business relationship, identify the persons and between H and J is a reportable business relationship because
describe their relationship on Schedule O (Form 990 or 990-EZ). each is a director or officer in the same business entity.
It is sufficient to enter “family relationship” or “business Example 5. K is an officer of the organization, and L is on its
relationship” without greater detail. board of directors. L is a greater-than-35% partner of a law firm

Instructions for Form 990 -21-


that charged $60,000 during the organization's tax year for legal • The provisions to amend the organizing or enabling document
services provided to K that were worth $600,000 at the law firm's or bylaws;
ordinary rates. Thus, the ordinary course of business exception • The quorum, voting rights, or voting approval requirements of
doesn't apply. However, the relationship between K and L isn't a the governing body members or the organization's stockholders
reportable business relationship because of the privileged or membership;
relationship of attorney and client. • The policies or procedures contained within the organizing
Reasonable effort. The organization isn't required to provide documents or bylaws regarding compensation of officers,
information about a family or business relationship between two directors, trustees, or key employees, conflicts of interest,
officers, directors, trustees, or key employees if it is unable whistleblowers, or document retention and destruction; and
to secure the information after making a reasonable effort to • The composition or procedures contained within the
obtain it. An example of a reasonable effort would be for the organizing document or bylaws of an audit committee.
organization to distribute a questionnaire annually to each such Example. Organization X has a written conflicts of interest
person that includes the name and title of each person reporting policy that isn't contained within the organizing document or
information, blank lines for those persons' signatures and bylaws. The policy is changed by board resolution. The policy
signature dates, and the pertinent instructions and definitions for change doesn't need to be reported on line 4.
line 2.
Examples of insignificant changes made to organizing or
Line 3. Answer “Yes,” if at any time during the organization's tax enabling documents or bylaws that aren't required to be reported
year the organization used a management company or other here include changes to the organization's registered agent with
person (other than persons acting in their capacities as officers, the state and to the required or permitted number or frequency of
directors, trustees, or key employees) to perform any governing body or member meetings.
management duties customarily performed by or under the Describe significant changes on Schedule O (Form 990 or
direct supervision of officers, directors, trustees, or key 990-EZ), but don't attach a copy of the amendments or amended
employees. Such management duties include, but aren't limited document to Form 990 (or recite the entire amended document
to, hiring, firing, and supervising personnel, planning or verbatim), unless such amended documents reflect a change in
executing budgets or financial operations, or supervising exempt the organization's name. See Specific Instructions, Heading,
operations or unrelated trades or businesses of the organization. Item B, regarding attachments required in the event of a change
Management duties don't include administrative services (such in the organization's name.
as payroll processing) that don't involve significant managerial
decision making. Management duties also don't include An organization must report significant changes to its
investment management unless the filing organization conducts TIP organizational documents on Form 990, Part VI, rather
investment management services for others. than in a letter to EO Determinations. EO Determinations
If “Yes,” on Schedule O list the name(s) of the management no longer issues letters confirming the tax-exempt status of
company or companies or other person(s) performing organizations that report significant changes to their
management duties; describe the services they provided to the organizational documents, though it will, on request, issue an
organization; list any of the organization’s current or former affirmation letter confirming an organization's name change. The
officers, directors, trustees, key employees, and highest IRS will no longer require a new exemption application from a
compensated employees listed in Part VII, Section A, who domestic section 501(c) organization that undergoes certain
were compensated by the management company or companies changes of form or place of organization described in Rev. Proc.
or other person(s) during the calendar year ending with or within 2018-15, 2018-9 I.R.B. 379.
the organization's tax year; and list the amounts of reportable
Line 5. Answer “Yes,” if the organization became aware during
and other compensation they received from the management
the organization's tax year of a significant diversion of its assets,
company or companies or other person(s) for services provided
whether or not the diversion occurred during the year. If “Yes,”
to the filing organization and related organizations during that
explain the nature of the diversion, dollar amounts and/or other
year.
property involved, corrective actions taken to address the
Line 4. The organization must report significant changes to its matter, and pertinent circumstances on Schedule O (Form 990
organizing or enabling document by which it was created or 990-EZ), although the person or persons who diverted the
(articles of incorporation, association, or organization; trust assets shouldn't be identified by name.
instrument; constitution; or similar document), and to its rules A diversion of assets includes any unauthorized conversion
governing its affairs commonly known as bylaws (or regulations, or use of the organization's assets other than for the
operating agreement, or similar document). Report significant organization's authorized purposes, including but not limited to
changes that weren't reported on any prior Form 990, and that embezzlement or theft. Report diversions by the organization's
were made before the end of the tax year. Don't report changes officers, directors, trustees, employees, volunteers,
to policies described or established outside of the organizing or independent contractors, grantees (diverting grant funds), or
enabling document and bylaws (or similar documents), such as any other person, even if not associated with the organization
adoption of, or change to, a policy adopted by resolution of the other than by the diversion. A diversion of assets doesn't include
governing body that doesn't entail a change to the organizing an authorized transfer of assets for FMV consideration, such as
document or bylaws. to a joint venture or for-profit subsidiary in exchange for an
Examples of significant changes to the organizing or enabling interest in the joint venture or subsidiary. For this purpose, a
document or bylaws include changes to: diversion is considered significant if the gross value of all
• The organization's exempt purposes or mission; diversions (not taking into account restitution, insurance, or
• The organization’s name (also see the instructions for similar recoveries) discovered during the organization's tax year
Specific Instructions, Heading, Item B); exceeds the lesser of (1) 5% of the organization's gross receipts
• The number, composition, qualifications, authority, or duties for its tax year, (2) 5% of the organization's total assets as of the
of the governing body's voting members; end of its tax year, or (3) $250,000.
• The number, composition, qualifications, authority, or duties
of the organization's officers or key employees; Note. A diversion of assets can in some cases be inurement of
• The role of the stockholders or membership in governance; the organization's net earnings. In the case of section 501(c)(3),
• The distribution of assets upon dissolution; 501(c)(4), and 501(c)(29) organizations, it can also be an

-22- Instructions for Form 990


excess benefit transaction taxable under section 4958 and employees. The organization can use its official mailing
reportable on Schedule L (Form 990 or 990-EZ). address stated on the first page of Form 990 as the mailing
address for such persons. Otherwise, enter on Schedule O
Line 6. Answer “Yes,” if the organization is organized as a stock
(Form 990 or 990-EZ) the mailing addresses for such persons
corporation, a joint-stock company, a partnership, a joint
that are to be contacted at a different address. Such information
venture, or a limited liability company. Also answer “Yes,” if the
will be available to the public.
organization is organized as a non-stock, nonprofit, or
not-for-profit corporation or association with members. For
purposes of Form 990, Part VI, member means (without regard Section B. Policies
to what a person, including a corporation or other legal entity, is Answer “Yes” to any question in this section that asks whether
called in the governing documents) any person who, pursuant to the organization had a particular policy or practice only if the
a provision of the organization's governing documents or organization's governing body (or a committee of the governing
applicable state law, has the right to participate in the body, if the governing body delegated authority to that
organization's governance or to receive distributions of income committee to adopt the policy) adopted the policy by the end of
or assets from the organization. Members don't include its tax year, and if the policy applied to the organization as a
governing body members. For purposes of Part VI, a whole. If the policy applied only on a division-wide or
membership organization includes members with the following department-wide level, answer “No.” The organization may
kinds of rights. explain the scope of such policy on Schedule O.
1. The members elect the members of the governing body
Line 10a. Answer “Yes,” if the organization had during its tax
(but not if the persons on the governing body are the
year any local chapters, local branches, local lodges, or other
organization's only members) or their delegates.
similar local units or affiliates over which the organization had
2. The members approve significant decisions of the the legal authority to exercise direct or indirect supervision and
governing body. control (whether or not in a group exemption) and local units
3. The members can receive a share of the organization's that aren't separate legal entities under state law over which the
profits or excess dues or a share of the organization's net assets organization had such authority. An affiliate or unit is considered
upon the organization's dissolution. “local” for this purpose if it is responsible for a smaller
geographical area than the filing organization is responsible for.
Describe on Schedule O (Form 990 or 990-EZ) the classes of Thus, a regional organization would be considered local for a
members or stockholders with the rights described above. national organization.
Line 7a. Answer “Yes” on line 7a if at any time during the Example 1. X is a national organization dedicated to the
organization's tax year there were one or more persons (other reform of K. X has affiliates in 15 states that conduct activities to
than the organization's governing body itself, acting in such carry out the purposes of X at the state level. X has the authority
capacity) that had the right to elect or appoint one or more to approve the annual budget of each affiliate. X must answer
members of the organization's governing body, whether “Yes” on line 10a.
periodically, or as vacancies arise, or otherwise. If “Yes,”
describe on Schedule O (Form 990 or 990-EZ) the class or Example 2. Y is a section 170(b)(1)(A)(iii) hospital located in
classes of such persons and the nature of their rights. M City. Y appoints a majority of the board of directors of Z, a
section 509(a)(3) supporting organization that invests funds and
Line 7b. Answer “Yes” on line 7b if at any time during the makes grants for the benefit of Y. Although Y controls Z, Z isn't a
organization's tax year any governance decisions of the local affiliate of Y that would require Y to answer “Yes” on
organization were reserved to (or subject to approval by) line 10a.
members, stockholders, or persons other than the governing
body, whether or not any such governance decisions were Line 10b. Written policies and procedures governing the
made during the tax year, such as approval of the governing activities of local chapters, branches, and affiliates to ensure
body's election or removal of members of the governing body, or their operations are consistent with the organization's
approval of the governing body's decision to dissolve the tax-exempt purposes are documents used by the organization
organization. If “Yes,” describe on Schedule O (Form 990 or and its local units to address the policies, practices, and
990-EZ) the class or classes of such persons, the decisions that activities of the local unit. Such policies and procedures can
require their approval, and the nature of their voting rights. include policies and procedures similar to those described in
lines 11–16 of this section, whether separate or included as
Line 8. Answer “Yes” on lines 8a and 8b if the organization required provisions in the chapter's articles of organization or
contemporaneously documented by any means permitted by bylaws, a manual provided to chapters, a constitution, or similar
state law every meeting held and written action taken during the documents. If “No,” explain on Schedule O (Form 990 or
organization's tax year by its governing body and committees 990-EZ) how the organization ensures that the local unit's
with authority to act on behalf of the governing body (which activities are consistent with the organization's tax-exempt
ordinarily don't include advisory boards). Documentation purposes.
permitted by state law can include approved minutes, email, or
similar writings that explain the action taken, when it was taken, Note. The central organization (parent organization) named in
and who made the decision. For this purpose, contemporaneous a group exemption letter is required to have general
means by the later of (1) the next meeting of the governing body supervision or control over its subordinate organizations as a
or committee (such as approving the minutes of the prior condition of the group exemption.
meeting) or (2) 60 days after the date of the meeting or written
Line 11a. Answer “Yes” only if a complete copy of the
action. If the answer to either line 8a or 8b is “No,” explain on
organization's final Form 990 (including all required schedules),
Schedule O (Form 990 or 990-EZ) the organization's practices
as ultimately filed with the IRS, was provided to each person
or policies, if any, regarding documentation of meetings and
who was a voting member of the governing body at the time
written actions of its governing body and committees with
the Form 990 was provided, whether in paper or electronic form,
authority to act on its behalf. If the organization had no
before its filing with the IRS. The organization can answer “Yes”
committees, answer “No” to line 8b.
if it emailed all of its governing body members a link to a
Line 9. The IRS needs a current mailing address to contact the password-protected website on which the entire Form 990 can
organization's officers, directors, trustees, or key be viewed, and noted in the email that the Form 990 is available

Instructions for Form 990 -23-


for review on that site. However, answer “No” if the organization should include an explanation of which persons are covered
merely informed its governing body members that a copy of the under the policy, the level at which determinations of whether a
Form 990 is available upon request. Answer “No” if the conflict exists are made, and the level at which actual conflicts
organization redacted or removed any information from the copy are reviewed. Also explain any restrictions imposed on persons
of its final Form 990 that it provided to its governing body with a conflict, such as prohibiting them from participating in the
members before filing the form. For example, answer “No” if the governing body's deliberations and decisions in the
organization, at the request of a donor, redacted the name and transaction.
address of that donor from the copy of its Form 990, Schedule B,
Lines 13 and 14. A whistleblower policy encourages staff and
that it provided to its governing body members. Under those
volunteers to come forward with credible information on illegal
circumstances, the organization may explain on Schedule O why
practices or violations of adopted policies of the organization,
it answered “No” to line 11a.
specifies that the organization will protect the individual from
Line 11b. Describe on Schedule O (Form 990 or 990-EZ) the retaliation, and identifies those staff or board members or
process, if any, by which any of the organization's officers, outside parties to whom such information can be reported. A
directors, trustees, board committee members, or document retention and destruction policy identifies the record
management reviewed the prepared Form 990, whether before retention responsibilities of staff, volunteers, board members,
or after it was filed with the IRS, including specifics about who and outsiders for maintaining and documenting the storage and
conducted the review, when they conducted it, and the extent of destruction of the organization's documents and records.
any such review. If no review was or will be conducted, enter “No
review was or will be conducted.” Certain federal or state laws provide protection against
Example. The return preparer emails a copy of the final TIP whistleblower retaliation and prohibit destruction of
version of Form 990 to each Board member before it was filed. certain documents. For instance, while the federal
However, no Board member undertakes any review of the form Sarbanes-Oxley legislation generally doesn't pertain to
either before or after filing. Because such a copy of the final tax-exempt organizations, it does impose criminal liability on
version of the form was provided to each voting member of the tax-exempt as well as other organizations for (1) retaliation
organization's governing body before it was filed, the against whistleblowers that report federal offenses, and (2) for
organization can answer “Yes” even though no review took destruction of records with the intent to obstruct a federal
place. The organization must describe its Form 990 review investigation. See 18 U.S.C. sections 1513(e) and 1519. Also
process (or lack thereof) on Schedule O (Form 990 or 990-EZ). note that an organization is required to keep books and records
relevant to its tax exemption and its filings with the IRS. Some
Line 12a. Answer “Yes,” if as of the end of the organization's tax states provide additional protection for whistleblowers.
year the organization had a written conflict of interest policy.
A conflict of interest policy defines conflicts of interest, identifies Line 15. Answer “Yes” on line 15a if, during the tax year, the
the classes of individuals within the organization covered by the organization (not a related organization or other third party)
policy, facilitates disclosure of information that can help identify used a process for determining compensation (reported on
conflicts of interest, and specifies procedures to be followed in Part VII or Schedule J (Form 990)) of the CEO, executive
managing conflicts of interest. A conflict of interest arises when a director, or other person who is the top management official,
person in a position of authority over an organization, such as an that included all of the following elements.
officer, director, manager, or key employee can benefit
financially from a decision he or she could make in such • Review and approval by a governing body or compensation
capacity, including indirect benefits such as to family members committee, provided that persons with a conflict of interest
or businesses with which the person is closely associated. For regarding the compensation arrangement at issue weren't
this purpose, a conflict of interest doesn't include questions involved. For purposes of this question, a member of the
involving a person's competing or respective duties to the governing body or compensation committee has a conflict of
organization and to another organization, such as by serving on interest regarding a compensation arrangement if any of the
the boards of both organizations, that don't involve a material following circumstances apply.
financial interest of, or benefit to, such person. 1. The member (or a family member of the member) is
participating in or economically benefitting from the
Example. B is a member of the governing body of X Charity
compensation arrangement.
and of Y Charity, both of which are section 501(c)(3) public
charities with different charitable purposes. X Charity has taken 2. The member is in an employment relationship subject to
a public stand in opposition to a specific legislative proposal. At the direction or control of any person participating in or
an upcoming board meeting, Y Charity will consider whether to economically benefitting from the compensation arrangement.
publicly endorse the same specific legislative proposal. While B 3. The member receives compensation or other payments
may have a conflict of interest in this decision, the conflict subject to approval by any person participating in or
doesn't involve a material financial interest of B's merely as a economically benefitting from the compensation arrangement.
result of Y Charity's position on the legislation. 4. The member has a material financial interest affected by
Line b. Answer “Yes,” if the organization's officers, directors, the compensation arrangement.
trustees, and key employees are required to disclose or 5. The member approves a transaction providing economic
update annually (or more frequently) information regarding their benefits to any person participating in the compensation
interests and those of their family members that could give rise arrangement, who in turn has approved or will approve a
to conflicts of interest, such as a list of family members, transaction providing economic benefits to the member. See
substantial business or investment holdings, and other Regulations section 53.4958-6(c)(1)(iii).
transactions or affiliations with businesses and other • Use of data as to comparable compensation for similarly
organizations and those of family members. qualified persons in functionally comparable positions at
Line 12c. If “Yes” on line 12c, describe on Schedule O (Form similarly situated organizations.
990 or 990-EZ) the organization's practices for monitoring • Contemporaneous documentation and recordkeeping for
proposed or ongoing transactions for conflicts of interest and deliberations and decisions regarding the compensation
dealing with potential or actual conflicts, whether discovered arrangement.
before or after the transaction has occurred. The description

-24- Instructions for Form 990


Answer “Yes” on line 15b if the process for determining Some states require or permit the filing of Form 990 to
compensation of one or more officers or key employees other TIP fulfill state exempt organization or charitable solicitation
than the top management official included all of the elements reporting requirements.
listed above.
If the answer was “Yes” on line 15a or 15b, describe the Line 18. Check the box for “Own website” only if the
process on Schedule O (Form 990 or 990-EZ), identify the organization posted an exact reproduction (other than for
offices or positions for which the process was used to establish information permitted by law to be withheld from public
compensation of the persons who served in those offices or disclosure, such as the names and addresses of contributors
positions, and enter the year in which this process was last listed on Form 990, Schedule B) of its Form 990, Form 990-T (for
undertaken for each such person. section 501(c)(3) organizations), or application for recognition of
exemption (Form 1023, 1023-EZ, 1024, or 1024-A) on its
If the organization didn't compensate its CEO, executive website during its tax year. Check the box for “Another's
director, or top management official during the tax year, answer website” only if the organization provided to another individual or
“No” to line 15a. If the organization didn't compensate any of its organization and that other individual or organization posted on
other officers or key employees during the tax year, even if such its website, an exact reproduction (other than for information
employees were compensated by a related organization, answer permitted by law to be withheld from public disclosure, such as
“No” to line 15b. the names and addresses of contributors listed on Form 990,
Line 16. Answer “Yes” on line 16a if at any time during its tax Schedule B) of any such forms during the tax year.
year the organization invested in, contributed assets to, or If “Other” is checked, explain on Schedule O (Form 990 or
otherwise participated in a joint venture or similar arrangement 990-EZ). Also explain on Schedule O (Form 990 or 990-EZ) if
with one or more taxable persons. For purposes of line 16, a joint the organization didn't make publicly available upon request any
venture or similar arrangement (or a “venture or arrangement”) of Forms 1023, 1023-EZ, 1024, 1024-A, 990, or 990-T that are
means any joint ownership or contractual arrangement through subject to public inspection requirements. Exempt organizations
which there is an agreement to jointly undertake a specific must make available for public inspection their Form 1023,
business enterprise, investment, or exempt-purpose activity 1023-EZ, 1024, or 1024-A application for recognition of
without regard to (1) whether the organization controls the exemption. Applications filed before July 15, 1987, need not be
venture or arrangement, (2) the legal structure of the venture or made publicly available unless the organization had a copy on
arrangement, or (3) whether the venture or arrangement is July 15, 1987. Organizations that file Form 990 must make it
treated as a partnership for federal income tax purposes, or as publicly available for a period of three years from the date it is
an association, or corporation for federal income tax purposes. required to be filed (including extensions) or, if later, is actually
Disregard ventures or arrangements that meet both of the filed. Organizations aren't required to make publicly available the
following conditions. names and addresses of contributors (as set forth on
1. 95% or more of the venture's or arrangement's income for Schedule B (Form 990, 990-EZ, or 990-PF), and on Form 1023,
its tax year ending with or within the organization's tax year is 1023-EZ, 1024, or 1024-A). Section 501(c)(3) organizations that
described in section 512(b)(1)–(5) (including unrelated file Form 990-T are also required to make their Form 990-T
debt-financed income). publicly available for the corresponding three-year period for
forms filed after August 17, 2006 (unless the form was filed
2. The primary purpose of the organization's contribution to,
solely to request a refund of telephone excise taxes). See
or investment or participation in, the venture or arrangement is
the production of income or appreciation of property. Appendix D for more information on public inspection
requirements.
Answer “Yes” on line 16b if, as of the end of the organization's
Line 19. Explain on Schedule O (Form 990 or 990-EZ) whether
tax year, the organization had both:
the organization made its governing documents (for example,
1. Followed a written policy or procedure that required the articles of incorporation, constitution, bylaws, trust instrument),
organization to negotiate, in its transactions and arrangements conflict of interest policy, and financial statements (whether
with other members of the venture or arrangement, such terms or not audited) available to the general public during the tax
and safeguards as are adequate to ensure that the year, and if so, how it made them available to the public (for
organization's exempt status is protected, and example, posting on the organization's website, posting on
2. Taken steps to safeguard the organization's exempt another website, providing copies on request, inspection at an
status for the venture or arrangement. office of the organization, etc.). If the organization didn't make
any of these documents available to the public, enter “No
Some examples of safeguards include the following. documents available to the public.”
• Control over the venture or arrangement sufficient to ensure
that the venture furthers the exempt purpose of the organization. Federal tax law doesn't require that such documents be made
publicly available unless they were included on a form that is
• Requirements that the venture or arrangement give priority to
exempt purposes over maximizing profits for the other publicly available (such as Form 1023, 1023-EZ, 1024, or
participants. 1024-A).
• The venture or arrangement not engage in activities that Line 20. Provide the name of the person who possesses the
would jeopardize the organization's exemption (such as political organization's books and records, and the business address and
intervention or substantial lobbying for a section 501(c)(3) telephone number of such person (or of the organization if the
organization). books and records are kept by such person at a personal
• All contracts entered into with the organization be on terms residence). If the books and records are kept at more than one
that are at arm's length or more favorable to the organization. location, provide the name, business address, and telephone
number of the person responsible for coordinating the
Section C. Disclosure maintenance of the books and records. The organization isn't
required to provide the address or telephone number of a
Line 17. List the states with which a copy of this Form 990 is
personal residence of an individual. If provided, however, such
required to be filed, even if the organization hasn't yet filed Form
information will be available to the public.
990 with that state. Use Schedule O (Form 990 or 990-EZ) if
additional space is necessary.

Instructions for Form 990 -25-


Part VII. Compensation of Officers, Section A. Officers, Directors, Trustees, Key
Employees, and Highest Compensated
Directors, Trustees, Key Employees, Employees
Highest Compensated Employees, Overview. Organizations are required to enter in Part VII,
and Independent Contractors Section A, the following officers, directors, trustees, and
employees of the organization whose reportable
Check the box in the heading of Part VII if Schedule O (Form compensation from the organization and related
990 or 990-EZ) contains any information pertaining to this part. organizations (as explained in the Glossary and the
Overview. Form 990, Part VII, requires the listing of the Instructions for Schedule R (Form 990)), exceeded the following
organization's current or former officers, directors, trustees, thresholds for the tax year.
key employees, and highest compensated employees, and • Current officers, directors, and trustees (no minimum
current independent contractors, and reporting of certain compensation threshold).
compensation information relating to such persons. • Current key employees (over $150,000 of reportable
All organizations are required to complete Part VII, and when compensation).
applicable, Schedule J (Form 990), for certain persons. • Current five highest compensated employees other than
Compensation must be reported for the calendar year ending officers, directors, trustees, or listed key employees (over
with or within the organization's tax year. In some cases, $100,000 of reportable compensation).
persons are reported in Part VII or Schedule J (Form 990) only if • Former officers, key employees, and highest compensated
their reportable compensation (as explained below) and employees (over $100,000 of reportable compensation, with
“other compensation” (as explained below) from the organization special rules for former highest compensated employees).
and related organizations (as explained in the Glossary and in • Former directors and trustees (over $10,000 of reportable
the Instructions for Schedule R (Form 990)) exceeds certain compensation in the capacity as a former director or trustee).
thresholds. In some cases, compensation from an unrelated Special rules apply to disregarded entities of which the
organization must be reported on Form 990. See the organization is the sole member. See instructions for
instructions for Part VII, Section A, line 5, later. The amount of Disregarded Entities, later.
compensation reported on Form 990, Part VII, for a listed person
To determine which persons are current or former officers,
may differ from the amount reported on Form 990, Part IX, line 5,
directors, trustees, key employees, or highest compensated
for that person due to factors such as a different accounting
employees, see the instructions for Part VII, Section A, column
period (calendar vs. fiscal year) or a different accounting
(C), later.
method.
Form 990, Part VII, relies on definitions of reportable Order of Reporting. List the persons required to be included in
compensation and other compensation. Reportable Part VII, Section A, in order from highest to lowest compensation
compensation generally refers to compensation reported on based on the sum of columns (D), (E), and (F) for each person.
Form W-2, box 1 or 5 (whichever amount is greater); and Form [When the amount of total compensation is the same, list the
1099-MISC, boxes 6 and 7. Organizations must also report other person in the following order: individual trustees or directors,
compensation in Part VII, as discussed in the instructions to Part institutional trustees, officers, key employees, highest
VII, Section A, column (F), later. compensated employees, and former such persons.
Organizations must report compensation for both current and Fiscal year filers. To determine which persons are listed in
former officers, directors, trustees, key employees, and highest Part VII, Section A, the organization must use the calendar year
compensated employees. The distinction between current and ending with or within the organization's fiscal year for some
former such persons is discussed below. The determination of (those whose compensation must exceed minimum thresholds
“former” uses a 5-year look-back period. in order to be reported) and the fiscal year for others. Report
officers, directors, and trustees that served at any time during
Organizations must report compensation from themselves
the fiscal year as “current” officers, directors, and trustees.
and from related organizations, which generally consist of
Report the following persons based on reportable
parents, subsidiaries, brother/sister organizations, supporting
compensation and status for the calendar year ending within
organizations, supported organizations, sponsoring
the fiscal year.
organizations of voluntary employees' beneficiary associations
(VEBAs), and contributing employers to VEBAs. See the • Current key employees (over $150,000 of reportable
compensation from the organization and related
Instructions for Schedule R (Form 990) for a fuller discussion of
organizations).
related organizations.
• Current five highest compensated employees (over
Part VII, Section A, requires reporting of officers, directors, $100,000 of reportable compensation from the organization and
trustees, key employees, and up to five of the organization's related organizations), other than current officers, directors,
highest compensated employees. Compensation from related trustees, and key employees.
organizations must also be taken into account in determining a • Former officers, key employees, and five highest
person's compensation and reported in Part VII, Section A, compensated employees (over $100,000 of reportable
columns (E) and (F). compensation from the organization and related organizations,
Up to 25 persons can be reported on the Form 990, Part VII, with special rules for former highest compensated employees).
Section A table. If more space is needed to enter additional • Former directors and trustees (over $10,000 of reportable
persons, use as many duplicates of the Section A table as are compensation for services in the capacity as director or trustee
needed, and change the numbering to reflect additional persons. of the organization, from the organization and related
(For example, if five additional persons are reported on a organizations).
duplicate Section A table, change the numbers along the left Report compensation on Form 990, Part VII, for the calendar
hand margin of the table from 1–5 to 26–30.) year ending within the organization's fiscal year, including that
Section B requires reporting of the five highest compensated of current officers, directors, and trustees, even if the fiscal year
independent contractors. Section B doesn't require reporting of is used to determine which such persons must be listed in Part
compensation from related organizations. VII.

-26- Instructions for Form 990


Director or trustee. A “director or trustee” is a member of the organizations. Note that any others, up to five, might be
organization's governing body, but only if the member has reportable as current highest compensated employees, with
voting rights. A director or trustee that served at any time during over $100,000 in reportable compensation. Use the calendar
the organization's tax year is deemed a current director or year ending with or within the organization's tax year for
trustee. Members of advisory boards that don't exercise any determining the organization's current key employees.
governance authority over the organization aren't considered An individual that isn't an employee of the organization (or of
directors or trustees. a disregarded entity of the organization) is nonetheless treated
An “institutional trustee” is a trustee that isn't an individual or as a key employee if he or she serves as an officer or director of
natural person but an organization. For instance, a bank or trust a disregarded entity of the organization and otherwise meets the
company serving as the trustee of a trust is an institutional standards of a key employee set forth above. See Disregarded
trustee. Entities, later, for treatment of certain employees of a
disregarded entity as a key employee of the organization.
Officer. An officer is a person elected or appointed to manage
If an employee is a key employee of the organization for only
the organization's daily operations. An officer that served at any
a portion of the year, that person's entire compensation for the
time during the organization's tax year is deemed a current
calendar year ending with or within the organization's tax year,
officer. The officers of an organization are determined by
from both the filing organization and related organizations,
reference to its organizing document, bylaws, or resolutions of
should be reported in Part VII, Section A.
its governing body, or as otherwise designated consistent with
state law, but, at a minimum, include those officers required by Management companies and similar entities that are
applicable state law. Officers can include a president, independent contractors shouldn't be reported as key
vice-president, secretary, treasurer and, in some cases, a Board employees. The organization's top management official and
Chair. In addition, for purposes of Form 990, including Part VII, top financial official are deemed officers rather than key
Section A, and Schedule J (Form 990), treat as an officer the employees.
following persons, regardless of their titles. In the examples set forth below, assume the individual
1. Top management official. The person who has ultimate involved is an employee that satisfies the $150,000 Test and
responsibility for implementing the decisions of the governing Top 20 Test and isn't an officer, director, or trustee.
body or for supervising the management, administration, or Example 1. T is a large section 501(c)(3) university. L is the
operation of the organization; for example, the organization's dean of the law school of T, which generates more than 10% of
president, CEO, or executive director. the revenue of T, including contributions from alumni and
2. Top financial official. The person who has ultimate foundations. Although L doesn't have ultimate responsibility for
responsibility for managing the organization's finances; for managing the university as a whole, L meets the Responsibility
example, the organization's treasurer or chief financial officer. Test and is reportable as a key employee of T.
If ultimate responsibility resides with two or more individuals (for Example 2. S chairs a small academic department in the
example, co-presidents or co-treasurers), who can exercise College of Arts and Sciences of the same university, T,
such responsibility in concert or individually, then treat all such described above. As department chair, S supervises faculty in
individuals as officers. the department, approves the course curriculum, and oversees
the operating budget for the department. The department
Key employee. For purposes of Form 990, a current key represents less than 10% of the university's activities, assets,
employee is an employee of the organization (other than an income, expenses, capital expenditures, operating budget, and
officer, director, or trustee) who meets all three of the employee compensation. Under these facts and circumstances,
following tests, applied in the following order: S doesn't meet the Responsibility Test and isn't a key employee
1. $150,000 Test: Receives reportable compensation of T.
from the organization and all related organizations in excess of Example 3. U is a large acute-care section 501(c)(3)
$150,000 for the calendar year ending with or within the hospital. U employs X as a radiologist. X gives instructions to
organization's tax year. staff for the radiology work X conducts, but X doesn't supervise
2. Responsibility Test: At any time during the calendar year other U employees, manage the radiology department, or have
ending with or within the organization's tax year: or share authority to control or determine 10% or more of U's
a. Has responsibilities, powers, or influence over the capital expenditures, operating budget, or employee
organization as a whole that is similar to those of officers, compensation. Under these facts and circumstances, X doesn't
directors, or trustees; meet the Responsibility Test and isn't a key employee of U.
b. Manages a discrete segment or activity of the Example 4. W is a cardiologist and head of the cardiology
organization that represents 10% or more of the activities, department of the same hospital U described above. The
assets, income, or expenses of the organization, as compared to cardiology department is a major source of patients admitted to
the organization as a whole; or U and consequently represents more than 10% of U's income,
as compared to U as a whole. As department head, W manages
c. Has or shares authority to control or determine 10% or
the cardiology department. Under these facts and
more of the organization's capital expenditures, operating
circumstances, W meets the Responsibility Test and is a key
budget, or compensation for employees.
employee of U.
3. Top 20 Test: Is one of the 20 employees other than
officers, directors, and trustees who satisfy the $150,000 Test Five highest compensated employees. The organization is
and Responsibility Test with the highest reportable required to enter its current five highest compensated
compensation from the organization and related organizations employees whose reportable compensation combined from
for the calendar year ending with or within the organization's tax the organization and related organizations is greater than
year. $100,000 for the calendar year ending with or within the
organization's tax year and who aren't also current officers,
If the organization has more than 20 individuals who meet the directors, trustees, or key employees of the organization.
$150,000 Test and Responsibility Test, report as key Such individuals are the “current” five highest compensated
employees only the 20 individuals that have the highest employees. These can include persons who meet some but not
reportable compensation from the organization and related

Instructions for Form 990 -27-


all of the tests for key employee status. The organization isn't services as officers, or perform only minor services and neither
required to enter more than the top five such persons, ranked by receive nor are entitled to receive, directly or indirectly, any
amount of reportable compensation. Use the calendar year compensation. Corporate directors are considered
ending with or within the organization's tax year for determining independent contractors, not employees, and director
the organization's current five highest compensated employees. compensation, if any, generally is required to be reported on
Example. X is an employee of Y University and isn't an Form 1099-MISC. See Regulations section 31.3401(c)-1(f).
officer, director, or trustee. X's reportable compensation for the For certain kinds of employees and for retirees, the amount in
calendar year exceeds $150,000, and X meets the box 5 of Form W-2 can be zero or less than the amount in Form
Responsibility Test. X would qualify as a key employee of Y, W-2, box 1. For instance, recipients of disability pay, certain
except that 20 employees had higher reportable compensation members of the clergy, and religious workers who aren't subject
and otherwise qualify as key employees. Therefore, those 20 are to social security and Medicare taxes as employees can receive
listed as the organization's key employees. X has the highest compensation that isn't reported in box 5. In that case, the
reportable compensation from the organization and related amount required to be reported on Form W-2, box 1, must be
organizations of all employees other than the 20 key employees. reported as reportable compensation.
X must be listed as one of the organization's five highest
compensated employees. If an officer, director, trustee, key employee, or highest
compensated employee of the organization is a foreign person
$10,000 exceptions for reporting compensation. Report who received U.S. source income during the calendar year
compensation paid or accrued by the filing organization and ending with or within the organization's tax year from the filing
related organizations. Special rules apply for reporting organization or a related organization, and if such income was
reportable compensation and other compensation. reported on Form 1042-S, Foreign Person's U.S. Source Income
All reportable compensation paid by the filing organization Subject to Withholding, box 2, then treat this income as
must be reported. Reportable compensation paid by a related reportable compensation and report it in Part VII, Section A,
organization isn't required to be reported unless (1) it is $10,000 column (D) or (E). For foreign persons for whom compensation
or more for the calendar year ending with or within the reporting on Form W-2, Form 1099-MISC, or Form 1042-S isn't
organization's tax year (the “$10,000-per-related-organization required, treat as reportable compensation in column (D) or (E)
exception”) or (2) it is paid for past services to the filing the total value of the compensation paid in the form of cash or
organization in the person's capacity as a former director or property during the calendar year ending with or within the
trustee. organization's tax year. Report other compensation from foreign
A particular item of other compensation (such as listed in the organizations as “other compensation” in column (F).
compensation table, later) paid or accrued by the filing To determine whether an individual received more than
organization isn't required to be reported unless (1) it is $10,000 $100,000 (or $150,000) in reportable compensation in the
or more for the calendar year ending with or within the aggregate from the filing organization (and, as discussed later,
organization's tax year (the “$10,000-per-item exception”) or (2) certain third parties such as common paymasters, payroll/
it is one of the five types of compensation (generally constituting reporting agents, and certain unrelated organizations,
deferred compensation (including retirement plan benefits) and compensation from which is considered compensation from the
health benefits) that must be reported regardless of amount (see filing organization) and related organizations, add the
the instructions for column (F)). The same principles apply to following amounts.
items of other compensation paid or accrued by a related • The amount reported on Form W-2, box 1 or 5 (whichever
organization (applied separately to each related organization). amount is greater), and/or Form 1099-MISC, boxes 6 and 7,
issued to the individual by the organization.
The $10,000 exceptions don't apply to reporting • Amounts reported on Form W-2, box 1 or 5 (whichever
! compensation on Schedule J (Form 990), Part II. amount is greater), or Form 1099-MISC, boxes 6 and 7, issued
to the individual by each related organization that reported
CAUTION

Reportable compensation. Reportable compensation $10,000 or more.


consists of: To determine whether an individual received solely in his or
• For officers and other employees, amounts required to be her capacity as a former trustee or director of the organization
reported on Form W-2, box 1 or 5 (whichever amount is greater) more than $10,000 in reportable compensation for the calendar
(as well as Form 1099-MISC, boxes 6 and 7 if the officer or year ending with or within the organization's tax year, in the
employee is also compensated as an independent contractor of aggregate, from the organization and all related organizations
the filing organization or a related organization); (and thus must be reported on Form 990, Part VII and
• For directors and individual trustees, amounts required to Schedule J (Form 990), Part II), add the amounts reported on all
be reported on Form 1099-MISC, boxes 6 and 7 for director and Forms 1099-MISC, boxes 6 and 7, and, if relevant, all Forms
other independent contractor services to the organization or a W-2, box 1 or 5 (whichever amount is greater) issued to the
related organization, plus amounts required to be reported on individual by the organization and all related organizations for
Form W-2, box 1 or 5 (whichever amount is greater) if also the calendar year ending with or within the organization's tax
compensated as an officer or employee of the filing organization year. Report such amounts only to the extent that such amounts
or a related organization; and relate to the individual's past services as a trustee or director of
• For institutional trustees, fees for services paid pursuant to the organization, and don't disregard any payments from a
a contractual agreement or statutory entitlement. While the related organization if below $10,000, for such purpose.
compensation of institutional trustees must be reported on Form
990, Part VII, it need not be reported on Schedule J (Form 990). Other compensation. Other compensation includes
compensation other than reportable compensation, including
If the organization didn't file a Form 1099-MISC because the deferred compensation not currently reportable on Form W-2,
amounts paid were below the threshold reporting requirement, box 1 or 5 or Form 1099-MISC, boxes 6 and 7, and certain
then include and report the amount actually paid. For a full nontaxable benefits, as discussed in detail in the instructions for
definition of reportable compensation, see Glossary. Schedule J, (Form 990), Part II. See the instructions for other
Corporate officers are considered employees for compensation reported in column (F), later, which includes a
TIP purposes of Form W-2 reporting, unless they perform no

-28- Instructions for Form 990


table to show where and how to report certain types of company, an exempt organization “leases” one or more
compensation in Part VII, Section A, and Schedule J (Form 990). employees from another company, which may be in the
business of leasing employees. Alternatively, the organization
Note. Don't report the same item of compensation in more than may enter into an agreement with a professional employer
one column of Part VII, Section A, for the tax year. organization to perform some or all of the federal employment
Disregarded entities. Disregarded entities (such as a limited tax withholding, reporting, and payment functions related to
liability company that is wholly owned by the organization and workers performing services for the organization. The
not treated as a separate entity for federal tax purposes) are organization should treat employees of an employee leasing
generally treated as part of the organization rather than as company, a professional employer organization (whether or not
related organizations for purposes of Form 990, including Part certified under the new Certified Professional Employer
VII and Schedule J (Form 990). A person isn't considered an Organization, or a management company as the organization's
officer or director of the organization by virtue of being an own employees if such persons are common law employees of
officer or director of a disregarded entity, but he or she can the filing organization under state law. Otherwise, the
qualify as a key employee or highest compensated compensation paid to leasing companies and professional
employee of the organization. An officer, director, or employee employer organizations should be treated like compensation to a
of a disregarded entity is a key employee of the organization if management company for purposes of Form 990 compensation
he or she meets the $150,000 Test and Top 20 Test for the filing reporting.
organization as a whole, and if, for the Responsibility Test, the
person has responsibilities, powers, or influence over a discrete Compensation from common paymasters, payroll/reporting
segment or activity of the disregarded entity that represents at agents, and unrelated organizations or individuals (except for
least 10 percent of the activities, assets, income, or expenses of compensation from management companies or leasing
the filing organization as a whole, or has or shares authority to companies, and compensation described in Taxable
control or determine the disregarded entity's capital organization employee exception, later) must be treated as
expenditures, operating budget, or compensation for employees reportable compensation in determining whether the dollar
that is at least 10 percent of the filing organization's respective thresholds are met for reporting (1) current or former employees
items as a whole. If an officer or director of a disregarded entity as current or former key employees or highest compensated
also serves as an officer, director, trustee, or key employee of employees, or (2) former officers, directors, or trustees, on Form
the organization, report this individual as an officer, director, 990, Part VII, Section A. If the Form 990, Part VII thresholds for
trustee, or key employee, as applicable, of the organization, and reporting are met, then the compensation from the common
add the compensation, if any, paid by the disregarded entity to paymaster, payroll/reporting agent, or unrelated organization or
this individual to the compensation, if any, paid directly by the individual must be reported as compensation from the filing
organization to this individual. Report the total aggregate amount organization in Part VII. The compensation may also need to be
in column (D). reported on Form 990, Part II (see the instructions for Form 990,
Part VII, Section A, line 5).
A disregarded entity generally must use the EIN of its
TIP sole member. An exception applies to employment The use of a leasing company, common paymaster,
taxes: for wages paid to employees of a disregarded ! payroll/reporting agent, or other payroll service provider
CAUTION doesn't relieve an employer of its obligation for
entity, the disregarded entity must file separate employment tax
returns and use its own EIN on such returns. See Regulations employment tax liabilities. The IRS strongly suggests that the
sections 301.6109-1(h) and 301.7701-2(c)(2)(iv). organization doesn't change its address to that of its payroll
service provider or other third party payer. Doing so could limit
Management companies. Management companies, as the organization’s ability to stay informed of tax matters,
independent contractors, are reported on Form 990, Part VII because the IRS sends correspondence regarding problems
(if at all) only in Section B. Independent Contractors, and aren't with an employer's account to the employer's address of record.
reported on (Form 990), Part II. If a current or former officer, Alternatively, an employer may grant permission for a third party
director, trustee, or key employee has a relationship with a payer to receive copies of IRS correspondence by using Form
management company that provides services to the 8822-B, Form 2848, or Form 8655, as appropriate.
organization, then the relationship may be reportable on
Schedule L (Form 990 or 990-EZ), Part IV. A key employee of a Compensation from unrelated organizations or individuals.
management company must be reported as a current officer of If a current or former officer, director, trustee, key employee,
the filing organization if he or she is the filing organization's top or highest compensated employee received or accrued
management official or top financial official or is designated compensation or payments from an unrelated organization
as an officer of the filing organization. However, that person (other than from management companies or leasing
doesn't qualify as a key employee of the filing organization solely companies, as discussed above) or an individual for services
on the basis of being a key employee of the management rendered to the filing organization in that person's capacity as an
company. If a current or former officer, director, trustee, key officer, director, trustee, or employee of the filing organization,
employee, or highest compensated employee received then the filing organization must report (subject to the Taxable
compensation from a management company that provided organization employee exception, next) such amounts as
services to the organization and was a related organization compensation from the filing organization if it has knowledge of
during the tax year, then the individual's compensation from the the arrangement, whether or not the unrelated organization or
management company must be reported on Form 990, Part VII, the individual treats the amounts as compensation, grants,
Section A, columns (E) and (F). If the management company contributions, or otherwise. Report such compensation from
wasn't a related organization during the tax year, the individual’s unrelated organizations in Section A, columns (D) and (F), as
compensation from the management company isn't reportable in appropriate. If the organization can't distinguish between
Part VII, Section A. Questions pertaining to management reportable compensation and other compensation from the
companies also appear on Form 990, Part VI, line 3, and unrelated organization, report all such compensation in column
Schedule H (Form 990), Part IV. (D).
Taxable organization employee exception. Don't report as
Employee leasing companies and professional employer compensation any payments from an unrelated taxable
organizations. In some cases, instead of hiring a management organization that employs the individual and continues to pay the

Instructions for Form 990 -29-


individual's regular compensation while the individual provides box for former officers, directors, trustees, and key employees
services without charge to the filing organization, but only if the only if both conditions below apply.
unrelated organization doesn't treat the payments as a charitable • The organization reported (or should have reported, applying
contribution to the filing organization. the instructions in effect for such years) an individual on any of
the organization's Form 990, 990-EZ or 990-PF, for any one or
Column (A). For each person required to be listed, enter the
more of the 5 prior years in one or more of the following
name on the top of each row and the person's title or position
capacities: officer, director, trustee, or key employee.
with the organization on the bottom of the row. If more than one
title or position, list all. List persons in the following order:
• The individual received reportable compensation, from the
organization and/or related organizations, in the calendar year
individual trustees or directors, institutional trustees,
ending with or within the organization's current tax year in
officers, key employees, highest compensated employees,
excess of the threshold amount ($100,000 for former officers
and former such persons. List each person on only one line.
and key employees, $10,000 paid to former directors and
Column (B). For each person listed in column (A), estimate the trustees for services rendered in their former capacity as
average hours per week devoted to the organization during the directors or trustees).
year. Entry of a specific number is required for a complete
answer. Enter “-0-” if applicable. Don't include statements such If a person was reported (or should have been reported) as an
as “as needed,” “as required,” or “40+.” If the average is less officer, director, trustee, or key employee on any of the
than one hour per week, then the organization can enter a organization's prior five Form 990, 990-EZ, or 990-PF, and if the
decimal rounded to the nearest tenth (for example, 0.2 hours per person was still employed at any time during the organization's
week). tax year either: (1) by the organization in a lesser capacity other
For each person listed in column (A), list below the dotted line than as an officer, director, trustee, key employee, or highest
an estimate of the average hours per week (if any) devoted to compensated employee, or (2) by a related organization in any
related organizations. capacity, but not by the filing organization, and if the person
received reportable compensation that exceeded the threshold
Column (C). For each person listed in column (A), check the amount described above, then check only the “Former” box. For
box that reflects the person's position with the organization example, don't check both the “Former” and “Officer” boxes for a
during the tax year. Don't check more than one box, unless the former president of the organization who wasn't an officer of the
person was both an officer and a director/trustee of the organization during the tax year.
organization during the tax year. For a former officer, director,
Whether or not the organization files Form 990 based on a
trustee, key employee, or highest compensated employee,
fiscal year, use the calendar year ending within the
check only the “Former” box and indicate the former status in the
organization's tax year to determine all “former” officers,
person's title.
directors, trustees, key employees, and five highest
“Current” officers, directors, trustees, key employees, compensated employees (because their status depends on their
and highest compensated employees. A “current” officer, reportable compensation, which is reported for the calendar
director, or trustee is a person that was an officer, director, or year).
trustee at any time during the organization's tax year. A “current”
key employee or highest compensated employee is a Check the “Former” box for the former five highest
person who was an employee at any time during the calendar compensated employees only if all four conditions below apply.
year ending with or within the organization's tax year, and was a 1. The individual wasn't an employee of the organization at
key employee or highest compensated employee for such any time during the calendar year ending with or within the
calendar year. organization's tax year.
If the organization files Form 990 based on a fiscal year, use 2. The individual was reported (or should have been
the fiscal year to determine the organization's “current” officers, reported, under the instructions in effect for such years) on any
directors, and trustees. Whether or not the organization files of the organization's Form 990, 990-EZ, or 990-PF for one or
Form 990 based on a fiscal year, use the calendar year ending more of the 5 prior years as one of the five highest compensated
with or within the organization's tax year to determine the employees.
organization's “current” key employees and five highest 3. The individual's reportable compensation exceeded
compensated employees. $100,000 for the calendar year ending with or within the
Don't check the “Former” box if the person was a current organization's tax year.
officer, director, or trustee at any time during the organization's 4. The amount of the individual's reportable compensation
tax year, or a current key employee or among the five highest for such year would place him or her among the organization's
compensated employees for the calendar year ending with or current five highest compensated employees if the individual
within the organization's tax year. A current employee (other were an employee during the calendar year ending with or within
than a current officer, director, trustee, key employee, or highest the organization's tax year.
compensated employee) can be reported on Form 990, Part VII,
and Schedule J (Form 990), Part II: (1) as a former director or Example 1. X was reported as one of Y Charity's five highest
trustee because he or she served as a director or trustee within compensated employees on one of Y's Form 990, 990-EZ, or
the last 5 years; and received more than $10,000 in reportable 990-PF from one of its 5 prior tax years. During Y’s tax year, X
compensation for the calendar year ending with or within the wasn't a current officer, director, trustee, key employee, or
organization’s tax year in his or her capacity as a former director highest compensated employee of Y. X wasn't an employee of Y
or trustee, or (2) a former officer or key employee (but not as a during the calendar year ending with or within Y's tax year.
former highest compensated employee) because he or she During this calendar year, X received reportable compensation
served as an officer or key employee within the last 5 years and in excess of $100,000 from Y for past services and would be
received more than $100,000 of reportable compensation for the among Y's five highest compensated employees if X were a
calendar year ending with or within the organization’s tax year. In current employee. Y must report X as a former highest
such a case, indicate the individual's former position in his or her compensated employee on Y's Form 990, Part VII, Section A, for
titles (for example, “former president”). Y's tax year.
“Former” officers, directors, trustees, key employees, Example 2. T was reported as one of Y Charity's five highest
and highest compensated employees. Check the “Former” compensated employees on one of Y's Form 990, 990-EZ, or

-30- Instructions for Form 990


990-PF from one of its 5 prior tax years. During Y’s tax year, T Reasonable effort. The organization isn't required to report
wasn't a current officer, director, trustee, key employee, or compensation from a related organization to a person listed on
highest compensated employee of Y, although T was still an Form 990, Part VII, Section A, if the organization is unable to
employee of Y during the calendar year ending with or within Y's secure the information on compensation paid by the related
tax year. T received reportable compensation in excess of organization after making a reasonable effort to obtain it, and if
$100,000 from Y and related organizations for such calendar it is unable to make a reasonable estimate of such
year. T isn't reportable as a former highest compensated compensation. If the organization makes reasonable efforts but
employee on Y's Form 990, Part VII, Section A, for Y’s tax year is unable to obtain the information or provide a reasonable
because T was an employee of Y during the calendar year estimate of compensation from a related organization in column
ending with or within Y's tax year. (E) or (F), then it must report the efforts undertaken on
Example 3. Z was reported as one of Y Charity's key Schedule O (Form 990 or 990-EZ). An example of a reasonable
employees on Y's Form 990 filed for one of its 5 prior tax years. effort is for the organization to distribute a questionnaire annually
During Y’s tax year, Z wasn't a current officer, director, trustee, to each of its current and former officers, directors, trustees, key
key employee, or highest compensated employee of Y. For the employees, and highest compensated employees that includes
calendar year ending with or within Y’s tax year, Z received the name and title of each person reporting information, blank
reportable compensation of $90,000 from Y as an employee lines for those persons' signatures and signature dates, and the
(and no reportable compensation from related organizations). pertinent instructions and definitions for Form 990, Part VII,
Because Z received less than $100,000 reportable Section A, columns (E) and (F).
compensation for the calendar year ending with or within Y’s tax Short year and final returns. For a short year return in
year from Y and its related organizations, Y isn't required to which there is no calendar year that ends with or within the short
report Z as a former key employee on Y's Form 990, Part VII, year, leave columns (D) and (E) blank, and don't report any key
Section A, for Y’s tax year. employees, highest compensated employees, or highest
compensated independent contractors (because such
Columns (D) and (E). Enter the amounts required to be persons are determined according to compensation received in
reported (whether or not actually reported) on Form W-2, box 1 the calendar year ending with or within the tax year for which the
or 5 (whichever is greater), and/or Form 1099-MISC, boxes 6 return is filed), unless the return is a final return. If the return is a
and 7, issued to the person for the calendar year ending with or final return, report the compensation that is reportable
within the organization's tax year. Enter an amount for each compensation on Forms W-2 and 1099 for the short year, from
person in each of columns (D) and (E). Enter “-0-” if the person both the filing organization and related organizations, whether or
received no reportable compensation. For institutional not Forms W-2 or 1099 have been filed yet to report such
trustees that don't receive a Form 1099-MISC, enter the amount compensation.
that the organization would have reported in box 7 if a Form
1099-MISC had been required. Column (F). Other compensation generally includes
compensation not currently reportable on Form W-2, box 1 or 5,
Reportable compensation paid to the person by a related or Form 1099-MISC, boxes 6 and 7, including nontaxable
organization at any time during the entire calendar year ending benefits other than disregarded benefits, as discussed in
with or within the filing organization's tax year should be reported disregarded benefits and in the instructions for Schedule J
in column (E). If the related organization was related to the filing (Form 990), Part II. Treat amounts paid or accrued under a
organization for only a portion of the tax year, then the filing deferred compensation plan, or held by a deferred
organization may choose to report only compensation paid or compensation trust, that is established, sponsored, or
accrued by the related organization during the time it was maintained by the organization (or a related organization) as
actually related. If the filing organization reports compensation paid, accrued, or held directly by the organization (or the related
on this basis, it must explain in Schedule O (Form 990 or organization). Deferred compensation to be reported in column
990-EZ) and state the period during which the related (F) includes compensation that is earned or accrued in one year
organization was related. and deferred to a future year, whether or not funded, vested,
$10,000-per-related-organization exception. For purposes qualified or nonqualified, or subject to a substantial risk of
of column (E), the organization need not include payments from forfeiture. But don't report in column (F) a deferral of
a single related organization if it is less than $10,000 for the compensation that causes an amount to be deferred from the
calendar year ending with or within the organization's tax year, calendar year ending with or within the tax year to a date that
except to the extent paid to a former director or former trustee isn't more than 2 ½ months after the end of the calendar year
of the filing organization for services as a director or trustee of ending with or within the tax year if such compensation is
the organization. For example, if an officer of the organization currently reported as reportable compensation.
received compensation of $6,000, $15,000, and $50,000 from
three separate related organizations for services provided to Enter an amount in column (F) for each person listed in Part
those organizations, the organization needs to report only VII, Section A. (Enter “-0-” if applicable.) Report a reasonable
$65,000 in column (E) for the officer. estimate if actual numbers aren't readily available.
Volunteer exception. The organization need not report in Other compensation paid to the person by a related
column (E) or (F) compensation from a related organization paid organization at any time during the calendar year ending with or
to a volunteer officer, director, or trustee of the filing within the filing organization's tax year should be reported in
organization if the related organization is a for-profit column (F). If the related organization was related to the filing
organization, isn't owned or controlled, directly or indirectly, by organization for only a portion of the tax year, then the filing
the organization or one or more related tax-exempt organization may choose to report only other compensation paid
organizations, and doesn't provide management services for a or accrued by the related organization during the time it was
fee to the organization. actually related. If the filing organization reports compensation
Bank or financial institution trustee. If the organization is a on this basis, it must explain on Schedule O (Form 990 or
trust with a bank or financial institution trustee that is also a 990-EZ) and state the period during which the related
trustee of another trust, it need not report in column (E) or (F) organization was related.
compensation from the other trust for services provided as the The following items of compensation provided by the filing
trustee to the other trust, because the other trust isn't a related organization and related organizations must be reported as
organization (see Glossary definition of related organization).

Instructions for Form 990 -31-


“other compensation” in column (F) in all cases regardless of the $21,000 Reportable compensation (including $1,000 pre-tax
amount, to the extent they aren't included in column (D). employee contribution to qualified defined contribution
1. Tax-deferred contributions by the employer to a qualified retirement plan)
defined contribution retirement plan. 1,000 Tax-deferred employer contribution to qualified defined
contribution retirement plan
2. The annual increase or decrease in actuarial value of a
5,000 Nontaxable tuition assistance
qualified defined benefit plan, whether or not funded or vested.
3. The value of health benefits provided by the employer, or
paid by the employee with pre-tax dollars, that aren't included in The officer receives no compensation in the capacity as a
reportable compensation. For this purpose, health benefits former director or trustee of X, and no unrelated organization
include: (1) payments of health benefit plan premiums, (2) pays the officer for services provided to X. The organization can
medical reimbursement and flexible spending programs, and (3) disregard as other compensation the (a) $4,500 in dependent
the value of health coverage (rather than actual benefits paid) care and group life insurance payments from the organization
provided by an employer's self-insured or self-funded (under the $10,000-per-item exception), and (b) the $5,000 in
arrangement. Health benefits include dental, optical, drug, and tuition assistance from the related organization (under the
medical equipment benefits. They don't include disability or $10,000-per-item exception) in determining whether the officer's
long-term care insurance premiums or allocated benefits for this total reportable and other compensation from the organization
purpose. and related organizations exceeds $150,000. In this case, total
4. Tax-deferred contributions by the employer and reportable compensation is $131,000, and total other
employee to a funded nonqualified defined contribution plan, compensation (excluding the excludible items below $10,000) is
and deferrals under an unfunded nonqualified defined $11,000. Under these circumstances, the officer's dependent
contribution plan, whether or not such plans are vested or care, group life, and tuition assistance items need not be
subject to a substantial risk of forfeiture. See examples on reported as other compensation on Form 990, Part VII,
Schedule J (Form 990), Part II instructions. Section A, column (F), and the officer's total reportable and other
5. The annual increase or decrease in actuarial value of a compensation ($142,000) isn't reportable on Schedule J (Form
nonqualified defined benefit plan, whether or not funded, vested, 990). If instead, the officer's reportable compensation from Y
or subject to a substantial risk of forfeiture. were $30,000 rather than $21,000, then the officer's total
reportable and other compensation ($151,000) would be
$10,000-per-item exception. Except for the five items listed reportable on Schedule J (Form 990), including the dependent
above, neither the organization nor a related organization is care, group life, and tuition assistance items, even though these
required to report on Form 990, Part VII, Section A, any item of items wouldn't have to be reported as other compensation on
“other compensation” (as set forth in the compensation table Form 990, Part VII.
beginning later) if its total value is less than $10,000 for the Example 2. Organization S provides health benefits to B (its
calendar year ending with or within the organization's tax year. CEO) under a self-insured medical reimbursement plan. The
Amounts excluded under the two separate $10,000 value of the plan benefits for the tax year is $10,000, which
exceptions (the $10,000-per-related-organization and represents the estimated cost of providing coverage for the year
$10,000-per-item exceptions) are to be excluded from if the employer paid a third-party insurer for similar benefits, as
compensation in determining whether an individual's total determined on an actuarial basis. The actual benefits paid for B
reportable compensation and other compensation exceeds and B's family for the year are $30,000. If the benefits aren't
the thresholds set forth on Form 990, Part VII, Section A, line 4. If reportable compensation to B, then Organization S must report
the individual's total compensation exceeds the relevant the $10,000 value of plan benefits as other compensation to B
threshold, then the amounts excluded under the $10,000 on Form 990, Part VII, Section A, column (F).
exceptions are included in the individual's compensation Disregarded benefits. Disregarded benefits under Regulations
reported on Schedule J (Form 990). Thus, the total amount of section 53.4958-4(a)(4) need not be reported in column (F).
compensation reported on Schedule J (Form 990) can be higher Disregarded benefits generally include fringe benefits excluded
than the amount reported on Form 990, Part VII, Section A. from gross income under section 132. These benefits include
The $10,000-per-item exception applies separately for each the following:
item of other compensation from the organization and from each • No-additional cost service,
related organization. • Qualified employee discount,
Example 1. Organization X provides the following • Working condition fringe,
compensation to its current officer: • De minimis fringe,
• Qualified transportation fringe,
$110,000 Reportable compensation (including pre-tax employee
• Qualified retirement planning services, and
contributions of $5,000 to a qualified defined contribution • Qualified military base realignment and closure fringe.
retirement plan and $2,500 to a qualified health benefit plan) For descriptions of each of these disregarded benefits, see
5,000 Tax-deferred employer contribution to qualified defined Instructions for Schedule J (Form 990 and 990-EZ),
contribution retirement plan Compensation Information.
5,000 Nontaxable employer contributions to health benefit plan
Short year and final returns. For a short year return in which
4,000 Nontaxable dependent care assistance
there is no calendar year that ends with or within the short year,
500 Nontaxable group life insurance premium
leave column (F) blank, unless the return is a final return. If the
return is a final return, report the other compensation for the
short year from both the filing organization and related
Organization Y, a related organization, also provides organizations.
compensation to the officer as follows:
Compensation table for reporting in Part VII, Section A, or
Schedule J (Form 990), Part II. The following table may be
useful in determining how and where to report items of
compensation on Form 990, Part VII, Section A, and on

-32- Instructions for Form 990


Schedule J (Form 990), Part II. The list isn't comprehensive but applicable persons, Schedule J (Form 990), Part II, column (B).
covers most items for most organizations. Many items of Items listed as “taxable” or “taxable in current year” are currently
compensation may or may not be taxable or currently taxable, includible in reportable compensation, but aren't necessarily
depending on the plan or arrangement adopted by the subject to federal income tax in the current year.
organization and other circumstances. The list attempts to take Any item listed in the following compensation table that isn't
into account these varying facts and circumstances. The list is followed by a star (x) or asterisk (*) in any column shouldn't be
merely a guideline to report amounts for those persons required reported on Part VII, Section A or in Schedule J, Part II (Form
to be listed. In all cases, items included on Form W-2, box 1 or 5 990).
(whichever is greater), and/or Form 1099-MISC, boxes 6 and 7,
are required to be reported on Part VII, Section A and, for

Instructions for Form 990 -33-


Where to Report
Form 990, Part VII, Section A, column (D) or (E) Form 990, Part VII, Section A, column
(F)
Type of Compensation
Schedule J Schedule J (Form Schedule J (Form Schedule J (Form Schedule J (Form
(Form 990), Part 990), Part II, 990), Part II, 990), Part II, 990), Part II,
II, column B(i) column B(ii) column B(iii) column C column D

Base salary/wages/fees paid x


Base salary/wages/fees deferred (taxable) x
Base salary/wages/fees deferred (nontaxable) x
Bonus paid (including signing bonus) x
Bonus deferred (taxable in current year) x
Bonus deferred (not taxable in current year) x
Incentive compensation paid x
Incentive compensation deferred (taxable in x
current year)
Incentive compensation deferred (not taxable in x
current year)
Severance or change of control payments made x
Sick pay paid by employer x
Third-party sick pay x
Other compensation amounts deferred (taxable in x
current year)
Other compensation amounts deferred (not x
taxable in current year)
Tax gross-ups paid x
Vacation/sick leave cashed out x
Stock options at time of grant x
Stock options at time of exercise x
Stock awards paid by taxable organizations x
substantially vested
Stock awards paid by taxable organizations not x
substantially vested
Stock equivalents paid by taxable organizations x
substantially vested
Stock equivalents paid by taxable organizations x
not substantially vested
Loans—forgone interest or debt forgiveness x
Contributions (employer) to qualified retirement x
plan
Contributions (employee deferrals) to section x
401(k) plan
Contributions (employee deferrals) to section x
403(b) plan
Qualified or nonqualified retirement plan defined x
benefit accruals (reasonable estimate of increase
or decrease in actuarial value)
Qualified retirement (defined contribution) plan
investment earnings or losses (not reportable or
other compensation)
Taxable distributions from qualified retirement
plan, including section 457(b) eligible
governmental plan (reported on Form 1099-R but
not reportable or other compensation on Form 990)

-34- Instructions for Form 990


Where to Report
Form 990, Part VII, Section A, column (D) or (E) Form 990, Part VII, Section A, column
(F)
Type of Compensation
Schedule J (Form Schedule J (Form Schedule J (Form Schedule J (Form Schedule J (Form
990), Part II, 990), Part II, 990), Part II, 990), Part II, 990), Part II,
column B(i) column B(ii) column B(iii) column C column D

Distributions from nongovernmental section 457(b) x


plan
Amounts includible in income under section 457(f) x
Amounts deferred by employer or employee (plus x
earnings) under section 457(b) plan (substantially
vested)
Amounts deferred by employer or employee under x
section 457(b) or 457(f) plan (not substantially
vested)
Amounts deferred under nonqualified defined x
contribution plans (substantially vested)
Amounts deferred under nonqualified defined x
contribution plans (not substantially vested)
Earnings or losses of nonqualified defined x
contribution plan (substantially vested)
Earnings or losses of nonqualified defined
contribution plan (not substantially vested)
Scholarships and fellowship grants (taxable) x
Health benefit plan premiums paid by employer
x
(taxable)
Health benefit plan premiums paid by the employee x
(taxable)
Health benefit plan premiums (nontaxable) x
Medical reimbursement and flexible spending x
programs (taxable)
Medical reimbursement and flexible spending x
programs (nontaxable)
Other health benefits (taxable) x
Other health benefits (nontaxable) x
Life, disability, or long-term-care insurance (taxable) x
Life, disability, or long-term-care insurance *
(nontaxable)
Split-dollar life insurance (see Notice 2002-8, 2002-1 x
C.B. 398)
Housing provided by employer or ministerial housing x
allowance (taxable)
Housing provided by employer or ministerial housing *
allowance (nontaxable) (but see Schedule J
instructions regarding working condition fringes)
Personal legal services (taxable) x
Personal legal services (nontaxable) *
Personal financial services (taxable) x
Personal financial services (nontaxable) *
Dependent care assistance (taxable) x
Dependent care assistance (nontaxable) *
Adoption assistance (taxable) x
Adoption assistance (nontaxable) *
Tuition assistance for family (taxable) x

Instructions for Form 990 -35-


Where to Report
Form 990, Part VII, Section A, column (D) or (E) Form 990, Part VII, Section A, column
(F)
Type of Compensation
Schedule J (Form Schedule J (Form Schedule J (Form Schedule J (Form Schedule J (Form
990), Part II, 990), Part II, 990), Part II, 990), Part II, 990), Part II,
column B(i) column B(ii) column B(iii) column C column D
Tuition assistance for family (nontaxable) *
Cafeteria plans (nontaxable health benefit) x
Cafeteria plans (nontaxable benefit other than health) *
Liability insurance (taxable) x
Employer-provided automobile (taxable) x
Employer-subsidized parking (taxable) x
Travel (taxable) x
Moving (taxable) x
Meals and entertainment (taxable) x
Social club dues (taxable) x
Spending account (taxable) x
Gift cards x
Disregarded benefits under Regulations section
53.4958-4(a)(4) (see Schedule J, Part II instructions)

Note. Items marked with an asterisk (*) instead of a star (x) are • Each individual that received, solely in the capacity as a
excludible from Form 990, Part VII, Section A, column (F), if former director or former trustee of the organization, more than
below $10,000. $10,000 of reportable compensation (Part VII, Section A,
columns (D) and (E)) during the year from the organization or
Line 1b. Report the subtotals of compensation from the
related organizations. To determine whether an individual
Section A, line 1a table in line 1b, columns (D), (E), and (F).
received or accrued more than $10,000 in reportable
Line 1c. Report the subtotals of compensation from compensation solely in the capacity as a former trustee or
continuation sheets (duplicate Section A tables for filers that director of the organization, add the amounts reported on all
report more than 25 persons in Section A, line 1a table) in Forms 1099-MISC, box 7, and, if applicable, Forms W-2, box 1
line 1c, columns (D), (E), and (F). or 5 (whichever is greater), and/or issued to the individual by the
organization and all related organizations, to the extent that such
Line 1d. Add the totals of lines 1b and 1c in line 1d for columns
amounts relate to the individual's past services as a trustee or
(D), (E), and (F).
director of the organization and not of a related organization. The
Line 2. Report the total number of individuals, both those listed $10,000-per-related-organization exception doesn't apply for
in the Part VII, Section A table, and those not listed, to whom the this purpose.
filing organization (not related organizations) paid over
Line 4. Complete Schedule J (Form 990) for each individual
$100,000 in reportable compensation during the tax year.
listed in Section A who received or accrued more than $150,000
Line 3. Complete Schedule J (Form 990) for each of the of reportable and other compensation from the organization and
following persons. related organizations. To determine whether any listed individual
• Each individual listed in Part VII, Section A, as a former received or accrued more than $150,000 of reportable and other
officer, former key employee, or a former highest compensation, add all compensation included in Part VII,
compensated employee. To determine whether an individual Section A, columns (D), (E), and (F), but disregard any
received more than $100,000 in reportable compensation in decreases in the actuarial value of defined benefit plans.
the aggregate from the organization and related organizations, The following chart explains which officers, directors,
add the amounts reported on all Forms W-2, box 1 or 5 trustees, key employees, and highest compensated
(whichever is greater), and/or Forms 1099-MISC, box 7, issued employees must be reported on Form 990, Part VII, Section A,
to the individual by the organization and all related organizations and on Schedule J (Form 990). See also line 5 for additional
(disregarding amounts from a related organization if below individuals who must be reported on Schedule J (Form 990),
$10,000) for the calendar year ending with or within the Part II.
organization's tax year.

-36- Instructions for Form 990


Matrix for Part VII, Section A, Lines 3 and 4

Enter on Form 990, Part VII, Enter on Schedule J (Form 990),


Position Current or former Section A . . . Part II . . .

If reportable and other compensation is


greater than $150,000 in the aggregate
Current All from organization and related
organizations (don't report institutional
Directors and Trustees trustees)
If reportable compensation in capacity
as former director or trustee is greater If listed on Form 990, Part VII, Section A
Former
than $10,000 in the aggregate from (don't report institutional trustees)
organization and related organizations
If reportable and other compensation is
greater than $150,000 in the aggregate
Current All
from organization and related
Officers organizations
If reportable compensation is greater
Former than $100,000 in the aggregate from If listed on Form 990, Part VII, Section A
organization and related organizations
Current All All

Key employees If reportable compensation is greater


Former than $100,000 in the aggregate from If listed on Form 990, Part VII, Section A
organization and related organizations
If reportable and other compensation is
If reportable compensation is greater
greater than $150,000 in the aggregate
Current than $100,000 in the aggregate from
from organization and related
organization and related organizations
Other Five Highest Compensated organizations
Employees
If reportable compensation is greater
Former than $100,000 in the aggregate from If listed on Form 990, Part VII, Section A
organization and related organizations

Line 5. Complete Schedule J (Form 990) for any individual organization for Form W-2 reporting purposes. A, as the top
listed on Form 990, Part VII, Section A, if the person receives or management official of the organization, must be listed as an
accrues compensation from an unrelated organization (other officer of the organization in Part VII, Section A. However, the
than from management companies and leasing companies, as amounts paid by B to A require that the organization answer
discussed earlier) for services rendered to the filing organization “Yes” on line 5 and complete Schedule J (Form 990) about A.
in the person's capacity as an officer, director, trustee, or Example 2. C is an attorney employed by a law firm that isn't
employee of the filing organization. Also, specify on Schedule J a related organization to the organization. The organization and
(Form 990), Part III, the name of the unrelated organization, the the law firm enter into an arrangement where C serves the
type and amount of compensation it paid or accrued, and the organization, a section 501(c)(3) legal aid society pro bono, on a
person receiving or accruing such compensation. See full-time basis as its vice-president and as a board member while
Compensation from unrelated organizations, earlier. continuing to receive her regular compensation from the law
For purposes of line 5, disregard: firm. The organization doesn't provide any compensation to C for
the services provided by C to the organization, and doesn't
1. Payments from a deferred compensation trust or plan
report C's compensation on Form W-2 or Form 1099-MISC. The
established, sponsored, or maintained by the organization (or a
law firm doesn't treat any part of C's compensation as a
related organization), and deferred compensation held by such
charitable contribution to the legal aid society. Under these
trust or plan;
circumstances, the amounts paid by the law firm to C don't
2. Payments from a common paymaster for services require that the organization answer “Yes” on line 5, about C.
provided to the organization (or to a related organization) (see Also, nothing in these facts would prevent C from qualifying as
instructions for Common paymaster or payroll/reporting an independent member of the organization's governing body for
agent, earlier); or purposes of Form 990, Part VI, line 1b.
3. Payments from an unrelated taxable organization that Example 3. D, a volunteer director of the organization, is
employs the individual and continues to pay the individual's also the sole owner and CEO of M management company (an
regular compensation while the individual provides services unrelated organization), which provides management services to
without charge to the filing organization, but only if the unrelated the organization. The organization pays M an annual fee of
organization doesn't treat the payments as a charitable $150,000 for management services. Under the circumstances,
contribution to the filing organization. the amounts paid by M to D (in the capacity as owner and CEO
Example 1. A is the CEO (and the top management of M) don't require that the organization answer “Yes” on line 5,
official) of the organization. In addition to compensation paid by regarding D. However, the organization must report the
the organization to A, A receives payments from B, an unrelated transaction with M, including the relationship between D and M,
corporation (using the definition of relatedness on Schedule R on Schedule L (Form 990 or 990-EZ), Part IV. Also, D doesn't
(Form 990)), for services provided by A to the organization. B qualify as an independent member of the organization's
also makes rent payments for A's personal residence. The governing body because D receives indirect financial benefits
organization is aware of the compensation arrangement from the organization through M that are reportable on
between A and B, and doesn't treat the payments as paid by the Schedule L (Form 990 or 990-EZ), Part IV.

Instructions for Form 990 -37-


Section B. Five Highest Compensated In column (C), report any unrelated business revenue received
by the organization during the tax year from an unrelated trade
Independent Contractors
or business, unless that revenue is reportable on Part VIII,
Complete this table for the five highest compensated column (D). See Pub. 598 and Instructions for Form 990-T for
independent contractors that received more than $100,000 in more information.
compensation for services, whether professional or other
services, from the organization. Independent contractors include A section 501(c)(3) organization that is an S corporation
organizations as well as individuals and can include professional TIP shareholder must treat all allocations of income from the
fundraisers, law firms, accounting firms, publishing companies, S corporation as unrelated business income. Gain on
management companies, and investment management the disposition of stock is also treated as unrelated business
companies. Don't report public utilities or insurance providers as income. See section 512(e).
independent contractors. See Pub. 1779, Independent
Contractor or Employee, and Pub. 15-A, Employer's Column (D).
Supplemental Tax Guide, for distinguishing employees from In column (D), report any revenue excludable from unrelated
independent contractors. business income by section 512, 513, or 514. Examples of
such revenue include receipts from the sale of donated
Column (C). Enter the amount the organization paid, whether merchandise, interest (unless debt-financed), and receipts from
reported on Form 1099-MISC, boxes 6 and 7, or paid under the bingo games.
parties' agreement or applicable state law, for the calendar year
Neither Form 5500 nor DOL Forms LM-2 or LM-3 should be
ending with or within the organization's tax year.
substituted for the Form 990, Parts VIII or IX.
For a short year return in which there is no calendar year that
ends with or within the short year, don't report any information in Line 1. In General
columns (A) through (C), unless the return is a final return. If the On lines 1a through 1f, report cash and noncash amounts
return is a final return, report the compensation paid to the received as voluntary contributions, gifts, grants or other
independent contractor(s) under the parties' agreement during similar amounts from the general public, governmental units,
the short year or the compensation that is reportable
foundations, and other exempt organizations. The general public
compensation on Form 1099 for the short year, whether or not
includes individuals, corporations, trusts, estates, and other
Form 1099 has been filed yet to report such compensation.
entities. Voluntary contributions are payments, or the part of any
Compensation includes fees and similar payments to payment, for which the payer (donor) doesn't receive full retail
independent contractors but not reimbursement of expenses value (fair market value) from the recipient (donee)
unless incidental to providing the service. However, for this organization. Contributions are reported on line 1 regardless of
purpose, the organization must report gross payments to the whether they are deductible by the contributor. The noncash
independent contractor that include expenses and fees if the portion of contributions reported on lines 1a through 1f is also
expenses aren't separately reported to the organization. reported on line 1g.
Form 1099-MISC may be required to be issued for Report gross amounts of contributions collected in the
TIP payments to an independent contractor, with organization's name by fundraisers.
compensation reported in boxes 6 and/or 7.
Report all expenses of raising contributions on Part IX,
column (D), Fundraising expenses. The organization must enter
Part VIII. Statement of Revenue on Part IX, line 11e, fees for professional fundraising
Check the box in the heading of Part VIII if Schedule O (Form services relating to the gross amounts of contributions collected
990 or 990-EZ) contains any information pertaining to this part. in the organization's name by professional fundraisers.
Column (A). Report on line 1 assets contributed to the organization by
All organizations must complete column (A), reporting their another entity in the course of the entity's liquidation, dissolution,
gross receipts for all sources of revenue. All organizations or termination.
(except section 527 political organizations) must complete
columns (B) through (D), which must add up to the amount in Report the value of noncash contributions at the time of the
column (A) for each line in Part VIII. Refer to specific instructions donation. For example, report the FMV of a donated car at the
in this part for completing each column. time the car was received as a donation.

If the organization enters an amount in column (A) for Don't net losses from uncollectible pledges from prior years,
TIP lines 2a through 2e or lines 11a through 11c, it must also refunds of contributions and service revenue from prior years, or
enter a corresponding business activity code from reversal of grant expenses from prior years on line 1. Rather,
Business Activity Codes. If none of the listed codes, or other report any such items as “Other changes in net assets or fund
6-digit codes listed on the NAICS website at NAICS 2017 balances” on Part XI, line 9, and explain in Schedule O.
Census Chart, accurately describe the activity, enter “900099.” The organization must report any contributions of
Use of these codes doesn't imply that the business activity is conservation easements and other qualified conservation
unrelated to the organization's exempt purpose. contributions consistently with how it reports revenue from
such contributions in its books, records, and financial
Column (B). statements.
In column (B), report all revenue from activities substantially
related to the organization's exempt purposes. Use of revenue Reporting on line 1 according to ASC 958 generally is
for the organization's exempt purposes doesn't make the activity acceptable (though not required) for Form 990 purposes, but the
that produced the income (for example, fundraising activity) value of donated services or use of materials, equipment, or
substantially related to the organization's exempt purposes. Also facilities may not be reported. An organization that receives a
report here any revenue that is excludable from gross income grant to be paid in future years should, according to ASC 958,
other than by section 512, 513, or 514, such as interest on state report the grant's present value on line 1. Accruals of present
and local bonds that is excluded from tax by section 103. value increments to the unpaid grant should be reported on
line 1 in future years.
Column (C).
Contributions don't include:

-38- Instructions for Form 990


• Grants, fees or other support from governmental units, Membership dues that aren't contributions because they
foundations, or other exempt organizations that represent a compare reasonably with available benefits are reported on
payment for a service, facility, or product that primarily gives line 2, Program Service Revenue.
some economic or physical benefit to the payer. Membership dues can consist of both contributions and
• The portion of any fundraising solicitation representing payment for goods and services. In that case, the portion of the
payment for goods, services, or anything else at retail value. membership dues that is a payment for goods or services should
• Unreimbursed expenses of officers, employees, or be reported on line 2, Program Service Revenue. The portion
volunteers. (See the explanations of charitable contributions that exceeds the FMV of the goods or services provided should
and employee business expenses in Pub. 526 and Pub. 463, be reported on line 1b.
respectively.)
The portion of membership dues attributable to certain
• Payments received from employers for welfare benefits under
plans described in sections 501(c)(9), (17), and (18). Report membership benefits that are considered to be insubstantial (for
these amounts on line 2, Program Service Revenue. example, low-cost articles, free or discounted admission to the
organization's activities, discounts on purchases from the
• Donations of services such as the value of donated
advertising space, broadcast air time (including donated public organization's gift shop, free or discounted parking) may be
service announcements), or discounts on services or donations reported as contributions on line 1, rather than as payments for
of use of materials, equipment, or facilities, even though goods or services on line 2. See Pub. 1771, for more information
reporting donated services and facilities as items of revenue and on insubstantial membership benefits that need not be valued or
expense is called for in certain circumstances by generally reported.
accepted accounting principles. The optional reporting of Line 1c. Enter the total amount of contributions received from
donated services and facilities is discussed in the instructions for fundraising events, which includes, but isn't limited to, dinners,
Form 990, Part III. auctions, and other events conducted for the sole or primary
Example 1. A hotel in a city's entertainment district donates purpose of raising funds for the organization's exempt activities.
100 “right to use” certificates covering 15 hotel rooms a night to Report contributions received from gaming activities on line 1f,
disaster relief organization B. B then uses these certificates as not on line 1c.
emergency housing in furtherance of its exempt purposes. B Example. An organization holds a dinner, charging $400 per
shouldn't report the value of this contribution on line 1 (or on any person for the meal. The dinner has a retail value of $160. A
other line in Part VIII), because this is a donation of services and person who purchases a ticket is really purchasing the dinner for
use of facilities to B. Similarly, if B were to auction off the $160 and making a contribution of $240. The contribution of
certificates as part of a fundraising event, B shouldn't report the $240, which is the difference between the buyer's payment and
value of the contributed certificates on line 1 (or on any other line the retail value of the dinner, would be reported on line 1c and
in Part VIII). Rather, it should report gross income from the again on line 8a (within the parentheses). The revenue received
auction on Part VIII, line 8a. ($160 retail value of the dinner) would be reported in the
Example 2. Organization C purchases 100 “right to use” right-hand column on line 8a.
certificates (as described in Example 1) from the hotel, then If a contributor gives more than $160, that person would be
contributes them to disaster relief organization B and designates making a contribution of the difference between the dinner's
that they be used for disaster relief purposes. B should report the retail value of $160 and the amount actually given. Rev. Rul.
FMV of these certificates on line 1. If B were to auction off the 67-246, 1967-2 C.B. 104, as distinguished by Rev. Rul. 74-348,
certificates as part of a fundraising event, then use the proceeds 1974-2 C.B. 80, explains this principle in detail. See also the
for disaster relief purposes, B should report the gross income instructions for lines 8a through 8c and Pub. 526, Charitable
from the auction on Part VIII, line 8a, report the FMV of the Contributions.
contributed certificates in line 8b, and report the difference
between lines 8a and 8b on line 8c. Organizations that report more than $15,000 total on lines 1c
and 8a must also answer “Yes” on Part IV, line 18, and complete
Line 1a. Enter on line 1a the total amount of contributions
Part II of Schedule G (Form 990 or 990-EZ).
received indirectly from the public through solicitation campaigns
conducted by federated fundraising agencies and similar Line 1d. Enter on line 1d amounts contributed to the
fundraising organizations (such as from a United Way organization by related organizations. Don't report amounts
organization). Federated fundraising agencies normally conduct reportable on line 1a.
fundraising campaigns within a single metropolitan area or some
Line 1e. Enter the total amount of contributions in the form of
part of a particular state, and allocate part of the net proceeds to
grants or similar payments from local, state, or federal
each participating organization on the basis of the donors'
government sources, as well as foreign governments. Include
individual designations and other factors.
grant amounts from U.S. possessions.
Federated fundraising agencies must, like all other filers, Whether a payment from a governmental unit is labeled a
TIP identify the sources of contributions made to them on “grant” or a “contract” doesn't determine where the payment
lines 1a through 1g. should be reported on Part VIII. Rather, a grant or other payment
from a governmental unit is reported here if its primary purpose
Line 1b. Report on line 1b membership dues and assessments is to enable the organization to provide a service to, or maintain
that represent contributions from the public rather than a facility for, the direct benefit of the public rather than to serve
payments for benefits received or payments from affiliated the direct and immediate needs of the governmental unit. In
organizations. other words, the payment is recorded on line 1e if the general
Example. M is an organization whose primary purpose is to public receives the primary and direct benefit from the payment
support the local symphony orchestra. Members have the and any benefit to the governmental unit is indirect and
privilege of purchasing subscriptions to the symphony's annual insubstantial as compared to the public benefit.
concert series before they go on sale to the general public, but The following are examples of governmental grants and other
must pay the same price as any other member of the public. payments that are treated as contributions and reported on
They are also entitled to attend a number of rehearsals each line 1e.
season without charge. Under these circumstances, M's receipts
from members are contributions reported on line 1b.

Instructions for Form 990 -39-


• Payments by a governmental unit for the construction or organization from participants or employers of participants for
maintenance of library or museum facilities open to the public. health and welfare benefits coverage; insurance premiums
• Payments by a governmental unit to nursing homes to provide received by a fraternal beneficiary society; and registration fees
care to their residents (but not Medicare/Medicaid or similar received in connection with a meeting or convention.
payments made on behalf of the residents).
Program-related investments. Program service revenue also
• Payments by a governmental unit to child placement or child includes income from program-related investments. These
guidance organizations under government programs to better
investments are made primarily to accomplish an exempt
serve children in the community.
purpose of the investing organization rather than to produce
Line 1f. Enter all other contributions, gifts, and similar income. Examples are scholarship loans and low interest loans
amounts the organization received from sources not reported to charitable organizations, indigents, or victims of a disaster.
separately on lines 1a through 1e. This amount includes Rental income from an exempt function is another example of
contributions from donor advised funds (unless the program-related investment income. For purposes of this return,
sponsoring organization is a related organization) and from report all rental income from an affiliated organization on line 2.
gaming activities.
Unrelated trade or business activities. Unrelated trade or
Line 1g. Enter on line 1g the value of noncash contributions business activities (not including any fundraising events or
included on lines 1a through 1f. If this amount exceeds $25,000, fundraising activities) that generate fees for services can also
the organization must answer “Yes” on Part IV, line 29, and be program service activities. A social club, for example, should
complete and attach Schedule M (Form 990). report as program service revenue the fees it charges both
Noncash contributions are anything other than cash, checks, members and nonmembers for the use of its tennis courts and
money orders, credit card charges, wire transfers, and other golf course.
transfers and deposits to a cash account of the organization.
Sales of inventory items by hospitals, colleges, and univer-
Value noncash donated items, like cars and securities, as of
sities. Books and records maintained according to generally
the time of their receipt, even if they were sold immediately after
accepted accounting principles for hospitals, colleges, and
they were received.
universities are more specialized than books and records
Example. A charity receives a gift of stock from an unrelated maintained according to those accounting principles for other
donor. The stock is delivered to the charity's broker, who sells it types or organizations that file Form 990. Accordingly,
on the same day and remits the sales proceeds, net of hospitals, colleges, and universities can report, as program
commissions, to the charity. The value of the stock at the time of service revenue on line 2, sales of inventory items otherwise
the contribution must be reported on line 1f and also on line 1g. reportable on line 10a. In that event, enter the applicable cost of
The sale of the stock, and the related sales expenses (including goods sold as program service expense in column (B) of Part IX.
the amount reported on lines 1f and 1g), must be reported on No other organizations should report sales of inventory items on
lines 7a through 7d. line 2.
Museums and other organizations that elect not to Common Types of Program Service Revenue:
TIP capitalize their collections (according to ASC • Medicare and Medicaid payments, and other government
958-360-45) shouldn't report an amount on line 1g for payments made to pay or reimburse the organization for medical
works of art and other collection items donated to them. services provided to individuals who qualify under a government
program for the services provided, and who select the service
For more information on noncash contributions, see the provider. See Rev. Rul. 83-153, 1983-2 C.B. 48.
Instructions for Schedule M (Form 990). • Payments for medical services by patients and their
Line 1h. Enter on line 1h the total of lines 1a through 1f (but not guarantors.
line 1g). • Fees and contracts from government agencies for a service,
facility, or product that primarily benefited the government
The organization may also need to attach Schedule B agencies.
TIP (Form 990, 990-EZ, or 990-PF) to report certain
contributors and their contributions. See the Example 1. A payment by a governmental agency to a
Instructions for Schedule B (Form 990, 990-EZ, or 990-PF) for medical clinic to provide vaccinations to the general public is a
information. contribution reported on line 1e. A payment by a governmental
agency to a medical clinic to provide vaccinations to employees
Line 2. On lines 2a through 2e, enter the organization's five of the agency is program service revenue reported on line 2.
largest sources of program service revenue. Program services Example 2. A payment by a governmental agency to an
are primarily those that form the basis of an organization's organization to provide job training and placement for disabled
exemption from tax. For a more detailed description of program individuals is a contribution reported on line 1e. A payment by a
service revenue, refer to the instructions for Part IX, column (B). governmental agency to the same organization to operate the
On line 2f, enter the total received from all other sources of agency's internal mail delivery system is program service
program service revenue not listed individually on lines 2a revenue reported on line 2.
through 2e. On line 2g, enter the total of column (A), lines 2a • Income from program-related investments. Report interest,
through 2f. dividends, and other revenues from those investments made
primarily to accomplish the organization's exempt purposes
Program service revenue. Program service revenue includes
rather than to produce income. Examples of program-related
income earned by the organization for providing a government
investments include student loans and notes receivable from
agency with a service, facility, or product that benefited that
other exempt organizations that borrowed the funds to pursue
government agency directly rather than benefiting the public as a
the filing organization's exempt function.
whole. Program service revenue also includes tuition received
by a school, revenue from admissions to a concert or other
• Membership dues and assessments received that compare
reasonably with the membership benefits provided by the
performing arts event or to a museum; royalties received as
organization. Organizations described in section 501(c)(5), (6),
author of an educational publication distributed by a commercial
or (7) generally provide benefits that have a reasonable
publisher; interest income on loans a credit union makes to its
relationship with dues.
members; payments received by a section 501(c)(9)

-40- Instructions for Form 990


Examples of membership benefits include: from real property are excluded in computing unrelated
• Subscriptions to publications, business income, while rental income from personal property is
• Newsletters (other than one only about the organization's included. There are special rules when rents are received from
activities), personal property leased with real property (a mixed lease). In
• Free or reduced-rate admissions to events sponsored by the general, rental revenue from real property is excluded from
organization, unrelated business revenue when:
• Use of the organization's facilities, and • The determination of the amount of such rents isn't based on
• Discounts on articles or services that members and income or net profits derived by any person from the property
nonmembers can buy. leased other than an amount based on a fixed percentage of the
gross receipts or sales;
For each amount entered on lines 2a through 2e, the
organization must also enter a corresponding business
• The lease doesn't include personal services other than
!
CAUTION activity code from Business Activity Codes. If you don't
customary ones such as trash removal and cleaning of public
areas;
see a code for the activity you are trying to categorize, select the
appropriate code from the NAICS website at 2017 NAICS
• Any portion attributable to personal property is 10% or less of
the total rent; and
Census Chart. Select the most specific 6-digit code available
that describes the activity producing the income. Note that most
• The real property isn't debt-financed within the meaning of
section 512, 513, or 514. (Rent from debt-financed real property
codes describe more than one type of activity. Avoid using
generally is includible in unrelated business income, but there
codes that describe the organization rather than the
can be exceptions based on use of the property. See Pub. 598.)
income-producing activity. For example, a credit union reporting
income from consumer lending activities should use code Rent received from leased personal property generally is
522291. Sales revenue from a museum gift shop should be taxable except when leased with real property, and the rent
reported with code 453220. An organization providing credit attributable to the personal property doesn't exceed 10% of the
counseling services should use code 541990. If none of the total rents from all leased property.
listed codes accurately describe the activity, enter “900099.” Line 6b. Enter on line 6b the expenses paid or incurred for the
Use of these codes doesn't imply that the activity is unrelated to income reported on line 6a. Include interest related to rental
the organization's exempt purpose. property and depreciation if it is recorded in the organization's
books and records. If the organization reported on line 2 any
Line 3. Enter the gross amount of interest income from savings rental income reportable as program service revenue, report any
and temporary cash investments, dividend and interest income rental expense allocable to such activity on the applicable lines
from equity and debt securities (stocks and bonds), amounts of Part IX, column (B).
received from payments on securities loans, as defined in
section 512(a)(5), as well as interest from notes and loans Line 6c. Subtract line 6b from line 6a for both columns (i) and
receivable. Don't include unrealized gains and losses on (ii) and enter on line 6c. Show any loss in parentheses.
investments carried at fair market value. Don't deduct Line 6d. Add line 6c, columns (i) and (ii) and enter on line 6d.
investment management fees from this amount, but report these Show any loss in parentheses.
fees on Part IX, line 11f.
Lines 7a through 7d. Enter on lines 7a through 7c all sales of
Line 4. Enter all investment income actually or constructively securities in column (i). Use column (ii) to report sales of all
received from investing the proceeds of a tax-exempt bond other types of investments (such as real estate, royalty interests,
issue, which are under the control of the organization. For this or partnership interests) and all other non-inventory assets (such
purpose, don't include any investment income received from as program-related investments and fixed assets used by the
investing proceeds that are technically under the control of the organization in its related and unrelated activities).
governmental issuer. For example, proceeds deposited into a
defeasance escrow that is irrevocably pledged to pay the On line 7a, for each column, enter the total gross sales price
principal and interest (debt service) on a bond issue isn't under of all such assets. Total the cost or other basis (less
the control of the organization. depreciation) and selling expenses and enter the result on
line 7b. On line 7c, enter the net gain or loss. Show any loss in
Line 5. Enter on line 5 royalties received by the organization parentheses.
from licensing the ongoing use of its property to others. On lines 7a and 7c, also report capital gains dividends, the
Typically, royalties are received for the use of intellectual organization's share of capital gains and losses from a joint
property, such as patents and trademarks. Royalties also venture, and capital gains distributions from trusts.
include payments to the owner of the property for the right to
exploit natural resources on the property, such as oil, natural Combine the gain or loss figures reported on line 7c, columns
gas, or minerals. (i) and (ii) and report that total on line 7d. Show any loss in
parentheses. Don't include any unrealized gains or losses on
Line 6a. Enter on line 6a the rental income received for the year securities carried at fair market value in the books of account.
from investment property and any other real property rented by
For reporting sales of securities on Form 990, the
the organization. Allocate revenue to real property and personal
organization can use the more convenient average cost basis
property in the spaces provided. Don't include on line 6a rental
method to figure the organization's gain or loss. When a security
income related to the filing organization's exempt function
is sold, compare its sales price with the average cost basis of the
(program service). Report such income on line 2. For example,
particular security to determine gain or loss. However, for
an exempt organization whose exempt purpose is to provide
reporting sales of securities on Form 990-T, don't use the
low-rental housing to persons with low income would report that
average cost basis to determine gain or loss.
rental income as program service revenue on line 2.
The organization should maintain books and records to
Only for purposes of completing this return, the filing
substantiate information about any securities or other assets
organization must report any rental income received from an
sold for which market quotations weren't published or weren't
affiliated exempt organization as program service revenue on
otherwise readily available. The recorded information should
line 2.
include:
Rental revenue can be from an activity that is related or • A description of the asset;
unrelated to the organization's exempt purpose. In general, rents • Date acquired;

Instructions for Form 990 -41-


• Whether acquired by donation or purchase; such as certain advertising expenses associated with raising
• Date sold and to whom sold; these contributions, must be reported on the appropriate lines
• Gross sales price; in Part IX, column (D), and not on line 8b.
• Cost, other basis, or, if donated, value at time acquired;
Line 8c. Enter on line 8c the difference between lines 8a and
• Expense of sale and cost of improvements made after
8b. Show any loss in parentheses. The organization must report
acquisition; and
net income from fundraising events as unrelated business
• Depreciation since acquisition, if depreciable property. revenue (column (C)) or as revenue excluded from tax under
Line 8a. Enter in the line 8a box the gross income from section 512, 513, or 514 (column (D)).
fundraising events, not including the amount of contributions Example 1. If an organization receives a donation of a
from fundraising events reported on line 1c. Report the line 1c home theater system with a FMV of $5,000 at the time of
amount in the line 8a parenthetical. If the sum of the amounts donation; sells the system for $7,500 at an auction, after having
reported on line 1c and the line 8a box exceeds $15,000, then displayed the system and its FMV (which remains $5,000) at and
the organization must answer “Yes” on Part IV, line 18, and before auction so that its value was known to the bidders; and
complete Schedule G (Form 990 or 990-EZ), Part II. If gaming is incurs $500 in costs related to selling the system at auction, it
conducted at a fundraising event, the income and expenses should report the following amounts in Part VIII:
must be allocated between the gaming and the fundraising event
on Form 990, Part VIII; report all income from gaming on line 9a.
Line 1c (contributions from $2,500
Compute the organization's gross income from fees, ticket fundraising events):
sales, or other revenue from fundraising events. Line 1f (all other contributions): $5,000
Line 1g (noncash contributions): $5,000
Fundraising events include: Fundraising events don't include: Line 8a (gross income from $5,000
• Dinners/dances, • Sales or gifts of goods or services of fundraising events):
only nominal value, Line 8a parenthetical (contributions $2,500
• Door-to-door sales of merchandise, • Raffles or lotteries in which prizes reported on line 1c):
have only nominal value, and Line 8b (direct expenses: $5,000 $5,500
• Concerts, • Solicitation campaigns that generate FMV on donation date + $500 in
only contributions. auction costs):
• Carnivals, Line 8c (net income from fundraising ($500)
event, line 8a minus line 8b):
• Sports events, and Proceeds from these activities are
considered contributions and should
be reported on line 1f. Example 2. If the home theater system in Example 1 sold at
• Auctions. auction for $2,500 instead of $7,500, and all other facts in
Example 1 remain the same, then the organization should report
the following amounts in Part VIII:
Fundraising events don't include events or activities that
substantially further the organization's exempt purpose even if
Line 1c (contributions from $0
they also raise funds. Revenue from such program service
fundraising events):
activities is reported on line 2.
Line 1f (all other contributions): $5,000
Example. An organization formed to promote and preserve Line 1g (noncash contributions): $5,000
folk music and related cultural traditions holds an annual folk Line 8a (gross income from $2,500
music festival featuring concerts, handcraft demonstrations, and fundraising events):
similar activities. Because the festival directly furthers the Line 8a parenthetical (contributions $0
organization's exempt purpose, income from ticket sales should reported on line 1c):
be reported on line 2 as program service revenue. Line 8b (direct expenses: $5,000 $5,500
Fundraising events sometimes generate both contributions FMV on donation date + $500 in
auction costs):
and income, such as when an individual pays more than the
Line 8c (net income from fundraising ($3,000)
retail value for the goods or services furnished. Report in
event, line 8a minus line 8b):
parentheses the total amount from fundraising events that
represents contributions rather than payment for goods or
services. Treat the following as contributions.
• Amounts paid in excess of retail value of goods or services In both Example 1 and Example 2, the organization would
furnished. See Example, earlier, in line 1c. need to report the $5,000 value of this contribution on
• Amounts received from fundraising events when the Schedule M if it received over $25,000 in total noncash
organization gives items of only nominal value to recipients. See contributions during the tax year.
Pub. 1771. Line 9a. Line 9a should include only gross income from
Example. In return for a contribution of any amount, donors gaming activity. It shouldn't include contributions from gaming
receive a keychain with the organization's logo. All amounts activity, which should be reported on line 1f. Organizations that
received should be reported as contributions on line 1f and all report more than $15,000 on line 9a must also answer “Yes” on
associated expenses on the appropriate lines in Part IX, column Part IV, line 19, and complete Part III of Schedule G (Form 990
(D). In such a case, no amounts would be reported on line 8. or 990-EZ).
Line 8b. Enter on this line both the cost or other basis of any
items sold at the events and the expenses that relate directly to
the production of the revenue portion of the fundraising activity,
whether incurred before, during, or after the event. In the line 1c
dinner example referred to earlier, the cost of the food and
beverages served and invitation to the dinner would be among
the items reported on line 8b. Indirect fundraising expenses,

-42- Instructions for Form 990


Types of gaming include, but aren't limited to: Line 11. Enter all other types of revenue not reportable on lines
- Bingo - Nevada Club tickets 1 through 10. Enter the three largest sources on lines 11a
- Pull tabs - Certain Casino nights through 11c and all other revenue on line 11d.
- Instant bingo - Certain Las Vegas nights For each amount entered on lines 11a, 11b, and 11c, the
- Raffles - Coin-operated
TIP organization must also enter a corresponding business
gambling devices
activity code from Business Activity Codes. If you don't
including:
see a code for the activity you are trying to categorize, select the
- Scratch-offs • Slot machines
appropriate code from the NAICS website at 2017 NAICS
- Charitable gaming tickets • Electronic video
Census Chart. Select the most specific 6-digit code available
slot or line games
that describes the activity producing the income. Note that most
- Break-opens • Video poker
codes describe more than one type of activity. Avoid using
- Hard cards • Video blackjack
codes that describe the organization rather than the
- Banded tickets • Video keno
income-producing activity. If none of the listed codes accurately
- Jar tickets • Video bingo
describe the activity, enter “900099.” Use of these codes doesn't
- Pickle cards • Video pull tab
imply that the activity is unrelated to the organization's exempt
games
purpose.

Line 12. For column (A), add lines 1h, 2g, 3 through 5, 6d, 7d,
Many games of chance are taxable. Income from bingo 8c, 9c, 10c, and 11e. For columns (B) through (D), add lines 2a
games generally isn't subject to the tax on unrelated business through 2f, 3, 4, 5, 6d, 7d, 8c, 9c, 10c, and 11a through 11d. The
income if the games meet the legal definition of bingo. For a amounts reported on line 12 in columns (B), (C), and (D), plus
game to meet the legal definition of bingo, wagers must be the amount reported on line 1h, should equal line 12, column (A).
placed, winners must be determined, and prizes or other
property must be distributed in the presence of all persons Part IX. Statement of Functional
placing wagers in that game.
A wagering game that doesn't meet the legal definition of
Expenses
bingo doesn't qualify for the exclusion, regardless of its name. Check the box in the heading of Part IX if Schedule O (Form 990
For example, instant bingo, in which a player buys a or 990-EZ) contains any information pertaining to this part.
pre-packaged bingo card with pull tabs that the player removes Use the organization's normal accounting method to
to determine if he or she is a winner, doesn't qualify. See Pub. complete this section. If the organization's accounting system
598. doesn't allocate expenses, the organization can use any
Line 9b. Enter on this line the expenses that relate directly to reasonable method of allocation. The organization must report
the production of the revenue portion of the gaming activity. amounts accurately and document the method of allocation in its
Direct expenses of gaming include: records. Report any expense described on lines 1–23 on the
• Cash prizes, appropriate line; don't report such expense on line 24. Don't
• Noncash prizes, report in Part IX expenses that must be reported on lines 6b, 7b,
• Compensation to bingo callers and workers, 8b, 9b, or 10b in Part VIII.
• Rental of gaming equipment, and Column (A)—Total
• Cost of gaming supplies such as pull tabs, bingo cards, etc. Section 501(c)(3) and 501(c)(4) organizations must complete
Line 9c. Enter the difference between line 9a and 9b. Show any columns (A) through (D).
loss in parentheses. All other organizations must complete column (A) but can
complete columns (B), (C), and (D).
Line 10a. Enter the organization's gross income from sales of
inventory items, less returns and allowances. Sales of inventory State reporting requirements can be different from IRS
items reportable on line 10a are sales of items that are donated ! reporting requirements applicable to Part IX.
to the organization, that the organization makes to sell to others, CAUTION

or that it buys for resale. Sales of inventory don't, however,


Column (B)—Program Services
include the sale of goods related to a fundraising event, which
Program services are mainly those activities that further the
must be reported on line 8. Sales of investments on which the
organization's exempt purposes. Fundraising expenses
organization expected to profit by appreciation and sale aren't
shouldn't be reported as program-service expenses even though
reported here. Report sales of investments on line 7.
one of the organization's purposes is to solicit contributions.
The organization must report the sales revenue regardless of
Include lobbying expenses in this column if the lobbying is
whether the sales activity is an exempt function of the
directly related to the organization's exempt purposes.
organization or an unrelated trade or business.
Example. Foundation M, an organization exempt under
Line 10b. Enter the cost of goods sold related to the sales of section 501(c)(3), has the exempt purpose of improving health
inventory. The usual items included in cost of goods sold are care for senior citizens. Foundation M operates in State N. The
direct and indirect labor, materials and supplies consumed, legislature of State N is considering legislation to improve
freight-in, and a portion of overhead expenses. Marketing and funding of health care for senior citizens. Foundation M lobbies
distribution costs aren't included in the cost of goods sold but are state legislators in support of the legislation. Since this lobbying
reported as expenses in Part IX. For purposes of Part VIII, the is directly related to Foundation M's exempt purpose, it would be
organization may include as cost of donated goods their fair considered an exempt function expense, and would be included
market value at the time of acquisition. under Column (B).
Line 10c. Enter in the appropriate columns (A) through (D), the Program services can also include the organization's
net income or (loss) from the sale of inventory items. Show any unrelated trade or business activities. Publishing a magazine
loss in parentheses. is a program service even though the magazine contains both
editorials and articles that further the organization's exempt

Instructions for Form 990 -43-


purpose as well as advertising, the income from which is taxable activity or project with a high degree of accuracy. Indirect costs
as unrelated business income. are costs that can't be identified specifically with an activity or
Also include costs to secure a “grant,” or contract, to conduct project. For example, a computer bought by a university
research, produce an item, or perform a program service, if the specifically for a research project is a direct cost. In contrast, the
activities are conducted to meet the grantor’s or other costs of software licensing for programs that run on all the
contracting party’s specific needs. Don't report these costs as university's computers are indirect costs.
fundraising expenses in column (D). Costs to solicit restricted or Colleges, universities, hospitals, and other organizations that
unrestricted grants to provide services to the general public incur indirect expenses in various cost centers (such as
should be reported in column (D). organizational memberships, books and subscriptions, and
Column (C)—Management and General regular telecommunications costs) can allocate and report such
Use column (C) to report expenses that relate to the expenses in the following manner:
organization's overall operations and management, rather than 1. Report the expenses of all indirect cost centers in column
to fundraising activities or program services. Overall (C), lines 5 through 24.
management usually includes the salaries and expenses of the 2. As a separate line item of line 24, enter “Allocation of
organization's chief executive officer and his or her staff, unless [name of indirect cost center] expenses.”
a part of their time is spent directly supervising program services
or fundraising activities. In that case, their salaries and expenses a. If any of the cost center's expenses are allocated to
should be allocated among management, fundraising, and expenses listed in Part VIII such as the expenses attributable to
program services. fundraising events and activities, enter such expenses as a
negative figure in columns (A) and (C).
Expenses incurred to manage investments must be reported
in column (C). Lobbying expenses should be reported in this b. Allocate expenses to column (B) or (D) as positive
column if they don't directly relate to the organization's exempt amounts.
purposes. c. Add the amounts in columns (B) and (D) and enter the
Organizations must also report the following in column (C): sum as a negative offsetting amount in column (C). Don't make
costs of board of directors' meetings; committee meetings, and any entries in column (A) for these offsetting entries.
staff meetings (unless they involve specific program services or Example. An organization reports in column (C) $50,000 of
fundraising activities); general legal services; accounting its actual management and general expenses and $100,000 of
(including patient accounting and billing); general liability expenses of an indirect cost center that are allocable in part to
insurance; office management; auditing, human resources, and other functions. The total of lines 5 through 24 of column (C)
other centralized services; preparation, publication, and would be $150,000 before the indirect cost center allocations
distribution of an annual report; and management of were made. Assume that of the $100,000 total expenses of the
investments. cost center, $10,000 was allocable to fundraising; $70,000 to
However, report expenses related to the production of various program services; $15,000 to management and general
program-related income in column (B) and expenses related to functions; and $5,000 to special events and activities. To report
the production of rental income in Part VIII, on line 6b. Rental this in Part IX under this optional method:
expenses incurred for the organization's office space or facilities 1. Indicate the cost center, the expenses of which are being
are reported on line 16. allocated, on line 24 as “Allocation of [specify the indirect cost
Don't use this column to report costs of special meetings or center] expenses;”
other activities that relate to fundraising or specific program 2. Enter a decrease of $5,000 on the same line in column
services. (A), Total expenses, representing the fundraising event
Column (D)—Fundraising expenses that were already reported in Part VIII, on line 8b;
Fundraising expenses are the expenses incurred in soliciting 3. Enter $70,000 on the same line in column (B), Program
cash and noncash contributions, gifts, and grants. Report as service expenses;
fundraising expenses all expenses, including allocable overhead 4. Enter $10,000 on the same line in column (D),
costs, incurred in: (a) publicizing and conducting fundraising Fundraising expenses; and
campaigns and (b) soliciting bequests and grants from
individuals, foundations, other organizations, or governmental 5. Enter a decrease of $85,000 on the same line in column
units that are reported on Part VIII, line 1. This includes (C), Management and general expenses, to represent the
expenses incurred in participating in federated fundraising allocations to functional areas other than management and
campaigns; preparing and distributing fundraising manuals, general.
instructions, and other materials; and preparing to solicit or
receive contributions. Report direct expenses of fundraising
events in Part VIII, line 8b, rather than in Part IX, column (D).
However, report indirect expenses of fundraising events, such
as certain advertising expenses, in Part IX, column (D) rather
than in Part VIII, line 8b.
Example. For an employee who works on fundraising 40
percent of the time and program management 60 percent of the
time, an organization must allocate that employee's salary 40
percent to fundraising and 60 percent to program service
expenses. It can’t report the 100 percent of salary as program
expenses simply because the employee spent over 50 percent
of his time on program management.

Allocating Indirect Expenses


Direct costs are expenses that can be identified specifically with
an organization's activity or project, and can be assigned to an

-44- Instructions for Form 990


After making these allocations, the column (C), line 25, total Line 2. Enter the amount paid by the organization to domestic
functional expenses would be $65,000, consisting of the individuals in the form of scholarships, fellowships, stipends,
$50,000 actual management and general expense amount and research grants, and similar payments and distributions.
the $15,000 allocation of the aggregate cost center expenses to
management and general. Also include grants and other assistance paid to third party
providers for the benefit of specified domestic individuals. For
The above is an example of a one-step allocation that shows example, a grant payment to a hospital to cover the medical
how to report the allocation in Part IX. This reporting method expenses of a specific patient must be reported on line 2. By
would actually be more useful to avoid multiple-step allocations comparison, a grant to the same hospital to provide services to
involving two or more cost centers. Without this optional the general public or to unspecified charity patients must be
reporting method, the total expenses of the first cost center reported on line 1.
would be allocated to the other functions, and might include an If line 2 exceeds $5,000, the organization must complete
allocation of part of these expenses to another cost center. The Parts I and III of Schedule I (Form 990).
expenses of the second cost center would then be allocated to
other functions and, perhaps, to other cost centers, and so on. Line 3. The organization must enter the total amount of grants
The greater the number of these cost centers that are allocated and other assistance made to foreign organizations, foreign
out, the more difficult it is to preserve the object classification governments, and foreign individuals, and to domestic
identity of the expenses of each cost center (for example, organizations or domestic individuals for the purpose of
salaries, interest, supplies, etc.). Using the reporting method providing grants or other assistance to designated foreign
described above avoids this problem. organizations or foreign individuals.
The intent of the above instructions is only to facilitate If line 3 exceeds $5,000, the organization may have to
reporting indirect expenses by both object classification complete Part II and/or Part III of Schedule F (Form 990). See
!
CAUTION and function. These instructions don't authorize the
Instructions for Schedule F for more information.
allocation to other functions of expenses that should be reported Line 4. Enter the payments made by the organization to provide
as management and general expenses. benefits to members (such as payments made by an
organization exempt under section 501(c)(8), 501(c)(9), or
Grants and Other Assistance to 501(c)(17) to obtain insurance benefits for members, or
patronage dividends paid by section 501(c)(12) organizations to
Governments, Organizations, and their members). Don't report on this line the cost of
Individuals employment-related benefits such as health insurance, life
insurance, or disability insurance provided by the organization to
Organizations should report the amount of grants and other its officers, directors, trustees, key employees, and other
assistance on lines 1 through 3. Report expenses incurred in employees. Report such costs for officers, directors, trustees,
selecting recipients or monitoring compliance with the terms of a and key employees on Part IX, line 5; report such costs for other
grant or award on lines 5 through 24. See the following disqualified persons on Part IX, line 6; and report such costs for
instructions. other employees on Part IX, lines 8 and 9.
Note. Organizations can report this information according to Line 5. Enter the total compensation paid to current officers,
ASC 958 but aren't required to do so. For example, an directors, trustees, and key employees (as defined in Part
organization that follows ASC 958 and makes a grant during the VII) for the organization's tax year. Compensation includes all
tax year to be paid in future years should report the grant's forms of income and other benefits earned or received from the
present value on this year's Form 990 and report accruals of filing organization, common paymasters, and payroll/reporting
additional value increments in future years. agents in return for services rendered to the filing organization,
including compensation reported on Forms W-2 and 1099,
Line 1. Enter the amount that the organization, at its own pension plan contributions and accruals, and other employee
discretion, paid in grants to domestic organizations and benefits, but doesn't include non-compensatory expense
domestic governments. United Way and similar federated reimbursements or allowances. Report all compensation
fundraising organizations should report grants to member or amounts relating to such an individual, including those related to
participating agencies on line 1. Organizations must report services performed in a capacity other than as an officer,
voluntary grants to state or local affiliates for specific (restricted) director, trustee, or key employee.
purposes or projects on line 1.
Compensation for Part IX is reported based on the
If the organization reported on line 1 more than $5,000 of
grants or other assistance to any domestic organization or
TIP accounting method and tax year used by the
organization, rather than the definitions and calendar
to any domestic government, the organization must complete
year used to complete Part VII or Schedule J (Form 990)
Parts I and II of Schedule I (Form 990), Grants and Other
regarding compensation of certain officers, directors,
Assistance to Organizations, Governments, and Individuals in
trustees, and other employees.
the United States.

Allocating Indirect Expenses—Example

Line (A) (B) (C) (D)


5–24a $150,000 - $150,000 -
24b Allocation of $100,000 indirect cost center expenses reported (5,000) 70,000 (85,000) 10,000
in (C)
25 $145,000 $70,000 $65,000 $10,000

Instructions for Form 990 -45-


Note. To the extent the following examples discuss allocation of 1099 was issued to the independent contractor. Don't include
expenses in columns (B), (C), and (D), they apply only to filers on line 11 amounts paid to or earned by employees, officers,
required to complete those columns. directors, trustees, or disqualified persons for these types of
services, which must be reported on lines 5 through 7.
Line 6. Section 501(c)(3), 501(c)(4), and 501(c)(29)
If the organization is able to distinguish between fees paid for
organizations must report the total compensation and other
independent contractor services and expense payments or
distributions provided to disqualified persons and persons
reimbursements to the contractor(s), report the fees paid for
described in section 4958(c)(3)(B) to the extent not included on
services on line 11 and the expense payments or
line 5. See Appendix G. Section 4958 Excess Benefit
reimbursements on the applicable lines in Part IX (including
Transactions.
line 24 if no other line is applicable). If the organization is unable
Compensation includes all forms of income and other to distinguish between service fees and expense payments or
benefits earned or received from the filing organization, common reimbursements, report all such amounts on line 11.
paymasters, and payroll/reporting agents in return for services
rendered to the filing organization, including compensation Line 11a. Management fees. Enter the total fees charged for
reported on Forms W-2 and 1099, pension plan contributions management services provided by outside firms and individuals.
and accruals, and other employee benefits, but doesn't include Line 11b. Legal fees. Enter the total legal fees charged by
non-compensatory expense reimbursements or allowances. outside firms and individuals. Don't include any penalties, fines,
Line 7. Enter the total amount of employee salaries, wages, settlements, or judgments imposed against the organization as a
fees, bonuses, severance payments, and similar amounts paid result of legal proceedings. Report those expenses on line 24.
or provided from the filing organization, common paymasters, Report any amounts for lobbying services provided by attorneys
and payroll/reporting agents in return for services rendered to on line 11d.
the filing organization that aren't reported on line 5 or 6. Line 11c. Accounting fees. Enter the total accounting and
Line 8. Enter the employer's share of contributions to, or auditing fees charged by outside firms and individuals.
accruals under, qualified and nonqualified pension and deferred Line 11d. Lobbying fees. Enter amounts for activities intended
compensation plans for the year. The organization should to influence foreign, national, state, or local legislation, including
include contributions made by the filing organization, common direct lobbying and grassroots lobbying.
paymasters, and payroll/reporting agents to the filing
organization's sections 401(k) and 403(b) pension plans on Line 11e. Professional fundraising fees. Enter amounts paid
behalf of employees. However, it shouldn't include contributions for professional fundraising services, including solicitation
to qualified pension, profit-sharing, and stock bonus plans under campaigns and advice or other consulting services supporting
section 401(a) solely for the benefit of current or former officers, in-house fundraising campaigns. If the organization is able to
directors, trustees, key employees, or disqualified persons, distinguish between fees paid for professional fundraising
which are reportable on line 5 or 6. services and amounts paid for fundraising expenses such as
printing, paper, envelopes, postage, mailing list rental, and
Complete Form 5500, Annual Return/Report of equipment rental, then fees paid for professional fundraising
TIP Employee Benefit Plan, for the organization's plan and services should be reported on line 11e and amounts paid for
file it as a separate return. If the organization has more fundraising expenses should be reported on line 24 as other
than one pension plan, complete a Form 5500 for each plan. File expenses. If the organization is unable to distinguish between
the form by the last day of the 7th month after the plan year these amounts, it should report all such fees and amounts on
ends. line 11e.
Line 9. Other employee benefits. Enter contributions by the Line 11f. Investment management fees. Enter amounts for
filing organization, common paymasters, and payroll/reporting investment counseling and portfolio management. Monthly
agents to the filing organization's employee benefit programs account service fees are considered portfolio management
(such as insurance, health, and welfare programs that aren't an expenses, and must be reported here. Don't include transaction
incidental part of a pension plan included on line 8), and the cost costs such as brokerage fees and commissions, which are
of other employee benefits. considered sales expenses and are included on Part VIII,
line 7b.
For example, report expenses for employee events such as a
picnic or holiday party on line 9. Don't include contributions on Line 11g. Other fees for services. Enter amounts for other
behalf of current or former officers, directors, trustees, key independent contractor services not listed on lines 11a
employees or other persons that were included on line 5 or 6. through 11f. For example, amounts paid to an independent
contractor for advocacy services that don't constitute lobbying
Line 10. Payroll taxes. Enter the amount of federal, state, and
should be reported here. For health care organizations,
local payroll taxes for the year but only those taxes that are
payments to health care professionals who are independent
imposed on the organization as an employer. This includes the
contractors are reported on line 11g. Report on line 11g
employer's share of social security and Medicare taxes, the
payments to payroll agents, common paymasters, and other
federal unemployment tax (FUTA), state unemployment
third parties for services provided by those third parties to the
compensation taxes, and other state and local payroll taxes.
filing organization. Report on lines 5–10, as appropriate,
Don't include on line 10 taxes withheld from employees' salaries
payments that reimburse third parties for compensation to the
and paid to various governmental units such as federal, state,
organization's officers, directors, trustees, key employees,
and local income taxes and the employees' shares of social
or other employees. Report payments to contractors for
security and Medicare taxes. Such withheld amounts are
information technology services on line 14, rather than on
reported as compensation.
line 11g.
Line 11. Fees for services paid to nonemployees (inde-
If the amount on line 11g exceeds 10% of the amount on
pendent contractors). Enter on lines 11a through 11g
line 25, column (A), the organization must list the type and
amounts for services provided by independent contractors for
management, legal, accounting, lobbying, professional amount of each line 11g expense on Schedule O (Form 990 or
990-EZ).
fundraising services, investment management, and other
services, respectively. Include amounts whether or not a Form

-46- Instructions for Form 990


Line 12. Advertising and promotion expenses. Enter expenditures for the year relating to such official (including family
amounts paid for advertising. Include amounts for print and members of such official) exceed $1,000 for the year.
electronic media advertising. Also include Internet site link costs, For expenditures that aren't specifically identifiable to a
signage costs, and advertising costs for the organization's particular individual, the organization can use any reasonable
in-house fundraising campaigns. Include fees paid to allocation method to estimate the cost of the expenditure to an
independent contractors for advertising, except for fees paid to individual. Amounts not described above can be included in the
independent contractors for conducting professional reported total amount for line 18 or can be reported on line 24.
fundraising services or campaigns, which are reported on The organization is responsible for keeping records of all travel
line 11e. and entertainment expenses related to a government official
whether or not the expenses are reported on line 18 or line 24.
Line 13. Office expenses. Enter amounts for supplies (office,
classroom, or other supplies); telephone (cell phones and Line 19. Conferences, conventions, and meetings. Enter
landlines) and facsimile; postage (overnight delivery, parcel the total expenses incurred by the organization in conducting
delivery, trucking, and other delivery expenses) and mailing meetings related to its activities. Include such expenses as
expenses; shipping materials; equipment rental; bank fees and facility rentals, speakers' fees and expenses, and printed
other similar costs. Also include printing costs of a general materials. Include the registration fees (but not travel expenses)
nature. Printing costs that relate to conferences or conventions paid for sending any of the organization's staff to conferences,
must be reported on line 19. conventions, and meetings conducted by other organizations.
Travel expenses incurred by officers, directors, and
Line 14. Information technology. Enter amounts for
employees attending such conferences, conventions, and
information technology, including hardware, software, and
meetings must be reported on line 17.
support services such as maintenance, help desk, and other
technical support services. Also include expenses for Line 20. Interest. Enter the total interest expense for the year.
infrastructure support, such as web site design and operations, Don't include any interest attributable to rental property (reported
virus protection and other information security programs and on Part VIII, line 6b) or any mortgage interest (reported as an
services to keep the organization's web site operational and occupancy expense on line 16).
secured against unauthorized and unwarranted intrusions, and
Line 21. Payments to affiliates. Enter certain types of
other information technology contractor services. Report
payments to organizations affiliated with (closely related to) the
payments to information technology employees on lines 5
filing organization.
through 10. Report depreciation/amortization related to
information technology on line 22. Payments to affiliated state or national organizations.
Dues paid by a local organization to its affiliated state or national
Line 15. Royalties. Enter amounts for royalties, license fees, (parent) organization are reported on line 21. Report on this line
and similar amounts that allow the organization to use predetermined quota support and dues (excluding membership
intellectual property such as patents and copyrights. dues of the type described below) by local agencies to their
Line 16. Occupancy. Enter amounts for the use of office space state or national organizations for unspecified purposes; that is,
or other facilities, including rent; heat, light, power, and other general use of funds for the national organization's own program
utilities expenses; property insurance; real estate taxes; and support services.
mortgage interest; and similar occupancy-related expenses. Purchases from affiliates. Purchases of goods or services
Don't include on line 16 expenses reported as office expenses from affiliates aren't reported on line 21 but are reported as
(such as telephone expenses) on line 13. expenses in the usual manner.
Expenses for providing goods or services to affiliates. In
Don't net any rental income received from leasing or
addition to payments made directly to affiliated organizations,
subletting rented space against the amount reported on line 16
expenses for providing goods or services to affiliates can be
for occupancy expenses. If the tenant's activities are related to
reported on line 21 if:
the organization's exempt purpose, report rental income as
program-service revenue on Part VIII, line 2, and allocable
• The goods or services provided aren't related to the program
services conducted by the organization furnishing them (for
occupancy expenses on line 16. However, if the tenant's
example, when a local organization incurs expenses in the
activities aren't program-related, report the rental income on Part
production of a solicitation film for the state or national
VIII, line 6a, and related rental expenses on Part VIII, line 6b.
organization); and
Don't include employee salaries or depreciation as • The costs involved aren't connected with the management
occupancy expenses. These expenses are reported on lines 5 and general or fundraising functions of the filing organization.
through 7 and 22, respectively. For example, when a local organization gives a copy of its
Line 17. Travel. Enter the total travel expenses, including mailing list to the state or national organization, the expense of
transportation costs (fares, mileage allowances, and automobile preparing the copy provided can be reported on line 21, but not
expenses), meals and lodging, and per diem payments. Travel the expenses of preparing and maintaining the local
costs include the expenses of purchasing, leasing, operating, organization's master list.
and repairing any vehicles owned by the organization and used Voluntary awards or grants to affiliates. Don't report on
for the organization's activities. However, if the organization line 21 voluntary awards or grants made by the organization to
leases vehicles on behalf of its executives or other employees its state or national organizations for specified purposes.
as part of an executive or employee compensation program, the Membership dues paid to other organizations. Report
leasing costs are considered employee compensation, and are membership dues paid to obtain general membership benefits
reported on lines 5 through 7. from other organizations, such as regular services, publications,
and other materials, on line 24. This is the case if a charitable
Line 18. Payments of travel or entertainment expenses for organization pays dues to a trade association comprised of
any federal, state, or local public officials. Enter total otherwise unrelated members.
amounts for travel or entertainment expenses (including
reimbursement for such costs) for any federal, state, or local Properly distinguishing between payments to affiliates
public officials (as determined under section 4946(c)) and their TIP and grants and allocations is especially important if the
family members (as determined under section 4946(d)). Report organization uses Form 990 for state reporting
amounts for a particular public official only if aggregate purposes. If the organization uses Form 990 only for reporting to

Instructions for Form 990 -47-


the IRS, payments to affiliated or national organizations that An organization conducts a combined educational campaign
don't represent membership dues reportable as miscellaneous and fundraising solicitation when it solicits contributions (by
expenses on line 24 can be reported either on line 21 or line 1. mail, telephone, broadcast media, or any other means) and
includes, with the solicitation, educational material or other
Line 22. Depreciation, depletion, and amortization. If the information that furthers a bona fide non-fundraising exempt
organization records depreciation, depletion, amortization, or purpose of the organization.
similar expenses, enter the total on line 22. Include any Expenses attributable to providing information regarding the
depreciation or amortization of leasehold improvements and organization itself, its use of past contributions, or its planned
intangible assets. An organization isn't required to use the use of contributions received, are fundraising expenses and
Modified Accelerated Cost Recovery System (MACRS) to must be reported in column (D). Don't report such expenses as
compute depreciation reported on Form 990. For an explanation program service expenses in column (B).
of acceptable methods for computing depreciation, see Pub.
946, How to Depreciate Property. If an amount is reported on Any method of allocating joint costs between columns (B) and
this line, the organization is required to maintain books and (D) must be reasonable under the facts and circumstances of
records to substantiate any amount reported. each case. Most states with reporting requirements for
charitable organizations and other organizations that solicit
Line 23. Insurance. Enter total insurance expenses other than contributions either require or allow reporting of joint costs under
insurance attributable to rental property (reported on Part VIII, AICPA Statement of Position 98-2 (SOP 98-2), Accounting for
line 6b). Don't report on this line payments made by Costs of Activities of Not-for-Profit Organizations and State and
organizations exempt under section 501(c)(8), (9), or (17) to Local Governmental Entities that Include Fundraising, now
obtain insurance benefits for members. Report those expenses codified in FASB Accounting Standards Codification 958-720,
on line 4. Don't report on this line the cost of employment-related Not-for-Profit Entities-Other Expenses (FASB ASC 958-720).
benefits such as health insurance, life insurance, or disability
insurance provided by the organization to or for its officers, Part X. Balance Sheet
directors, trustees, key employees, and other employees. Check the box in the heading of Part X if Schedule O (Form 990
Report the costs for officers, directors, trustees, and key or 990-EZ) contains any information pertaining to this part.
employees on Part IX, line 5; report the costs for other
disqualified persons on Part IX, line 6; and report the costs for All organizations must complete Part X. No substitute balance
other employees on Part IX, line 9. Report the costs for members sheet will be accepted. All references to Schedule D are to
on Part IX, line 4, not on Part IX, line 23. Don't report on this line Schedule D (Form 990), Supplemental Financial Statements.
property or occupancy-related insurance. Report those Column (A)— Beginning of year. In column (A), enter the
expenses on line 16. amount from the preceding year's Form 990, column (B). If the
Line 24. Other expenses. Enter the types and amounts of organization was excepted from filing Form 990 for the
expenses which weren't reported on lines 1 through 23. Include preceding year, enter amounts the organization would have
expenses for medical supplies incurred by health care/medical entered in column (B) for that year. If this is the organization's
organizations. Include payments by the organization to first year of existence, enter zeros on lines 16, 26, 33, and 34 in
professional fundraisers of fundraising expenses such as column (A).
printing, paper, envelopes, postage, mailing list rental, and Column (B)— End of year. When Schedule D (Form 990)
equipment rental, if the organization is able to distinguish these reporting is required for any item in Part X, it is only for the
expense amounts from fees for professional fundraising services end-of-year balance sheet figure reported in column (B). If this is
reportable on line 11e. Enter the four largest dollar amounts on the organization's final return, enter zeros on lines 16, 26, 33,
lines 24a through 24d and the total of all remaining and 34 in column (B).
miscellaneous expenses on line 24e. Don't include a separate
entry for “miscellaneous expenses,” “program expenses,” “other Line 1. Cash (non-interest-bearing). Enter the total funds that
expenses,” or a similar general category on lines 24a–d. If the the organization has in cash, including amounts held as “petty
amount on line 24e exceeds 10% of the amount on line 25, cash” at its offices or other facilities, and amounts held in banks
column (A), the organization must list the type and amount of in non-interest-bearing accounts. Don't include cash balances
each line 24e expense on Schedule O (Form 990 or 990-EZ). held in an investment account with a financial institution and
The organization must separately report the amount, if any, of reported on lines 11 through 13.
unrelated business income taxes that it paid or accrued Line 2. Savings and temporary cash investments. Enter the
during the tax year on line 24. combined total of amounts held in interest-bearing checking and
Line 25. Total functional expenses. Section 501(c)(3) and savings accounts, deposits in transit, temporary cash
501(c)(4) organizations. Add lines 1 through 24e and enter investments (such as money market funds, commercial paper,
the totals on line 25 in columns (A), (B), (C), and (D). and certificates of deposit), and U.S. Treasury bills or other
governmental obligations that mature in less than a year. Don't
All other organizations. Add lines 1 through 24e and enter the include cash balances held in an investment account with a
total on line 25 in column (A). financial institution and reported on lines 11 through 13. Don't
Line 26. Joint costs. Organizations that included in program include advances to employees or officers or refundable
service expenses (column (B) of Part IX) any joint costs from a deposits paid to suppliers or other independent contractors.
combined educational campaign and fundraising solicitation Report the income from these investments on Part VIII, line 3.
must disclose how the total joint costs of all such combined Line 3. Pledges and grants receivable, net. Enter the total of
activities were allocated in Part IX between education and (a) all pledges receivable, less any amounts estimated to be
fundraising. For instance, if the organization spent $100,000 on uncollectible, including pledges made by officers, directors,
joint costs and allocated 10% to education, it would report trustees, key employees, and highest compensated
$100,000 on line 26, column (A), $10,000 in column (B), and employees and (b) all grants receivable.
$90,000 in column (D). Any costs reported here aren't to be Organizations that follow ASC 958 can report the present
deducted from the other lines in Part IX on which they are value of the grants receivable as of each balance sheet date.
reported. Don't check the box unless the organization followed
SOP 98-2 (FASB ASC 958-720) in allocating such costs.

-48- Instructions for Form 990


Line 4. Accounts receivable, net. Enter the organization's The amount reported on line 10b must equal the total of
total accounts receivable (reduced by any allowance for doubtful Schedule D (Form 990), Part VI, column (c).
accounts) from the sale of goods and the performance of Line 10c. Column (A)—Beginning of year. Enter the cost or
services. Report claims against vendors or refundable deposits other basis of land, buildings, and equipment, net of any
with suppliers or others here, if not significant in amount. accumulated depreciation, as of the beginning of the year.
Otherwise, report them on line 15, Other assets. Report the net
amount of all receivables due from officers, directors, Line 10c. Column (B)—End of year. Enter line 10a minus
trustees, or key employees on line 5. Report receivables line 10b. The amount reported must equal the total of
(including loans and advances) due from other disqualified Schedule D (Form 990), Part VI, column (d).
persons on line 6. Receivables (including loans and advances) Line 11. Investments—publicly traded securities. Enter the
from employees who aren't current or former officers, directors, total value of publicly traded securities held by the
trustees, key employees, or disqualified persons must be organization as investments. Publicly traded securities include
reported on line 7. common and preferred stocks, bonds (including governmental
Lines 5 and 6. Loans and other receivables from current obligations such as bonds and Treasury bills), and mutual fund
and former officers, directors, trustees, key employees, shares that are listed and regularly traded in an over-the-counter
and creator or founder, substantial contributor, or 35% market or an established exchange and for which market
controlled entity or family member of any of these persons. quotations are published or are otherwise readily available.
Report on line 5 loans and other receivables due from current or Report dividends and interest from these securities on Part VIII,
former officers, directors, trustees, key employees, and line 3.
creator or founder, substantial contributor, or 35% Don't report on line 11 publicly traded stock for which the
controlled entity or family member of any of these persons. organization holds 5% or more of the outstanding shares of the
Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations must same class or publicly traded stock in a corporation that
also report on line 6 receivables due from other disqualified comprises more than 5% of the organization's total assets.
persons (for purposes of section 4958, see Appendix G), and Report these investments on line 12.
from persons described in section 4958(c)(3)(B). Include all
Line 12. Investments—other securities. Enter on this line the
amounts owed on secured and unsecured loans made to such
total value of all securities, partnerships, or funds that aren't
persons. Report interest from such receivables on Part VIII,
publicly traded. This includes stock in a closely held company
line 11. Don't report on line 5 or 6 (a) pledges or grants
whose stock isn't available for sale to the general public or which
receivable, which are to be reported on line 3 or (b) receivables
isn't widely traded. Other securities reportable on line 12 also
that are excepted from reporting on Schedule L (Form 990 or
include publicly traded stock for which the organization holds 5%
990-EZ), Part II (except for excess benefit transactions
or more of the outstanding shares of the same class, and
involving receivables). If the organization must report loans and
publicly traded stock in a corporation that comprises more than
other receivables on either line 5 or 6, it must answer “Yes” on
5% of the organization's total assets. Don't include
Part IV, line 26.
program-related investments.
Line 7. Notes and loans receivable, net. Enter the net If an amount is reported on this line that is 5% or more of the
amount of all notes receivable and loans receivable not listed on amount reported on Part X, line 16, answer “Yes” on Part IV,
lines 5 and 6, including receivables from unrelated third parties. line 11b and complete Schedule D (Form 990), Part VII. The
The term “unrelated third parties” includes independent amount reported on column (B), line 12, must equal the total of
contractors providing goods or services and employees who Schedule D (Form 990), Part VII, column (b).
aren't current or former officers, directors, trustees, key
employees, highest compensated employees, or Line 13. Program-related investments. Report here the total
disqualified persons. Don't include the following. book value of all investments made primarily to accomplish the
• Receivables reported on line 4. organization's exempt purposes rather than to produce income.
• Program-related investments reported on line 13. Examples of program-related investments include student loans
• Notes receivable acquired as investments reported on line 12. and notes receivable from other exempt organizations that
obtained the funds to pursue the filing organization's exempt
Line 8. Inventories for sale or use. Enter the amount of function.
materials, goods, and supplies held for future sale or use,
whether purchased, manufactured by the organization, or If the amount reported on this line is 5% or more of the
donated. amount reported on Part X, line 16, answer “Yes” on Part IV,
line 11c and complete Part VIII of Schedule D (Form 990). The
Line 9. Prepaid expenses and deferred charges. Enter the amount reported on Part X, column (B), line 13, must equal the
amount of short-term and long-term prepayments of expenses total of Schedule D (Form 990), Part VIII, column (b).
attributable to one or more future accounting periods. Examples
include prepayments of rent, insurance, or pension costs, and Line 14. Intangible assets. Report on this line the total value
expenses incurred for a solicitation campaign to be conducted in of all non-monetary, non-physical assets such as copyrights,
a future accounting period. patents, trademarks, mailing lists, or goodwill.

Line 10a. Land, buildings, equipment, and leasehold im- Line 15. Other assets. Report on this line the total book value
provements. Enter the cost or other basis of all land, buildings, of all assets held and not reported on lines 1 through 14.
equipment, and leasehold improvements held at the end of the If an amount is reported on this line that is 5% or more of the
year. Include both property held for investment purposes and amount reported on Part X, line 16, answer “Yes” on Part IV,
property used for the organization's exempt functions. If an line 11d and complete Schedule D (Form 990), Part IX. The
amount is reported here, answer “Yes” on Part IV, line 11a, and amount reported on Part X, column (B), line 15, must equal the
complete Schedule D (Form 990), Part VI. The amount reported total of Schedule D, Part IX, column (b).
on line 10a must equal the total of Schedule D, Part VI, columns Line 16. Total assets. Add the totals in columns (A) and (B),
(a) and (b). lines 1 through 15. The amounts on line 16 must equal the
Line 10b. Accumulated depreciation. Enter the total amount amounts on line 34 for both the beginning and end of the year.
of accumulated depreciation for the assets reported on line 10a. The organization must enter a zero or a dollar amount on this
line.

Instructions for Form 990 -49-


Line 17. Accounts payable and accrued expenses. Enter organization must also answer “Yes” on Part IV, line 11e, and
the total of accounts payable to suppliers, service providers, complete Schedule D (Form 990), Part X.
property managers, and other independent contractors, plus Line 26. Total liabilities. Add the totals in columns (A) and (B),
accrued expenses such as salaries payable, accrued payroll lines 17 through 25. The organization must enter a zero or a
taxes, and interest payable. dollar amount on this line.
Line 18. Grants payable. Enter the unpaid portion of grants
and awards that the organization has committed to pay other Net Assets and Fund Balances
organizations or individuals, whether or not the commitments FASB Accounting Standards Codification 958, Not-for-Profit
have been communicated to the grantees. Entities (ASC 958) provides standards for external financial
statements certified by an independent accountant for certain
Line 19. Deferred revenue. Report revenue that the
types of nonprofit organizations. ASC 958-10-15-5 doesn't apply
organization has received but not yet earned as of the balance
to credit unions, voluntary employees' beneficiary associations,
sheet date under its method of accounting.
supplemental unemployment benefit trusts, section 501(c)(12)
Line 20. Tax-exempt bond liabilities. Enter the amount of cooperatives, and other member benefit or mutual benefit
tax-exempt bonds (or other obligations) for which the organizations.
organization has a direct or indirect liability that were either
issued by the organization on behalf of a state or local While some states may require reporting according to FASB
governmental unit, or by a state or local governmental unit on ASC 958, the IRS doesn't. However, a Form 990 return prepared
behalf of the organization, and for which the organization has a according to ASC 958 will be acceptable to the IRS.
direct or indirect liability. Tax-exempt bonds include state or Organizations that follow ASC 958. If the organization follows
local bonds and any obligations, including direct borrowing from ASC 958, check the box above line 27, and complete lines 27
a lender, or certificates of participation, the interest on which is through 28 and lines 32 and 33. Classify and report net assets in
excluded from the gross income of the recipient for federal two groups in Part X (unrestricted, donor-restricted) based on
income tax purposes under section 103. the existence or absence of donor-imposed restrictions and the
See also Part IV, line 24a, and Schedule K (Form 990). nature of those restrictions. Enter the sum of the two classes of
net assets on line 32. On line 33, add the amounts on lines 26
Line 21. Escrow or custodial account liability. Enter the and 32 to show total liabilities and net assets. The amount on
amount of funds or other assets held in an escrow or custodial line 33 must equal the amount on line 16.
account for other individuals or organizations. Enter these
amounts only if the related assets (such as cash) are reported Effective for reporting years ending after December 15,
on lines 1 through 15 of this part. If an amount is reported on this ! 2017, ASC 958-205, Not-for-Profit Entities–Presentation
CAUTION of Financial Statements (ASC 958), addresses reporting
line, the organization must also answer “Yes” on Part IV, line 9,
and complete Schedule D (Form 990), Part IV. If the organization of donor-restricted endowments and board-designated
has signature authority over, or another interest in an escrow or (quasi) endowments. Further, most states have enacted the
custodial account for which it doesn't report the assets or Uniform Prudent Management of Institutional Funds Act
liabilities, it must also answer “Yes” on Part IV, line 9, and (UPMIFA). If the organization is subject to UPMIFA or ASC 958,
complete Schedule D, Part IV. it may affect the amounts reported on lines 27 through 28.
Example. A credit counseling organization collects amounts Line 27. Net assets without donor restrictions. Enter the
from debtors to remit to creditors and reports the amounts balance per books of net assets without donor restrictions. All
temporarily in its possession as cash on line 1 of the balance funds without donor-imposed restrictions must be reported on
sheet. It must then report the corresponding liability (the line 27, regardless of the existence of any board designations or
amounts to be paid to the creditors on the debtors' behalf) on appropriations.
line 21.
Line 28. Net assets with donor restrictions. Enter the
Lines 22–24. Enter on line 22 the unpaid balance of loans and balance per books of net assets with donor restrictions.
other payables (whether or not secured) to current and former Donors' restrictions may require that resources be used after a
officers, directors, trustees, key employees, creator or specified date (time restrictions), or that resources be used for a
founder, substantial contributor, or 35% controlled entity specified purpose (purpose restrictions), or both. Donors may
or family member of any of these persons, and persons also stipulate that assets, such as land or works of art, be used
described in section 4958(c)(3)(B). If the organization reports a for a specified purpose, be preserved, and not be sold or
loan payable on this line, it must answer “Yes” on Part IV, line 26. donated with stipulations that they be invested to provide a
Don't report on line 22 accrued but unpaid compensation owed permanent source of income.
by the organization. Don't report on line 22 loans and payables
excepted from reporting on Schedule L, Part II (except for Organizations that don't follow ASC 958. If the organization
excess benefit transactions involving receivables). doesn't follow ASC 958, check the box above line 29 and
complete lines 29 through 33. Report capital stock, trust
On line 23, enter the total amount of secured mortgages and
principal, or current funds on line 29. Report paid-in capital
notes payable to unrelated third parties that are secured by the
surplus or land, building, or equipment funds on line 30. Report
organization's assets as of the end of the tax year. Report on
retained earnings, endowment, accumulated income, or other
line 25 (and not line 23) any secured mortgages and notes
funds on line 31.
payable to related organizations.
On line 24, enter the total amount of notes and loans that are Line 29. Capital stock or trust principal, or current funds.
payable to unrelated third parties but aren't secured by the For corporations, enter the balance per books of capital stock
organization's assets. Report on line 25 (and not line 24) any accounts. Show par or stated value (or for stock with no par or
unsecured payables to related organizations. stated value, total amount received on issuance) of all classes of
stock issued and not yet canceled. For trusts, enter the amount
Line 25. Other liabilities. Enter the total amount of all liabilities in the trust principal or corpus. For organizations using the fund
not properly reportable on lines 17 through 24. Items properly method of accounting, enter the fund balances for the
reported on this line include federal income taxes payable and organization's current restricted and unrestricted funds.
secured or unsecured payables to related organizations. The

-50- Instructions for Form 990


Line 30. Paid-in or capital surplus, or land, building, and award or grant, and any other changes in net assets or fund
equipment fund. Enter the balance of paid-in capital in excess balances not listed on lines 5–8. Itemize these changes on
of par or stated value for all stock issued and not yet canceled, Schedule O (Form 990 or 990-EZ) and check the box in the
as recorded on the corporation's books. If stockholders or others heading of Part XI.
made donations that the organization records as paid-in capital,
include them here. Enter the fund balance for the land, building, Line 10. Combine the amounts on lines 3 through 9. The total
and equipment fund on this line. must equal the amount reported on Part X, line 32, column (B).

Line 31. Retained earnings, endowment, accumulated in- Part XII. Financial Statements and
come, or other funds. For corporations, enter the balance of
retained earnings as recorded on the corporation's books, or Reporting
similar account, minus the cost of any corporate treasury stock.
For trusts, enter the balance in the accumulated income or
similar account. For those organizations using the fund method Check the box in the heading of Part XII if Schedule O (Form
of accounting, enter the total of the fund balances for the net 990 or 990-EZ) contains any information pertaining to this part.
assets without donor restrictions funds, and the net assets Line 1. Accounting method. Indicate the method of
with donor restrictions funds, as well as balances of any other accounting used in preparing this return. See Part D, earlier.
funds not reported on lines 29 and 30. Provide an explanation on Schedule O (Form 990 or 990-EZ) (1)
if the organization changed its method of accounting from a prior
Line 32. Total net assets or fund balances. For
year, or (2) if the organization checked the “Other” accounting
organizations that follow ASC 958 enter the total of lines 27
method box.
through 28. For all other organizations, enter the total of lines 29
through 31. All filers must enter a zero or a dollar amount on this Line 2. Financial statements and independent accountant.
line. Answer “Yes” or “No” to indicate on line 2a or line 2b whether the
organization's financial statements for the tax year were
Line 33. Total liabilities and net assets/fund balances.
compiled, reviewed, or audited by an independent
Enter the total of line 26 and line 32. This amount must equal the
accountant. An accountant is independent if he or she meets the
amount on line 16. The organization must enter a zero or a dollar
standards of independence set forth by the American Institute of
amount on this line.
Certified Public Accountants (AICPA), the Public Company
Part XI. Reconciliation of Net Assets Accounting Oversight Board (PCAOB), or another similar body
that oversees or sets standards for the accounting or auditing
Check the box in the heading of Part XI if Schedule O (Form 990 professions.
or 990-EZ) contains any information pertaining to this part.
If “Yes” on either line 2a or 2b, answer “Yes” or “No” on line 2c
to indicate whether the organization has a committee that is
Line 1. Enter the amount of total revenue reported on Part VIII,
responsible under its governing documents or through
line 12, column (A).
delegation by its governing body for (i) overseeing the
compilation, review, or audit of the financial statements, and (ii)
Line 2. Enter the amount of total expenses reported on Part IX,
the selection of an independent accountant that compiled,
line 25, column (A).
reviewed, or audited the statements. Answer “Yes” only if both (i)
and (ii) apply. If this process has changed from the prior year,
Line 3. Enter the difference between lines 1 and 2.
describe on Schedule O (Form 990 or 990-EZ).
Line 4. Enter the amount of net assets or fund balances at the Line 3a. Single Audit Act and OMB Circular A-133. Answer
beginning of year reported on Part X, line 32, column (A). This “Yes,” if during the year the organization was required under the
amount should be the same amount reported on Part X, line 33, Single Audit Act of 1984, as amended in 1996, and OMB
column (B), for the prior year’s return. Circular A-133 to undergo an audit or audits because of its
receipt of federal contract awards. The Single Audit Act requires
Line 5. Report the net unrealized gains or losses on investments states, local governments, and nonprofit organizations that
reported in the organization's audited financial statements (or spend $750,000 or more of federal awards in a year to obtain an
other financial statements). This amount represents the change annual audit according to the Act.
in market value of investments that weren't sold or exchanged
Note. The Single Audit Act of 1984 and OMB Circular A-133 are
during the tax year.
superseded by Uniform Guidance, 2 C.F.R. Part 200, Subpart F,
and now requires states, local governments, and nonprofit
Line 6. Report the value of services or use of facilities donated
organizations that expend $750,000 (previously was $500,000)
to the organization (net of services or use of facilities donated by
or more of federal awards in a year to obtain an annual audit.
the organization) reported as income or expense in the financial
statements. Line 3b. Required audits. If “Yes” on line 3a, indicate whether
the organization has undergone the required audit or audits.
Line 8. Report the net prior period adjustments during the tax Answer “Yes,” if the audit was completed or in progress during
year reported in the financial statements. Prior period the organization's tax year. If the answer to line 3b is “No,”
adjustments are corrections of errors in financial statements of explain on Schedule O (Form 990 or 990-EZ) why the
prior years, or changes in accounting principles applied to such organization hasn't undergone any required audits and describe
years. The errors may include math errors, mistakes in applying any steps taken to undergo such audits.
accounting principles, or oversight or misuse of facts that existed
at the time the financial statements were prepared. Paperwork Reduction Act Notice. We ask for the information
on these forms to carry out the Internal Revenue laws of the
Line 9. Enter the total amount of other changes in net assets or United States. You are required to give us the information. We
fund balances during the year. Amounts to report here include need it to ensure that you are complying with these laws and to
losses on uncollectible pledges, refunds of contributions and allow us to figure and collect the right amount of tax. You are not
program service revenue, reversal of grant expenses, any required to provide the information requested on a form that is
difference between FMV and book value of property given as an subject to the Paperwork Reduction Act unless the form displays

Instructions for Form 990 -51-


a valid OMB control number. Books or records relating to a form Fiscal Year 2020 Form 990 Series Tax Compliance
or its instructions must be retained as long as their contents may
Cost Estimates
become material in the administration of any Internal Revenue
law. Generally, tax returns and return information are
Form 990 Form 990-EZ Form 990-PF Form 990-T Form 990-N
confidential, as required by section 6103. However, certain
returns and return information of tax exempt organizations and Projections of
trusts are subject to public disclosure and inspection, as the Number
of Returns to
provided by section 6104. be Filed with
IRS 315,762 232,345 118,192 198,798 741,133
Estimates of Taxpayer Burden. These include Forms in the
990 series and attachments and 1023, 1024, 1028, 5578, Estimated
Average Total
5884-C, 8038, 8038-B, 8038-CP, 8038-G, 8038-GC, 8038-R, Time (Hours) 85 45 47 40 2
8038-T, 8038-TC, 8328, 8718, 8282, 8453-EO, 8453-X, 8868,
Estimated
8870, 8871, 8872, 8879-EO, 8886-T, 8899 and their schedules Average Total
and all the forms tax-exempt organizations attach to their Out-of-Pocket
information returns. Time spent and out-of-pocket costs are Costs $2,600 $500 $2,000 $1,500 $10
presented separately. Time burden includes the time spent Estimated
preparing to file and to file, with recordkeeping representing the Average Total
Monetized
largest component. Out-of-pocket costs include any expenses Burden $8,000 $1,200 $3,900 $4,400 $30
incurred by tax exempt organizations to prepare and submit their
Estimated
tax returns. Examples include tax return preparation and Total Time
submission fees, postage and photocopying costs, and tax (Hours) 26,760,000 10,500,000 5,510,000 8,040,000 1,630,000
preparation software costs. Note that these estimates don't Estimated
include burden associated with post-filing activities. IRS Total
operational data indicate that electronically prepared and filed Out-of-Pocket
returns have fewer arithmetic errors, implying lower post-filing Costs (Note.
Totals may
burden. not add due
to rounding.) $835,700,000 $127,500,000 $236,200,000 $290,300,000 $6,800,000
Reported time and cost burdens are national averages and
don't necessarily reflect a “typical” case. Most tax exempt Note. Amounts above are for FY2020. Reported time and cost burdens are national averages
and don't necessarily reflect a “typical” case. Most taxpayers experience lower than average
organizations experience lower than average burden, with tax burden, with taxpayer burden varying considerably by taxpayer type. Detail may not add due
exempt organization burden varying considerably by taxpayer to rounding.
type. For instance, the estimated average time burden for all tax
exempt organizations filing Forms 990, 990-EZ, 990-PF, 990-T, Comments and suggestions.
and 990-N and related forms is 32.7 hours, with an average cost
If you have comments concerning the accuracy of these time
of $932 per return. This average includes all associated forms
estimates or suggestions for making this form simpler, we would
and schedules, across all preparation methods and tax exempt
be happy to hear from you. You can send us comments from
organization activities.
IRS.gov/FormComments. Or you can write to the Internal
Revenue Service, Tax Forms and Publications Division, 1111
Constitution Ave. NW, IR-6526, Washington, DC 20224. Don't
send your return to this address. Instead, see the General
Instructions, Section E, When, Where, and How to File, earlier,
for the location for filing your return.

-52- Instructions for Form 990


Business Activity Codes
The codes listed in this section are a to categorize, select the appropriate code more than one type of activity. Avoid
selection from the North American from the NAICS website at 2017 NAICS using codes that describe the
Industry Classification System (NAICS) Census website. Select the most specific organization rather than the
that should be used in completing Form 6-digit code available that describes the income-producing activity.
990, Part VIII, lines 2 and 11. If you don't activity producing the income being
see a code for the activity you are trying reported. Note that most codes describe
Business Activity Codes

Agriculture, Forestry, Hunting 511140 Directory and mailing list 533110 Lessors of nonfinancial 621300 Offices of other health
publishers (except Internet) intangible assets (except practitioners
and Fishing 511190 Other publishers (except copyrighted works) 621400 Outpatient care centers
Internet)
Code Professional, Scientific, and 621500 Medical and diagnostic
512000 Motion picture and sound laboratories
110000 Agriculture, forestry, hunting and recording industries Technical Services
fishing 621610 Home health care services
515100 Radio and television Code 621910 Ambulance services
111000 Crop production broadcasting (except Internet)
541100 Legal services 621990 All other ambulatory health care
Mining 517000 Telecommunications (including
541990 Consumer credit counseling services
paging, cellular, satellite, cable,
Code other telecommunications, and services 623000 Nursing and residential care
Internet service providers) 541200 Accounting, tax preparation, facilities
211120 Crude petroleum extraction
519100 Other information services bookkeeping, and payroll 623990 Other residential care facilities
211130 Natural gas extraction services
(including news syndicates and 624100 Individual and family services
212000 Mining (except oil and gas) libraries) 541300 Architectural, engineering, and 624110 Community centers (except rec.
Utilities 519130 Internet Publishing related services only), youth Adoption agencies
541380 Testing laboratories 624200 Community food and housing,
Code Data Processing Services 541511 Custom computer programming and emergency and other relief
221000 Utilities Code services services
Construction 518210 Data Processing, Hosting, and 541519 Other computer-related services 624210 Meal delivery programs, Soup
Related Services 541610 Management consulting services kitchens, or Food banks
Code 624310 Vocational rehabilitation services
Finance and Insurance 541700 Scientific research and
230000 Construction development services 624410 Child day care services
236000 Construction of buildings Code 541800 Advertising and related services
522100 Depository credit intermediation
Arts, Entertainment, and
Manufacturing 541860 Direct mail advertising
(including commercial banking,
541900 Other professional, scientific, Recreation
Code savings institutions, and credit
unions) and technical services code
310000 Manufacturing
323100 Printing and related support 522200 Nondepository credit Management of Companies and 711110 Theater companies and dinner
intermediation (including credit theaters
activities Enterprises
card issuing and sales financing) 711120 Dance companies
Wholesale Trade 522210 Credit card issuing Code 711130 Musical groups and artists
Code 522220 Sales Financing 551111 Offices of bank holding 711190 Other performing art companies
423000 Merchant wholesalers, durable 522291 Consumer lending companies 711210 Spectator sports (including
goods 522292 Real estate credit 551112 Offices of other holding sports clubs and racetracks)
424000 Merchant wholesalers, 522298 Other nondepository credit companies 711300 Promoters of performing arts,
nondurable goods intermediation sports and similar events
Administrative and Support
523000 Securities, commodity contracts, 713110 Amusement and theme parks
Retail Trade and other financial investments Services 713200 Gambling industries
Code and related activities 713910 Golf courses and country clubs
Code
441100 Automobile dealers 523920 Portfolio management 713940 Fitness and recreational sports
561000 Administrative and support
442000 Furniture and home furnishings 523930 Investment advice services centers
stores 524113 Direct life insurance carriers 561300 Employment services 713990 All other amusement and
443142 Computer and software stores 524114 Direct health and medical recreation industries (including
561439 Other business service centers skiing facilities, marinas, and
444100 Building materials and supplies insurance carriers
561499 All other business support bowling centers)
dealers 524126 Direct property and casualty services
445100 Grocery stores insurance carriers Accommodation and Food
561500 Travel arrangement and
445200 Specialty food stores 524130 Reinsurance carriers reservation services
446110 Pharmacies and drug stores 524292 Third-party administration of Services
561520 Tour operators
insurance and pension funds Code
446199 All other health and personal 561700 Services to buildings and
care stores 524298 All other insurance-related dwellings 721000 Accommodation
activities
448000 Clothing and clothing 721110 Hotels (except casino hotels)
accessories stores 525100 Insurance and employee benefit Waste Management and and motels
funds
451110 Sporting goods stores
525920 Trusts, estates, and agency
Remediation Services 721210 RV (recreational vehicle) parks
451211 Book stores and recreational camps
accounts Code
452000 General merchandise stores 721310 Rooming and boarding houses,
525990 Other Financial vehicles 562000 Waste management and dormitories, and workers’ camps
453000 Miscellaneous store retailers (including mortgage REITs) remediation services (sanitary 722320 Caterers
453220 Gift, novelty, and souvenir stores services)
Real Estate and Rental Leasing 722410 Drinking places (alcoholic
453310 Used merchandise stores Educational Services beverages)
454110 Electronic shopping and Code
Code 722511 Full-service restaurants
mail-order houses 531110 Lessors of residential buildings
and dwellings (including equity 611420 Computer training 722513 Limited-service restaurants
Transportation and REITs) 611430 Professional and management 722514 Cafeterias and buffets
Warehousing 531120 Lessors of nonresidential development training 722515 Snack and non-alcoholic
buildings (except 616000 Other schools and instruction beverage bars
Code minwarehouses) (including (other than elementary and
485000 Transit and ground passenger equity REITs) secondary schools or colleges
Other Services
transportation 531190 Lessors of other real estate and universities, which should Code
493000 Warehousing and storage property (including equity REITs) select a code to describe their 811000 Repair and maintenance
531310 Real estate property managers unrelated activities)
Information 812300 Drycleaning and laundry services
531390 Other activities related to real 611710 Educational support services
estate 812900 Other personal services
Code Healthcare and Social
532000 Rental and leasing services 812930 Parking lots and garages
511110 Newspaper publishers (except
Internet) 532420 Office machinery and equipment Assistance
511120 Periodical publishers (except rental and leasing
Code
Internet)
621110 Offices of physicians
511130 Book publishers (except Internet)

Instructions for Form 990 -53-


Business Activity Codes (Continued)

Other 900002 Rental of personal property


900003 Passive income activities with
Code controlled organizations
900001 Investment activities of section 900004 Exploited exempt activities
501(c)(7), (9), or (17) 900099 Other activity
organizations

Glossary
NOTES: • Words in bold within a definition are defined elsewhere within the Glossary.
• All section references are to the Internal Revenue Code (Title 26 of U.S. Code)
or regulations under Title 26, unless otherwise specified.
• Definitions are for purposes of filing Form 990 (and Schedules) only.
35% controlled entity An entity that is owned, directly or indirectly (for example, under constructive
ownership rules of section 267(c)), by a given person, such as the
organization's current or former officers, directors, trustees, or key
employees listed on Form 990, Part VII, Section 1, or the family members
thereof (listed persons) as follows:
1. A corporation in which listed persons own more than 35% of the total
combined voting power;
2. A partnership in which listed persons own more than 35% of the profits
interest; or
3. A trust or estate in which listed persons own more than 35% of the
beneficial interest.
Accountable plan A reimbursement or other expense allowance arrangement that satisfies the
requirements of section 62(c) by meeting the requirements of business
connection, substantiation, and returning amounts in excess of substantiated
expenses. See Regulations section 1.62-2(c)(2).
Activities conducted outside the United States For purposes of Schedule F (Form 990), Statement of Activities Outside the
United States, include grantmaking, fundraising, unrelated trade or
business, program services, program-related investments, other
investments, or maintaining offices, employees, or agents in particular
regions outside the United States.
Applicable tax-exempt organization A section 501(c)(3), 501(c)(4), or 501(c)(29) organization that is tax-exempt
under section 501(a), or that was such an organization at any time during the
5-year period ending on the day of the excess benefit transaction.
Art See Works of art.
ASC 740 See FIN 48 (ASC 740).
ASC 958 Financial Accounting Standards Board, Accounting Standards Codification 958
(ASC 958) provides standards for external financial statements certified by an
independent accountant for certain types of nonprofit organizations. ASC 958
doesn't apply to credit unions, voluntary employees' beneficiary associations,
supplemental unemployment benefit trusts, section 501(c)(12) cooperatives,
and other member benefit or mutual benefit organizations.
While some states may require reporting according to ASC 958, the IRS
doesn't. However, a Form 990 return prepared according to ASC 958 will be
acceptable to the IRS.
ASC 2016–14 Accounting Standards Update 2016-14 is codified in Accounting Standards
Codification 958, Not-for-Profit Entities (ASC 958).
Audit A formal examination of an organization's financial records and practices by an
independent, certified public accountant with the objective of issuing a report
on the organization's financial statements as to whether those statements are
fairly stated according to generally accepted accounting principles (or other
recognized comprehensive basis of accounting).
Audited financial statements Financial statements accompanied by a formal opinion or report prepared by
an independent, certified public accountant with the objective of assessing the
accuracy and reliability of the organization's financial statements.

-54- Instructions for Form 990


Audit committee A committee, generally established by the governing body of an organization,
with the responsibilities to oversee the organization's financial reporting
process, monitor choice of accounting policies and principles, monitor internal
control processes, or oversee hiring and performance of any external auditors.
Bingo A game of chance played with cards that are generally printed with five rows of
five squares each. Participants place markers over randomly called numbers
on the cards in an attempt to form a pre-selected pattern such as a horizontal,
vertical, or diagonal line, or all four corners. The first participant to form the
pre-selected pattern wins the game. To be a bingo game, the game must be of
the type described in which wagers are placed, winners are determined, and
prizes or other property are distributed in the presence of all persons placing
wagers in that game. Satellite, Internet, and progressive or event bingo aren't
bingo, because they are conducted in many different places simultaneously,
and the winners aren't all present when the wagers are placed, the winners are
determined, and the prizes are distributed. Thus, all revenue and expenses
associated with satellite, Internet, and progressive or event bingo generally
should be included under pull tabs. Certain bingo games within a hybrid
gaming event (such as progressive or event bingo) can also qualify as bingo if
the individual game meets the preceding definition of bingo.
Board-designated endowment See quasi-endowment.
Bond issue An issue of two or more bonds that are:
1. Sold at substantially the same time;
2. Sold under the same plan of financing; and
3. Payable from the same source of funds.
See Regulations section 1.150-1(c).
Business relationship For purposes of Part VI, line 2, business relationships between two persons
include the following.
1. One person is employed by the other in a sole proprietorship or by an
organization with which the other is associated as a trustee, director, officer,
or greater-than-35% owner.
2. One person is transacting business with the other (other than in the
ordinary course of either party's business on the same terms as are generally
offered to the public), directly or indirectly, in one or more contracts of sale,
lease, license, loan, performance of services, or other transaction involving
transfers of cash or property valued in excess of $10,000 in the aggregate
during the organization's tax year. Indirect transactions are transactions with an
organization with which the one person is associated as a trustee, director,
officer, or greater-than-35% owner. Such transactions don't include charitable
contributions to tax-exempt organizations.
3. The two persons are each a director, trustee, officer, or
greater-than-10% owner in the same business or investment entity (but not in
the same tax-exempt organization).
Ownership is measured by stock ownership (either voting power or value) of
a corporation, profits or capital interest in a partnership or limited liability
company, membership interest in a nonprofit organization, or beneficial interest
in a trust. Ownership includes indirect ownership (for example, ownership in an
entity that has ownership in the entity in question); there can be ownership
through multiple tiers of entities.
Cash contributions Contributions received in the form of cash, checks, money orders, credit card
charges, wire transfers, and other transfers and deposits to a cash account of
the organization.
Central organization The organization, sometimes referred to as the parent organization, that holds
a group exemption letter for one or more subordinate organizations under
its general supervision and control.
CEO, executive director, or top management See top management official. “CEO” stands for chief executive officer.
official

Instructions for Form 990 -55-


Certified historic structure Any building or structure listed in the National Register of Historic Places as
well as any building certified as being of historic significance to a registered
historic district. See section 170(h)(4)(B) for special rules that apply to
contributions made after August 17, 2006.
Church Certain characteristics are generally attributed to churches. These attributes of
a church have been developed by the IRS and by court decisions. They
include: distinct legal existence; recognized creed and form of worship; definite
and distinct ecclesiastical government; formal code of doctrine and discipline;
distinct religious history; membership not associated with any other church or
denomination; organization of ordained ministers; ordained ministers selected
after completing prescribed courses of study; literature of its own; established
places of worship; regular congregations; regular religious services; Sunday
schools for the religious instruction of the young; schools for the preparation of
its ministers. The IRS generally uses a combination of these characteristics,
together with other facts and circumstances, to determine whether an
organization is considered a church for federal tax purposes. A convention or
association of churches is generally treated like a church for federal tax
purposes. See Pub. 1828, Tax Guide for Churches and Religious
Organizations.
Closely held stock Generally, shares of stock in a closely held company that isn't available for sale
to the general public or which isn't widely traded (see further explanation in the
instructions for Part X, line 12, and Schedule M (Form 990), Noncash
Contributions, line 10).
Collectibles Include autographs, sports memorabilia, dolls, stamps, coins, books (other
than books and publications reported on line 4 of Schedule M), gems, and
jewelry (other than costume jewelry reportable on line 5 of Schedule M).
Collections of works of art, historical Include collections, as described in ASC 958-360-45, of works of art,
treasures, and other similar assets historical treasures, and other similar assets held for public exhibition,
education, or research in furtherance of public service.
Compensation Unless otherwise provided, all forms of cash and noncash payments or
benefits provided in exchange for services, including salary and wages,
bonuses, severance payments, deferred payments, retirement benefits, fringe
benefits, and other financial arrangements or transactions such as personal
vehicles, meals, housing, personal and family educational benefits,
below-market loans, payment of personal or family travel, entertainment, and
personal use of the organization's property. Compensation includes payments
and other benefits provided to both employees and independent
contractors in exchange for services. See also deferred compensation,
nonqualified deferred compensation, and reportable compensation.
Compilation (compiled financial statements) A compilation is a presentation of financial statements and other information
that is the representation of the management or ownership of an organization
and which hasn't been reviewed or audited by an independent accountant.
Conflict of interest policy A policy that defines conflict of interest, identifies the classes of individuals
within the organization covered by the policy, facilitates disclosure of
information that can help identify conflicts of interest, and specifies procedures
to be followed in managing conflicts of interest. A conflict of interest arises
when a person in a position of authority over an organization, such as an
officer, director, or manager, can benefit financially from a decision he or she
could make in such capacity, including indirect benefits such as to family
members or businesses with which the person is closely associated. For this
purpose, a conflict of interest doesn't include questions involving a person's
competing or respective duties to the organization and to another organization,
such as by serving on the boards of both organizations, that don't involve a
material financial interest of, or benefit to, such person. For a description of
“conflict of interest” for purposes of determining whether governing body
members who are reviewing a potential excess benefit transaction have a
conflict of interest, pursuant to Regulations section 53.4958-6(c)(1)(iii), see
instructions for Part VI, line 15.

-56- Instructions for Form 990


Conservation easement A restriction (granted in perpetuity) on the use that may be made of real
property granted exclusively for conservation purposes. Conservation
purposes include preserving land areas for outdoor recreation by, or for the
education of, the general public; protecting a relatively natural habitat of fish,
wildlife, or plants, or a similar ecosystem; preserving open space, including
farmland and forest land, where such preservation will yield a significant public
benefit and is either for the scenic enjoyment of the general public or pursuant
to a clearly defined federal, state, or local governmental conservation policy;
and preserving a historically important land area or a certified historic structure.
For more information, see section 170(h) and Notice 2004-41, 2004-2 C.B. 31.
Contributions Unless otherwise provided, includes donations, gifts, bequests, grants, and
other transfers of money or property to the extent that adequate consideration
isn't provided in exchange and that the contributor intends to make a gift,
whether or not made for charitable purposes. A transaction can be partly a sale
and partly a contribution, but discounts provided on sales of goods in the
ordinary course of business shouldn't be reported as contributions. Neither
donations of services (such as the value of donated advertising space,
broadcast air time, or discounts on services) nor donations of use of materials,
equipment, or facilities should be reported as contributions. For purposes of
Form 990, a distribution to a section 501(c)(3) organization from a split interest
trust (for example, charitable remainder trust, charitable lead trust) is reportable
as a contribution. See also cash contributions and noncash contributions.

Instructions for Form 990 -57-


Control For purposes of determining related organizations:

Control of a nonprofit organization (or other organization without owners or


persons having beneficial interests, whether the organization is taxable or
tax-exempt)
One or more persons (whether individuals or organizations) control a nonprofit
organization if they have the power to remove and replace (or to appoint, elect,
or approve or veto the appointment or election of, if such power includes a
continuing power to appoint, elect, or approve or veto the appointment or
election of, periodically or in the event of vacancies) a majority of the nonprofit
organization's directors or trustees, or a majority of members who elect a
majority of the nonprofit organization's directors or trustees. Such power can be
exercised directly by a (parent) organization through one or more of the
(parent) organization's officers, directors, trustees, or agents, acting in their
capacity as officers, directors, trustees, or agents of the (parent) organization.
Also, a (parent) organization controls a (subsidiary) nonprofit organization if a
majority of the subsidiary's directors or trustees are trustees, directors, officers,
employees, or agents of the parent.

Control of a stock corporation


One or more persons (whether individuals or organizations) control a stock
corporation if they own more than 50% of the stock (by voting power or value)
of the corporation.

Control of a partnership or limited liability company


One or more persons control a partnership if they own more than 50% of the
profits or capital interests in the partnership (including a limited liability
company treated as a partnership or disregarded entity for federal tax
purposes, regardless of the designation under state law of the ownership
interests as stock, membership interests, or otherwise). A person also controls
a partnership if the person is a managing partner or managing member of a
partnership or limited liability company which has three or fewer managing
partners or managing members (regardless of which partner or member has
the most actual control), or if the person is a general partner in a limited
partnership which has three or fewer general partners (regardless of which
partner has the most actual control). For this purpose, a “managing partner” is a
partner designated as such under the partnership agreement, or regularly
engaged in the management of the partnership even though not so designated.

Control of a trust with beneficial interests


One or more persons control a trust if they own more than 50% of the beneficial
interests in the trust. A person's beneficial interest in a trust shall be determined
in proportion to that person's actuarial interest in the trust as of the end of the
tax year. See Regulations sections 301.7701-2, 3, and 4 for more information
on classification of corporations, partnerships, disregarded entities, and trusts.
Control can be indirect. See the Schedule R (Form 990) instructions for a
description of indirect control.
Controlled entity An organization controlled by a controlling organization under section
512(b)(13). A controlled entity may be a nonprofit organization. For the
definition of control in this context, see section 512(b)(13)(D) and Regulations
section 1.512(b)-1(l)(4) (substituting “more than 50%” for “at least 80%” in the
regulation, for purposes of this definition). Controlled entities are a subset of
related organizations. For purposes of Form 990, controlled entities don't
include disregarded entities of the filing organization.

-58- Instructions for Form 990


Controlling organization under section 512(b) An exempt organization that controls a controlled entity. Section 512(b)(13)
(13) treats payments of interest, annuity, royalties, and rent from a controlled entity
to a controlling organization as unrelated business taxable income under
certain circumstances. Control in this context means (i) in the case of a
corporation, ownership (by vote or value) of more than 50% of the stock in such
corporation, (ii) in the case of a partnership, ownership of more than 50% of the
profits interests or capital interests in such partnership, or (iii) in any other case,
ownership of more than 50% of the beneficial interests in the entity. Section
318 (relating to constructive ownership of stock) shall apply for purposes of
determining ownership of stock in a corporation. Similar principles shall apply
for purposes of determining ownership of interests in any other entity.
Core form The Form 990, Return of Organization Exempt From Income Tax Under section
501(c), 527, or 4947(a)(1) of the Internal Revenue Code (except for private
foundations). It doesn't include any schedules that may be attached to Form
990.
Credit counseling services Include the providing of information to the general public on budgeting,
personal finance, and saving and spending practices, or assisting individuals
and families with financial problems by providing them with counseling. See
section 501(q)(4)(A).
Current year The tax year for which the Form 990 is being filed; see also fiscal year.
Debt management plan services Services related to the repayment, consolidation, or restructuring of a
consumer's debt, including the negotiation with creditors of lower interest rates,
the waiver or reduction of fees, and the marketing and processing of debt
management plans. See section 501(q)(4)(B).
Defeasance escrow An irrevocable escrow established to redeem the bonds on their earliest call
date in an amount that, together with investment earnings, is sufficient to pay all
the principal of, and interest and call premiums on, bonds from the date the
escrow is established to the earliest call date. See Regulations section
1.141-12(d)(5).
Deferred compensation Compensation that is earned or accrued in, or is attributable to, one year and
deferred to a future year for any reason, whether or not funded, vested,
qualified or nonqualified, or subject to a substantial risk of forfeiture. However,
a deferral of compensation that causes an amount to be deferred from the
calendar year ending with or within the tax year to a date that isn't more than 2
½ months after the end of the calendar year ending with or within the tax year
isn't treated as deferred compensation for purposes of Form 990, if such
compensation is currently reported as reportable compensation. Deferred
compensation may or may not be included in reportable compensation for
the current year.
Director See director or trustee.
Director or trustee Unless otherwise provided, a member of the organization's governing body at
any time during the tax year, but only if the member has any voting rights. A
member of an advisory board that doesn't exercise any governance authority
over the organization isn't considered a director or trustee.
Disqualified person A. For purposes of section 4958; Form 990, Parts IX and X; and Schedule L
(Form 990 or 990-EZ), Transactions With Interested Persons, Parts I and II, any
person (including an individual, corporation, or other entity) who was in a
position to exercise substantial influence over the affairs of the applicable
tax-exempt organization at any time during a 5-year period ending on the
date of the transaction. If the 5-year period ended within the organization's tax
year, the organization may treat the person as a disqualified person for the
entire tax year. Persons who hold certain powers, responsibilities, or interests
are among those who are in a position to exercise substantial influence over
the affairs of the organization.

Instructions for Form 990 -59-


A disqualified person includes:
• A disqualified person's family member,
• A 35% controlled entity of a (1) disqualified person and/or (2) family members
of the disqualified person,
• A donor or donor advisor to a donor advised fund, or
• An investment advisor of a sponsoring organization.
The disqualified persons of a supported organization include the
disqualified persons of a section 509(a)(3) supporting organization that
supports the supported organization.
See Appendix G for more information on disqualified persons and section
4958 excess benefit transactions.
B. Under section 4946, a disqualified person includes:
1. A substantial contributor, which is any person who gave an aggregate
amount of more than $5,000, if that amount is more than 2% of the total
contributions the foundation or organization received from its inception
through the end of the year in which that person's contributions were received.
If the organization is a trust, a substantial contributor includes the creator of the
trust (without regard to the amount of contributions the trust received from the
creator and related persons). Any person who is a substantial contributor at any
time generally remains a substantial contributor for all future periods even if
later contributions by others push that person's contributions below the 2%
figure discussed above. Gifts from the contributor's spouse are treated as gifts
from the contributor. Gifts are generally valued at FMV as of the date the
organization received them.
2. A foundation manager, defined as an officer, director, or trustee of the
organization or any individual having powers or responsibilities similar to those
of officers, directors, or trustees.
3. An owner of more than 20% of the voting power of a corporation, profits
interest of a partnership, or beneficial interest of a trust or an unincorporated
enterprise that is a substantial contributor to the organization.
4. A family member of an individual in the first three categories. For this
purpose, “family member” includes only the individual's spouse, ancestors,
children, grandchildren, great-grandchildren, and the spouses of children,
grandchildren, and great-grandchildren.
5. A corporation, partnership, trust, or estate in which persons described in
(1) through (4) above own more than 35% of the voting power, profits interest,
or beneficial interest.
For purposes of section 509(a)(2), as referenced in Schedule A (Form 990
or 990-EZ), Public Charity Status and Public Support, a disqualified person is
defined in section 4946, except that it doesn't include an organization
described in section 509(a)(1).
For purposes of section 509(a)(3), as referenced in Schedule A (Form 990
or 990-EZ), a disqualified person is defined in section 4946, except that it
doesn't include a foundation manager or an organization described in section
509(a)(1) or 509(a)(2).
Disregarded entity or entities An entity wholly owned by the organization that is generally not treated as a
separate entity for federal tax purposes (for example, single-member limited
liability company of which the organization is the sole member). See
Regulations sections 301.7701-2 and 3. A disregarded entity generally must
use the EIN of its sole member. An exception applies to employment taxes: for
wages paid to employees of a disregarded entity, the disregarded entity must
file separate employment tax returns and use its own EIN on such returns. See
Regulations sections 301.6109-1(h) and 301.7701-2(c)(2)(iv).
Domestic government See governmental unit.
Domestic individual An individual who lives or resides in the United States and isn't a foreign
individual.

-60- Instructions for Form 990


Domestic organization A corporation or partnership is domestic if created or organized in the United
States or under the law of the United States or of any state or possession. A
trust is domestic if a court within the United States or a U.S. possession is
able to exercise primary supervision over the administration of the trust, and
one or more U.S. persons (or persons in possessions of the United States)
have the authority to control all substantial decisions of the trust.
Donor advised fund A fund or account:
1. That is separately identified by reference to contributions of a donor or
donors;
2. That is owned and controlled by a sponsoring organization; and
3. For which the donor or donor advisor has or reasonably expects to
have advisory privileges in the distribution or investment of amounts held in the
donor advised funds or accounts because of the donor's status as a donor.
A donor advised fund doesn't include any fund or account:
1. That makes distributions only to a single identified organization or
governmental entity, or
2. In which a donor or donor advisor gives advice about which individuals
receive grants for travel, study, or other similar purposes, if:
a. The donor or donor advisor's advisory privileges are performed
exclusively by such person in his or her capacity as a committee member in
which all of the committee members are appointed by the sponsoring
organization;
b. No combination of donors or donor advisors (and related persons as
defined below) directly or indirectly control the committee; and
c. All grants from the fund or account are awarded on an objective and
nondiscriminatory basis following a procedure approved in advance by the
board of directors of the sponsoring organization. The procedure must be
designed to ensure that all grants meet the requirements of section 4945(g)(1),
(2), or (3); or
3. That the IRS exempts from being treated as a donor advised fund
because either such fund or account is advised by a committee not directly or
indirectly controlled by the donor or donor advisor or such fund benefits a
single identified charitable purpose. For example, see Section 5.01 of Notice
2006-109, 2006-51 I.R.B. 1121, and any future related guidance.
Donor advisor Any person appointed or designated by a donor to advise a sponsoring
organization on the distribution or investment of amounts held in the donor's
donor advised fund.
Donor-Imposed Restriction A donor stipulation (donors include other types of contributors, including
makers of certain grants) that specifies a use for a contributed asset that is
more specific than broad limits resulting from:
• The nature of the not-for-profit entity
• The environment in which it operates; or
• The purposes specified in its articles of incorporation or bylaws or comparable
documents for an unincorporated association.
Some donors impose restrictions that are temporary in nature, for example,
stipulating that resources may be used only after a specified date, for particular
programs or services, or to acquire buildings and or equipment. Other donors
impose restrictions that are perpetual in nature, for example, stipulating that
resources be maintained in perpetuity.
Donor-Restricted Endowment Fund An endowment fund created by a donor stipulation (donors include other types
of contributors, including makers of certain grants) requiring investment of the
gift in perpetuity or for a specified term. Some donors or laws may require that a
portion of income, gains, or both be added to the gift and invested subject to
similar restrictions.
EIN Employer identification number, a nine-digit number. Use Form SS-4 to apply
for an EIN.

Instructions for Form 990 -61-


Employee Any individual who, under the usual common law rules applicable in
determining the employer-employee relationship, has the status of an
employee, and any other individual who is treated as an employee for federal
employment tax purposes under section 3121(d). See Pub. 1779 for more
information.
Endowment Fund An established fund of cash, securities, or other assets to provide income for
the maintenance of a not-for-profit entity. The use of the assets of the fund may
be with or without donor-imposed restrictions. Endowment funds generally are
established by donor-restricted gifts and bequests to provide a source of
income perpetuity or for a specified period. Alternatively, a not-for-profit's
governing board may earmark a portion of its net assets (see
Quasi-endowment).
Escrow or custodial account Refers to an account (whether a segregated account at a financial institution or
a set-aside on the organization's books and records) over which the
organization has signature authority, in which the funds are held for the benefit
of other organizations or individuals, whether or not the funds are reported on
Part X, line 21, and whether or not the account is labeled as “escrow account,”
“custodial account,” “trust account,” or some similar term. An escrow or
custodial account doesn't include a split-interest trust (or the beneficial interest
in such trust) described in section 4947(a)(2) for which the filing organization is
a trustee, other than a trust in the trade or business of lending money, repairing
credit, or providing debt management plan services, payment processing, or
similar services.
Excess benefit transaction In the case of an applicable tax-exempt organization, any transaction in
which an excess benefit is provided by the organization, directly or indirectly to,
or for the use of, any disqualified person, as defined in section 4958. Excess
benefit generally means the excess of the economic benefit received from the
applicable organization over the consideration given (including services) by a
disqualified person, but see the special rules below regarding donor advised
funds and supporting organizations. See Appendix G for more information.
Donor advised fund. For a donor advised fund, an excess benefit
transaction also includes a grant, loan, compensation, or similar payment
from the fund to a:
• Donor or donor advisor;
• Family member of a donor or donor advisor;
• 35% controlled entity of a donor or donor advisor; or
• 35% controlled entity of a family member of a donor or donor advisor.
The excess benefit in this transaction is the amount of the grant, loan,
compensation, or similar payments.

For additional information, see the Instructions for Form 4720.


Supporting organization. For any supporting organization, defined in
section 509(a)(3), an excess benefit transaction also includes grants, loans,
compensation, or similar payments provided by the supporting organization to
a:
• Substantial contributor,
• Family member of a substantial contributor,
• 35% controlled entity of a substantial contributor, or
• 35% controlled entity of a family member of a substantial contributor.
For this purpose, the excess benefit is defined as the amount of the grant, loan,
compensation, or similar payments. Additionally, an excess benefit
transaction includes any loans provided by the supporting organization to a
disqualified person (other than an organization described in section 509(a)(1),
(2), or (4)).
Exempt bond See tax-exempt bond.

-62- Instructions for Form 990


Fair market value (FMV) The price at which property, or the right to use property, would change hands
between a willing buyer and a willing seller, neither being under any
compulsion to buy, sell, or transfer property or the right to use property, and
both having reasonable knowledge of relevant facts.
Family member, family relationship Unless specified otherwise, the family of an individual includes only his or her
spouse (see Rev. Rul. 2013-17 regarding same-sex marriage), ancestors,
brothers and sisters (whether whole or half blood), children (whether natural or
adopted), grandchildren, great-grandchildren, and spouses of brothers, sisters,
children, grandchildren, and great-grandchildren.
FIN 48 (FASB ASC 740) Financial Accounting Standards Board (FASB) Interpretation No. 48,
Accounting for Uncertainty in Income Taxes, an interpretation of FASB
Statement No. 109, now codified in FASB Accounting Standards Codification
740, Income Taxes (ASC 740). The organization can be required to provide in
Schedule D (Form 990), Supplemental Financial Statements, the text of the
footnote to its financial statements regarding the organization's liability for
uncertain tax positions under FIN 48 (ASC 740).
Financial statements An organization's statements of revenue and expenses and balance sheet, or
similar statements prepared regarding the financial operations of the
organization.
Fiscal year An annual accounting period ending on the last day of a month other than
December. See also tax year and current year.
Foreign government A governmental agency or entity, or a political subdivision thereof, that isn't
classified as a United States agency or governmental unit, regardless of
where it is located or operated.
Foreign individual A person, including a U.S. citizen or resident, who lives or resides outside the
United States. For purposes of Form 990, Part IX, and Schedule F (Form 990),
Statement of Activities Outside the United States, a person who lives or resides
outside the United States at the time the grant is paid or distributed to the
individual is a foreign individual.
Foreign organization An organization that isn't a domestic organization. A foreign organization
includes an affiliate that is organized as a legal entity separate from the filing
organization, but doesn't include any branch office, account, or employee of a
domestic organization located outside the United States.
Fundraising See fundraising activities.
Fundraising activities Activities undertaken to induce potential donors to contribute money,
securities, services, materials, facilities, other assets, or time. They include
publicizing and conducting fundraising campaigns; maintaining donor mailing
lists; conducting fundraising events, preparing and distributing fundraising
manuals, instructions, and other materials; professional fundraising
services; and conducting other activities involved with soliciting contributions
from individuals, foundations, governments, and others. Fundraising activities
don't include gaming, the conduct of any trade or business that is regularly
carried on, or activities substantially related to the accomplishment of the
organization's exempt purpose (other than by raising funds).

Instructions for Form 990 -63-


Fundraising events Include dinners and dances, door-to-door sales of merchandise, concerts,
carnivals, sports events, auctions, casino nights (in which participants can play
casino-style games but the only prizes or auction items provided to participants
are noncash items that were donated to the organization), and similar events
not regularly carried on that are conducted for the primary purpose of raising
funds. Fundraising events don't include the following:
1. The conduct of a trade or business that is regularly carried on;
2. Activities substantially related to the accomplishment of the
organization's exempt purposes (other than by raising funds);
3. Solicitation campaigns that generate only contributions, which may
involve gifts of goods or services from the organization of only nominal value, or
sweepstakes, lotteries, or raffles in which the names of contributors or other
respondents are entered in a drawing for prizes of only nominal value; and
4. Gaming.
GAAP See generally accepted accounting principles.
Gaming Includes (but isn't limited to): bingo, pull tabs/instant bingo (including
satellite and progressive or event bingo), Texas Hold-Em Poker, 21, and other
card games involving betting, raffles, scratch-offs, charitable gaming tickets,
break-opens, hard cards, banded tickets, jar tickets, pickle cards, Lucky Seven
cards, Nevada Club tickets, casino nights/Las Vegas nights (other than events
not regularly carried on in which participants can play casino-style games but
the only prizes or auction items provided to participants are noncash items that
were donated to the organization, which events are fundraising events), and
coin-operated gambling devices. Coin-operated gambling devices include slot
machines, electronic video slot or line games, video poker, video blackjack,
video keno, video bingo, video pull tab games, etc. See Pub. 3079,
Tax-Exempt Organizations and Gaming.
Generally accepted accounting principles/ The accounting principles set forth by the Financial Accounting Standards
GAAP Board (FASB) and the American Institute of Certified Public Accountants
(AICPA) that guide the work of accountants in reporting financial information
and preparing audited financial statements for organizations.
Governing body The group of one or more persons authorized under state law to make
governance decisions on behalf of the organization and its shareholders or
members, if applicable. The governing body is, generally speaking, the board
of directors (sometimes referred to as board of trustees) of a corporation or
association, or the trustee or trustees of a trust (sometimes referred to as the
board of trustees).
Government official A federal, state, or local official described within section 4946(c).
Governmental issuer A state or local governmental unit that issues a tax-exempt bond.
Governmental unit A state, a possession of the United States, or a political subdivision of a
state or U.S. possession, the United States, or the District of Columbia. See
section 170(c)(1).
Grants and other assistance For purposes of Part IX, lines 1–3; Schedule F (Form 990); and Schedule I
(Form 990), includes awards, prizes, contributions, noncash assistance, cash
allocations, stipends, scholarships, fellowships, research grants, and similar
payments and distributions made by the organization during the tax year. It
doesn't include salaries or other compensation to employees or payments to
independent contractors if the primary purpose is to serve the direct and
immediate needs of the organization (such as legal, accounting, or fundraising
services); the payment of any benefit by a section 501(c)(9) voluntary
employees' beneficiary association (VEBA) to employees of a sponsoring
organization or contributing employer, if such payment is made under the terms
of the VEBA and in compliance with section 505; or payments or other
assistance to affiliates or branch offices that aren't organized as legal entities
separate from the filing organization.

-64- Instructions for Form 990


Gross proceeds For purposes of Schedule K (Form 990), Supplemental Information on
Tax-Exempt Bonds, generally any sale proceeds, investment proceeds,
transferred proceeds, and replacement proceeds of an issue. See Regulations
sections 1.148-1(b) and 1(c).
Gross receipts The total amounts the organization received from all sources during its tax year,
without subtracting any costs or expenses. See Appendix B. How to Determine
Whether an Organization's Gross Receipts Are Normally $50,000 (or $5,000)
or Less and Appendix C. Special Gross Receipts Tests for Determining
Exempt Status of section 501(c)(7) and 501(c)(15) Organizations.
Group exemption Tax exemption of a group of organizations all exempt under the same Code
section, applied for and obtained by a central organization on behalf of
subordinate organizations under the central organization's general
supervision or control. See Rev. Proc. 80-27, 1980-1 C.B. 677, Rev. Proc.
96-40, 1996-2 C.B. 301, and Appendix E. Group Returns—Reporting
Information on Behalf of the Group, for more information.
Group return A Form 990 filed by the central organization of a group exemption for two or
more of the subordinate organizations. See General Instructions, Section I.
Group Return, earlier, and Appendix E. Group Returns—Reporting Information
on Behalf of the Group, for more information.
Highest compensated employee One of the five highest compensated employees of the organization (including
employees of a disregarded entity of the organization), other than current
officers, directors, trustees, or key employees, whose aggregate
reportable compensation from the organization and related organizations
is greater than $100,000 for the calendar year ending with or within the
organization's tax year. These employees should be reported in Part VII,
Section A, of Form 990.
Historical treasure A building, structure, area, or property (real or personal) with recognized
cultural, aesthetic, or historical value that is significant in the history,
architecture, archaeology, or culture of a country, state, or city.
Hospital/hospital facility For purposes of Schedule H (Form 990), Hospitals, a hospital, or hospital
facility, is a facility that is, or is required to be, licensed, registered, or similarly
recognized by a state as a hospital. This includes a hospital facility that is
operated through a disregarded entity or a joint venture treated as a
partnership for federal income tax purposes. It doesn't include hospital facilities
that are located outside the United States. It also doesn't include hospital
facilities that are operated by entities organized as separate legal entities from
the organization that are taxable as a corporation for federal tax purposes
(except for members of a group exemption included in a group return filed
by an organization).
Hospital organization An organization which operates one or more hospital facilities.
Hospital (or cooperative hospital service For purposes of Schedule A (Form 990 or 990-EZ), Public Charity Status and
organization) Public Support, a hospital (or cooperative hospital service organization) is an
organization whose main purpose is to provide hospital or medical care. For
purposes of Schedule A, a rehabilitation institution or an outpatient clinic can
qualify as a hospital if its principal purposes or functions are the providing of
hospital or medical care, but the term doesn't include medical schools, medical
research organizations, convalescent homes, homes for children or the aged,
animal hospitals, or vocational training institutions for handicapped individuals.
Household goods Include furniture, furnishings, electronics, appliances, linens, and other similar
items. They don't include food, paintings, antiques and other objects of art,
jewelry and gems (other than costume jewelry), and collections.
Independent contractor An individual or organization that receives compensation for providing services
to the organization but who isn't treated as an employee. See Pub. 1779 for
more information.

Instructions for Form 990 -65-


Independent voting member of governing A voting member of the governing body, if all four of the following
body circumstances applied at all times during the organization's tax year.
1. The member wasn't compensated as an officer or other employee of
the organization or of a related organization (see the Instructions for
Schedule R (Form 990), Related Organizations and Unrelated Partnerships),
except as provided in the religious exception discussed in the instructions for
Form 990, Part VI.
2. The member didn't receive total compensation or other payments
exceeding $10,000 during the organization's tax year from the organization or
from related organizations as an independent contractor, other than
reasonable compensation for services provided in the capacity as a
member of the governing body. For example, a person who receives
reasonable expense reimbursements and reasonable compensation as a
director of the organization doesn't cease to be independent merely because
he or she also received payments of $7,500 from the organization for other
arrangements.
3. Neither the member, nor any family member of the member, was
involved in a transaction with the organization (whether directly or indirectly
through affiliation with another organization) required to be reported on
Schedule L (Form 990 or 990-EZ), Transactions With Interested Persons, for
the organization's tax year.
4. Neither the member, nor any family member of the member, was
involved in a transaction with a taxable or tax-exempt related organization of a
type and amount that would be reportable on Schedule L (Form 990 or 990-EZ)
if required to be filed by the related organization.
A member of the governing body isn't considered to lack independence merely
because of any of the following circumstances.
1. The member is a donor to the organization, regardless of the amount of
the contribution.
2. The member has taken a bona fide vow of poverty and either:
a. Receives compensation as an agent of a religious order or a section
501(d) religious or apostolic organization, but only under circumstances in
which the member doesn't receive taxable income (for example, Rev. Rul.
77-290, 1977-2 C.B. 26; Rev. Rul. 80-332, 1980-2 C.B. 34); or
b. Belongs to a religious order that receives sponsorship or payments from
the organization that don't constitute taxable income to the member.
3. The member receives financial benefits from the organization solely in
the capacity of being a member of the charitable or other class served by the
organization in the exercise of its exempt function, such as being a member of
a section 501(c)(6) organization, so long as the financial benefits comply with
the organization's terms of membership.
Initial contract A binding written contract between an applicable tax-exempt organization
and a person who wasn't a disqualified person immediately before entering
into the contract.
Instant bingo See pull tabs.
Institutional trustee A trustee that isn't an individual or natural person but an organization. For
instance, a bank or trust company serving as the trustee of a trust is an
institutional trustee.
Joint venture Unless otherwise provided, a partnership, limited liability company, or other
entity treated as a partnership for federal tax purposes, as described in
Regulations sections 301.7701-1 through 301.7701-3.

-66- Instructions for Form 990


Key employee For purposes of Form 990, an employee of an organization (other than an
officer, director, or trustee) who meets all three of the following tests applied
in the following order:
1. $150,000 Test. Receives reportable compensation from the
organization and all related organizations in excess of $150,000 for the
calendar year ending with or within the organization's tax year.
2. Responsibility Test. The employee:

a. has responsibilities, powers or influence over the organization as a whole


similar to those of officers, directors, or trustees;

b. manages a discrete segment or activity of the organization that represents


10% or more of the activities, assets, income, or expenses of the organization,
as compared to the organization as a whole; or

c. has or shares authority to control or determine 10% or more of the


organization's capital expenditures, operating budget, or compensation for
employees.
3. Top 20 Test. Is one of the 20 employees (that satisfy the $150,000 Test
and Responsibility Test) with the highest reportable compensation from the
organization and related organizations for the calendar year ending with or
within the organization's tax year.

See instructions for Part VII for examples of key employees.

Legislation Includes action by Congress, any state legislature, any local council, or similar
governing body about acts, bills, resolutions, or similar items, or action by the
public in referenda, ballot initiatives, constitutional amendments, or similar
procedures. It doesn't include actions by executive, judicial, or administrative
bodies.
Lobbying See lobbying activities.
Lobbying activities All activities intended to influence foreign, national, state, or local legislation.
Such activities include direct lobbying (attempting to influence the legislators)
and grassroots lobbying (attempting to influence legislation by influencing the
general public).
Maintaining offices, employees, or agents For purposes of Schedule F (Form 990), Statement of Activities Outside the
United States, includes principal, regional, district, or branch offices, such
offices maintained by agents, independent contractors, and persons situated at
those offices paid wages for services performed. “Agent” is defined under
traditional agency principles (but doesn't include volunteers).
Management company An organization that performs management duties for another organization
customarily performed by or under the direct supervision of the other
organization's officers, directors, trustees, or key employees. These
management duties include, but aren't limited to, hiring, firing, and supervising
personnel; planning or executing budgets or financial operations; and
supervising exempt operations or unrelated trades or businesses.
Medical research For purposes of a medical research organization operated in conjunction with a
hospital (see Schedule A (Form 990 or 990-EZ), Public Charity Status and
Public Support), medical research means investigations, studies and
experiments performed to discover, develop, or verify knowledge relating to
physical or mental diseases and impairments and their causes, diagnosis,
prevention, treatment, or control.
Member of the governing body A person who serves on an organization's governing body, including a
director or trustee, but not if the person lacks voting power.

Instructions for Form 990 -67-


Net Assets with donor restrictions Includes endowment funds established by donor-restricted gifts that are
maintained to provide a source of income for either a specified period of time or
until a specific event occurs (see ASC 958-205-45), as well as all other
temporarily restricted net assets held in a donor-restricted endowment,
including unappropriated income from permanent endowments that isn't
subject to a permanent restriction. After Accounting Standards Update
2016-14, ASC 958 uses two classifications, instead of three – net assets with
donor restrictions and net assets without donor restrictions. ASC 958 no longer
uses the term “temporarily-restricted endowment.”

The part of net assets of a not-for-profit entity that is subject to donor-imposed


restrictions.
Net Assets without Donor Restrictions Part of net assets of a not-for-profit entity that is not subject to donor-imposed
restrictions.
Noncash contributions Contributions of property, tangible or intangible, other than money. Noncash
contributions include, but aren't limited to, stocks, bonds, and other securities;
real estate; works of art; stamps, coins, and other collectibles; clothing and
household goods; vehicles, boats, and airplanes; inventories of food, medical
equipment or supplies, books, or seeds; intellectual property, including patents,
trademarks, copyrights, and trade secrets; donated items that are sold
immediately after donation, such as publicly traded stock or used cars; and
items donated for sale at a charity auction. Noncash contributions don't include
volunteer services performed for the reporting organization or donated use of
materials, facilities, or equipment.
Nonexempt charitable trust A trust that meets the following conditions:
• Isn't exempt from tax under section 501(a),
• All of its unexpired interests are devoted to charitable purposes, and
• A charitable deduction was allowed for contributions to the trust under section
170, section 545(b)(2), section 642(c), section 2055, section 2106(a)(2), or section
2522, or for amounts paid by or permanently set aside by the trust under section
642(c).
Nonqualified deferred compensation Deferred compensation that is earned pursuant to a nonqualified plan or
nongovernmental section 457 plan. Different rules can apply for purposes of
identifying arrangements subject to sections 83, 409A, 457(f), and 3121(v).
Earned but unpaid incentive compensation can be deferred pursuant to a
nonqualified deferred compensation plan.
Officer Unless otherwise provided (for example, Signature Block, principal officer in
Heading), a person elected or appointed to manage the organization's daily
operations at any time during the tax year, such as a president, vice-president,
secretary, treasurer, and, in some cases, Board Chair. The officers of an
organization are determined by reference to its organizing document, bylaws,
or resolutions of its governing body, or as otherwise designated consistent with
state law, but at a minimum include those officers required by applicable state
law. For purposes of Form 990, treat the organization's top management
official and top financial official as officers.
“On behalf of” issuer A corporation organized under the general nonprofit corporation law of a state
whose obligations are considered obligations of a state or local governmental
unit. See Rev. Proc. 82-26, 1982-1 C.B. 476, for a description of the
circumstances under which the IRS will ordinarily issue an advance ruling that
the obligations of a nonprofit corporation were issued on behalf of a state or
local governmental unit. See also Rev. Rul. 63-20, 1963-1 C.B. 24; Rev. Rul.
59-41, 1959-1 C.B. 13; and Rev. Rul. 54-296, 1954-2 C.B. 59. An “on behalf of”
issuer also includes any corporation organized by a state or local governmental
unit specifically to issue tax-exempt bonds to further public purposes. See
Rev. Rul. 57-187, 1957-1 C.B. 65.
Organization manager For purposes of section 4958, any officer, director, or trustee of an
applicable tax-exempt organization, or any individual having powers or
responsibilities similar to officers, directors, or trustees of the organization,
regardless of title.

-68- Instructions for Form 990


Political campaign activities All activities that support or oppose candidates for elective federal, state, or
local public office. It doesn't matter whether the candidate is elected. A
candidate is one who offers himself or is proposed by others for public office.
Political campaign activity doesn't include any activity to encourage
participation in the electoral process, such as voter registration or voter
education, provided that the activity doesn't directly or indirectly support or
oppose any candidate.
Political subdivision A division of any state or local governmental unit which is a municipal
corporation or which has been delegated the right to exercise part of the
sovereign power of the unit. Sovereign power includes the power to make and
enforce laws.
Possession of the United States Includes the Commonwealth of Puerto Rico, the Commonwealth of the
Northern Mariana Islands, Guam, American Samoa, and the U.S. Virgin
Islands.
Principal officer For purposes of the Heading on page 1 of Form 990 (but not for the purposes
of the Signature Block or other parts of the Form 990), an officer of the
organization who, regardless of title, has ultimate responsibility for
implementing the decisions of the organization's governing body, or for
supervising the management, administration, or operation of the organization.
Private business use For purposes of Schedule K (Form 990), Supplemental Information on
Tax-Exempt Bonds, use by the organization or another 501(c)(3) organization
in an unrelated trade or business. Private business use also generally
includes any use by a nongovernmental person, other than a section 501(c)(3)
organization, unless otherwise permitted through an exception or safe harbor
provided under the regulations or a revenue procedure.
Private foundation An organization described in section 501(c)(3) that isn't a public charity.
Some private foundations are classified as operating foundations (also known
as private operating foundations) under section 4942(j)(3) or exempt operating
foundations under section 4940(d)(2). A private foundation retains its private
foundation status until such status is terminated under section 507. Thus, a
tax-exempt private foundation becomes a taxable private foundation if its
section 501(c)(3) status is revoked.
Proceeds For purposes of Schedule K (Form 990), Supplemental Information on
Tax-Exempt Bonds, generally the sale proceeds of an issue (other than those
sale proceeds used to retire bonds of the issue that aren't deposited in a
reasonably required reserve or replacement fund). Proceeds also include any
investment proceeds from investments that accrue during the project period
(net of rebate amounts attributable to the project period). See Regulations
section 1.141-1(b).
Professional fundraising services Services performed for the organization requiring the exercise of professional
judgment or discretion consisting of planning, management, preparation of
materials (such as direct mail solicitation packages and applications for grants
or other assistance), provision of advice and consulting regarding solicitation of
contributions, and direct solicitation of contributions, such as soliciting
restricted or unrestricted grants to provide services to the general public.
However, professional fundraising doesn't include services provided by the
organization's employees in their capacity as employees (except as provided
in the instructions for Part I, line 16a), nor does professional fundraising include
purely ministerial tasks, such as printing, mailing services, or receiving and
depositing contributions to a charity, such as services provided by a bank or
caging service.
Program-related investment Investments made primarily to accomplish the organization's exempt purposes
rather than to produce income. Examples of program-related investments
include student loans and notes receivable from other exempt organizations
that obtained the funds to pursue the filing organization's exempt function.

Instructions for Form 990 -69-


Public charity An organization described in section 501(c)(3) and that is excepted from
private foundation status because it is described in section 509(a)(1) (which
cross-references sections 170(b)(1)(A)(i) through (vi), and (ix)), 509(a)(2),
509(a)(3), or 509(a)(4).
Publicly traded securities Generally, include common and preferred stocks, bonds (including
governmental obligations such as bonds and Treasury bills), mutual fund
shares, and other investments listed and regularly traded in an
over-the-counter market or an established exchange and for which market
quotations are published or are otherwise readily available. (See further
explanation in the instructions for Part X, line 11, and Schedule M (Form 990),
Noncash Contributions, line 9).
Pull tabs Includes games in which an individual places a wager by purchasing preprinted
cards that are covered with pull tabs. Winners are revealed when the individual
pulls back the sealed tabs on the front of the card and compares the patterns
under the tabs with the winning patterns preprinted on the back of the card.
Included in the definition of pull tabs are “instant bingo,” “mini bingo,” and other
similar scratch-off cards. Satellite, Internet, and progressive or event bingo are
games conducted in many different places simultaneously and the winners
aren't all present when the wagers are placed, the winners are determined, and
the prizes are distributed. Revenue and expenses associated with satellite,
Internet, and progressive bingo should be included under this category.
However, certain bingo games within a hybrid gaming event (such as
progressive or event bingo) can also qualify as bingo if the individual game
meets the preceding definition of bingo.
Qualified 501(c)(3) bond A tax-exempt bond, the proceeds of which are used by a section 501(c)(3)
organization to advance its charitable purpose. Requirements generally
applicable to a qualified section 501(c)(3) bond under section 145 include the
following.
1. All property financed by the bond issue is to be owned by a section
501(c)(3) organization or a governmental unit.
2. At least 95% of net proceeds of the bond issue are used either by a
governmental unit or a section 501(c)(3) organization in activities that aren't
unrelated trades or businesses (determined by applying section 513).
Qualified conservation contribution Any contribution of a qualified real property interest to a qualified organization
exclusively for conservation purposes. A “qualified real property interest”
means any of the following interests in real property:
1. The entire interest of the donor,
2. A remainder interest, or
3. A restriction (such as an easement), granted in perpetuity, on the use
which may be made of the real property.
A “qualified organization” means an organization which is:
a. a governmental unit described in section 170(c)(1);
b. a publicly supported charitable organization described in sections 509(a)(1)
and 170(b)(1)(A)(vi) or section 509(a)(2) (see the instructions for Parts II and III
of Schedule A (Form 990 or 990-EZ)); or
c. a supporting organization described in sections 501(c)(3) and 509(a)(3)
that is controlled by a governmental unit or a publicly supported charitable
organization.

In addition, a qualified organization must have a commitment to protect the


conservation purposes of a qualified conservation contribution, and have the
resources to enforce the restrictions.

-70- Instructions for Form 990


A “conservation purpose” means:
1. The preservation of land areas for outdoor recreation by, or the
education of, the general public;
2. The protection of a relatively natural habitat of fish, wildlife, plants, or
similar ecosystems;
3. The preservation of open space (including farm and forest land) where
such preservation will yield a significant public benefit and is for the scenic
enjoyment of the general public or is pursuant to a clearly delineated federal,
state, or local governmental conservation policy; or
4. The preservation of an historically important land area or a certified
historic structure.
See section 170(h) for additional information, including special rules about the
conservation purpose requirement for buildings in registered historic districts.
See also conservation easement.
Qualified state or local political organization A type of political organization that meets the following requirements:
• It limits its exempt function to the selection process relating solely to any state or
local public office or office in a state or local political organization;
• It is required under a state law to report to a state agency (and does report)
information that otherwise would be required to be reported on Form 8872, Political
Organization Report of Contributions and Expenditures, or it is required to report
under state law (and does report) at least the following information:
1. The name and address of every person who contributes a total of $500 or
more during the calendar year and the amount of each contribution;
2. The name and address of every person to whom the organization makes
expenditures aggregating $800 or more during the calendar year, and the amount
of each expenditure; and
3. Any additional information specified in section 527(j)(3), if state law requires
the reporting of that information to the state agency.
• The state agency makes the reports filed by the organization publicly available;
• The organization makes the reports filed with the state agency publicly available
in the manner described in section 6104(d); and
• No federal candidate or office holder controls or materially participates in the
direction of the organization, solicits contributions to the organization, or directs
any of the organization's disbursements.
Quasi-endowment Net assets without donor restrictions designated by an entity's governing board
to be invested to provide income for generally a long but not necessarily
specified period. A board-designated endowment, which results from an
internal designation, is generally not donor-restricted and is classified as net
assets without donor restrictions. The governing board has the right to decide
at any time to expend such funds. Also referred to as a board-designated
endowment.
Reasonable compensation The value that would ordinarily be paid for like services by like enterprises
under like circumstances.
Reasonable effort A reasonable amount of effort in information gathering that the organization is
expected to undertake in order to provide information requested on the Form
990. See the specific instructions for Part VI, lines 1b and 2; Part VII, Section A
(compensation from related organizations); and Schedule L (Form 990 or
990-EZ), Parts III and IV, for examples of reasonable efforts.
Refunding escrow One or more funds established as part of a single transaction or a series of
related transactions, containing proceeds of a refunding issue and any other
amounts to provide for payment of principal or interest on one or more prior
issues. See Regulations section 1.148-1(b).

Instructions for Form 990 -71-


Refunding issue An issue of obligations, the proceeds of which are used to pay principal,
interest, or redemption price on another issue (a prior issue), including the
issuance costs, accrued interest, capitalized interest on the refunding issue, a
reserve or replacement fund, or similar costs, if any, properly allocable to that
refunding issue. A current refunding issue is a refunding issue that is issued not
more than 90 days before the last expenditure of any proceeds of the refunding
issue for the payment of principal or interest on the prior issue. An advance
refunding issue is a refunding issue that isn't a current refunding issue. See
Regulations sections 1.150-1(d)(1), 1.150-1(d)(3), and 1.150-1(d)(4).
Related organization An organization, including a nonprofit organization, a stock corporation, a
partnership or limited liability company, a trust, and a governmental unit or
other government entity, that stands in one or more of the following
relationships to the filing organization at any time during the tax year.
• Parent: an organization that controls the filing organization.
• Subsidiary: an organization controlled by the filing organization.
• Brother/Sister: an organization controlled by the same person or persons that
control the filing organization. However, if the filing organization is a trust that has a
bank or financial institution trustee that is also the trustee of another trust, the other
trust isn't a Brother/Sister related organization of the filing organization on the
ground of common control by the bank or financial institution trustee.
• Supporting/Supported: an organization that claims to be at any time during the
tax year, or that is classified by the IRS at any time during the tax year, as (i) a
supporting organization of the filing organization within the meaning of section
509(a)(3), if the filing organization is a supported organization within the
meaning of section 509(f)(3); (ii) or a supported organization, if the filing
organization is a supporting organization.
• Sponsoring Organization of a VEBA: an organization that establishes or
maintains a section 501(c)(9) voluntary employees’ beneficiary association (VEBA)
during the tax year. A sponsoring organization of a VEBA also includes an
employee organization, association, committee, joint board of trustees, or other
similar group of representatives of the parties which establish or maintain a VEBA.
Although a VEBA must report a sponsoring organization as a related organization,
a sponsoring organization shouldn't report a VEBA as a related organization,
unless the VEBA is related to the sponsoring organization in some other capacity
described in this definition.
• Contributing Employer of a VEBA: an employer that makes a contribution or
contributions to the VEBA during the tax year. Although a VEBA must report a
contributing employer as a related organization, a contributing employer shouldn't
report a VEBA as a related organization, unless the VEBA is related to the
contributing employer in some other capacity described in this definition.

The organization must determine its related organizations for purposes of


completing Form 990, Parts VI (Governance), VII (Compensation), VIII
(Statement of Revenue), and X (Balance Sheet), Schedule D (Form 990),
Schedule J (Form 990), and Schedule R (Form 990). See instructions for those
parts and schedules for related organization reporting requirements.
Religious order An organization described in Rev. Proc. 91-20, 1991-1 C.B. 524.
Reportable compensation In general, the aggregate compensation that is reported (or required to be
reported, if greater) on Form W-2, box 1 or 5 (whichever amount is greater);
and/or Form 1099-MISC, box 7, for the calendar year ending with or within the
organization's tax year. For foreign persons who receive U.S. source income,
reportable compensation includes the amount reportable on Form 1042-S,
box 2. For persons for whom compensation reporting on Form W-2,
1099-MISC, or 1042-S isn't required (certain foreign persons, institutional
trustees, and persons whose compensation was below the $600 reporting
threshold for Form 1099-MISC), reportable compensation includes the total
value of the compensation paid in the form of cash or property during the
calendar year ending with or within the organization's tax year.
Review of financial statement An examination of an organization's financial records and practices by an
independent accountant with the objective of assessing whether the financial
statements are plausible, without the extensive testing and external validation
procedures of an audit.

-72- Instructions for Form 990


School An organization, the primary function of which is the presentation of formal
instruction, and which has a regular faculty, curriculum, an enrolled body of
students, and a place where educational activities are regularly conducted.
Security/securities Any bond, debenture, note, or certificate or other evidence of indebtedness
issued by a corporation, government or political subdivision, share of stock,
voting trust certificate, or any certificate of interest or participation in, certificate
of deposit or receipt for, temporary or interim certificate for, or warrant or right
to subscribe to or purchase, any of the foregoing.
Short accounting period An accounting period of less than 12 months, which exists when an
organization changes its annual accounting period, and which can exist in its
initial or final year of existence (see tax year).
Short period See short accounting period.
Significant disposition of net assets A disposition of net assets, consisting of a sale, exchange, disposition or other
transfer of more than 25% of the FMV of the organization's net assets during
the year, whether or not the organization received full or adequate
consideration. A significant disposition of net assets involves:
1. One or more dispositions during the organization's tax year, amounting
to more than 25% of the FMV of the organization's net assets as of the
beginning of its tax year; or
2. One of a series of related dispositions or events begun in a prior year
that, when combined, comprise more than 25% of the FMV of the
organization's net assets as of the beginning of the tax year when the first
disposition in the series was made. Whether a significant disposition of net
assets occurred through a series of related dispositions depends on the facts
and circumstances in each case.
Examples of the types of transactions that are “a significant disposition of net
assets” required to be reported on Schedule N (Form 990 or 990-EZ),
Liquidation, Termination, Dissolution or Significant Disposition of Assets, Part
II, include:
• Taxable or tax-free sales or exchanges of exempt assets for cash or other
consideration (a social club described in section 501(c)(7) selling land or an
exempt organization selling assets it had used to further its exempt purposes);
• Sales, contributions or other transfers of assets to establish or maintain a
partnership, joint venture, or a corporation (for-profit or nonprofit) whether or not
the sales or transfers are governed by section 721 or section 351, whether or not
the transferor received an ownership interest in exchange for the transfer;
• Sales of assets by a partnership or joint venture in which the exempt partner has
an ownership interest; and
• Transfers of assets pursuant to a reorganization in which the organization is a
surviving entity.

The following types of situations aren't considered significant dispositions of


net assets for purposes of Schedule N, Part II:
• The change in composition of publicly traded securities held in an exempt
organization's passive investment portfolio;
• Asset sales made in the ordinary course of the organization's exempt activities
to accomplish the organization's exempt purposes, for instance, gross sales of
inventory;
• Grants or other assistance made in the ordinary course of the organization's
exempt activities to accomplish the organization's exempt purposes, for instance,
the regular charitable distributions of a United Way or other federated fundraising
organization;
• A decrease in the value of net assets due to market fluctuation in the value of
assets held by the organization; and
• Transfers to a disregarded entity of which the organization is the sole member.
Sponsoring organization Any organization which is all of the following:
• Described in section 170(c), other than governmental units described in section
170(c)(1) and without regard to section 170(c)(2)(A);
• Not a private foundation as defined in section 509(a); and
• Maintains one or more donor advised funds.

Instructions for Form 990 -73-


State of legal domicile For a corporation, the state of incorporation (country of incorporation for a
foreign corporation formed outside the United States). For a trust or other
entity, the state whose law governs the organization's internal affairs (the
foreign country whose law governs for a foreign organization other than a
corporation).
Subordinate organization One of the organizations, typically local in nature, that is recognized as exempt
in a group exemption letter and subject to the general supervision and control
of a central organization.
Supported organization A public charity described in section 509(a)(1) or 509(a)(2) supported by a
supporting organization described in section 509(a)(3).
Supporting organization A public charity claiming status on Form 990 or otherwise under section 509(a)
(3). A supporting organization is organized and operated exclusively to support
one or more supported organizations. A supporting organization that is
operated, supervised, or controlled by one or more supported organizations is
a Type I supporting organization. The relationship of a Type I supporting
organization with its supported organization(s) is comparable to that of a
parent-subsidiary relationship. A supporting organization supervised or
controlled in connection with one or more supported organizations is a Type II
supporting organization. A Type II supporting organization is controlled or
managed by the same persons that control or manage its supported
organization(s). A supporting organization that is operated in connection with
one or more supported organizations is a Type III supporting organization. A
Type III supporting organization is further considered either functionally
integrated with its supported organization(s) or not functionally integrated with
its supported organization(s) (Type III other). Finally, a supporting organization
can't be controlled directly or indirectly by one or more disqualified persons
(as defined in section 4946), other than foundation managers and other than
one or more public charities described in section 509(a)(1) or (2).
Tax-exempt bond An obligation issued by or on behalf of a governmental issuer on which the
interest paid is excluded from the holder's gross income under section 103. For
this purpose, a bond can be any form of indebtedness under federal tax law,
including a bond, note, loan, or lease-purchase agreement.
Tax year The annual accounting period for which the Form 990 is being filed, whether
the calendar year ending December 31st or a fiscal year ending on the last day
of any other month. The organization may have a short tax year in its first year
of existence, in any year when it changes its annual accounting period (for
example, from a December 31 year-end to a June 30 year-end), and in its last
year of existence (for example, when it merges into another organization or
dissolves). See also current year, fiscal year, and short period.
Term endowment An endowment fund established to provide income for a specified period.
Top financial official The person who has ultimate responsibility for managing the organization's
finances, for example, the treasurer or chief financial officer.
Top management official A person who has ultimate responsibility for implementing the decisions of the
organization's governing body or for supervising the management,
administration, or operation of the organization (for example, the organization's
president, CEO, or executive director).
Total assets The amount reported on Form 990, Part X, line 16, column (B).
Trustee See director or trustee.
United States Unless otherwise provided, includes the 50 states, the District of Columbia, the
Commonwealth of Puerto Rico, the Commonwealth of the Northern Mariana
Islands, Guam, American Samoa, and the United States Virgin Islands.
Unrelated business See unrelated trade or business.
Unrelated business income Income from an unrelated trade or business as defined in section 513.
Unrelated business gross income Gross income from an unrelated trade or business as defined in section 513.
Unrelated organization An organization that isn't a related organization to the filing organization.

-74- Instructions for Form 990


Unrelated trade or business Any trade or business, the conduct of which isn't substantially related to the
exercise or performance by the organization of its charitable, educational, or
other purpose or function constituting the basis for its exemption. See Pub. 598
and the Instructions for Form 990-T for a discussion of what is an unrelated
trade or business.
U.S. possession See possession of the United States.
Volunteer A person who serves the organization without compensation, for instance, a
member of the organization's governing body who serves the organization
without compensation. “Compensation” for this purpose includes tips and
noncash benefits, except for:
• Reimbursement of expenses under a reimbursement or other expense
allowance arrangement in which there is adequate accounting to the organization,
• Working condition fringe benefits described in section 132,
• Liability insurance coverage for acts performed on behalf of the exempt
organization, and
• De minimis fringe benefits.
Voting member of the governing body A member of the organization's governing body with power to vote on all
matters that may come before the governing body (other than a conflict of
interest that disqualifies the member from voting).
Works of art Include paintings, sculptures, prints, drawings, ceramics, antiques, decorative
arts, textiles, carpets, silver, photography, film, video, installation and
multimedia arts, rare books and manuscripts, historical memorabilia, and other
similar objects. Art doesn't include collectibles.
Year of formation The year in which the organization was created or formed under applicable
state law (if a corporation, the year of incorporation).

Instructions for Form 990 -75-


Appendix of Special
Instructions to Form
990

Contents
A Exempt Organizations Reference Chart
B How To Determine Whether an Organization's Gross Receipts Are Normally $50,000 (or $5,000) or Less
C Special Gross Receipts Tests for Determining Exempt Status of Section 501(c)(7) and Section 501(c)(15) Organizations
D Public Inspection of Returns
E Group Returns—Reporting Information on Behalf of the Group
F Disregarded Entities and Joint Ventures—Inclusion of Activities and Items
G Section 4958 Excess Benefit Transactions
H Forms and Publications To File or Use
I Use of Form 990 or 990-EZ To Satisfy State Reporting Requirements
J Contributions

-76- Instructions to Form 990


Appendix A. Exempt
Organizations
Reference Chart

Type of Organization I.R.C. Section


Corporations Organized Under Act of Congress 501(c)(1)

Title Holding Corporations 501(c)(2)

Charitable, Religious, Educational, Scientific, etc., Organizations 501(c)(3)

Civic Leagues and Social Welfare Organizations 501(c)(4)

Labor, Agricultural, and Horticultural Organizations 501(c)(5)

Business Leagues, etc. 501(c)(6)

Social and Recreation Clubs 501(c)(7)

Fraternal Beneficiary and Domestic Fraternal Societies and Associations 501(c)(8) & (c)(10)

Voluntary Employees' Beneficiary Associations 501(c)(9)

Teachers' Retirement Fund Associations 501(c)(11)

Benevolent Life Insurance Associations, Mutual Ditch or Irrigation Companies, 501(c)(12)


Mutual or Cooperative Telephone Companies, etc.

Cemetery Companies 501(c)(13)

State Chartered Credit Unions, Mutual Reserve Funds 501(c)(14)

Insurance Companies or Associations Other than Life 501(c)(15)

Cooperative Organizations to Finance Crop Operations 501(c)(16)

Supplemental Unemployment Benefit Trusts 501(c)(17)

Employee Funded Pension Trusts (created before 6/25/1959) 501(c)(18)

Organizations of Past or Present Members of the Armed Forces 501(c)(19) & (c)(23)

Black Lung Benefit Trusts 501(c)(21)

Withdrawal Liability Payment Funds 501(c)(22)

Trusts described in section 4049 of the Employer Retirement Income Security 501(c)(24)
Act

Title Holding Corporations or Trusts 501(c)(25)

State-Sponsored Organizations Providing Health Coverage for High-Risk 501(c)(26)


Individuals

State-Sponsored Workmen's Compensation and Insurance and Reinsurance 501(c)(27)


Organizations

National Railroad Retirement Investment Trust 501(c)(28)

Qualified Nonprofit Health Insurance Issuers 501(c)(29)

Religious and Apostolic Associations 501(d)

Cooperative Hospital Service Organizations 501(e)

Instructions for Form 990 -77-


Cooperative Service Organizations of Operating Educational Organizations 501(f)

Amateur Sports Organizations 501(j)

Child Care Organizations 501(k)

Charitable Risk Pools 501(n)

Political Organizations 527

Appendix B. How To Form 990-EZ. Gross receipts are the considered normally to be $5,000 or less
if the organization is:
sum of lines 5b, 6c, 7b, and 9 of Form
Determine Whether an 990-EZ, Part I. 1. Up to a year old and has received,
Organization's Gross Example. Organization M reported or donors have pledged to give, $7,500
or less during its first tax year;
$50,000 as total revenue on line 9 of its
Receipts Are Normally Form 990-EZ. M added back the costs 2. Between 1 and 3 years old and
$50,000 (or $5,000) or and expenses it had deducted on lines
5b ($2,000); 6b ($1,500); and 7b ($500)
averaged $6,000 or less in gross receipts
during each of its first 2 tax years; or
Less to its total revenue of $50,000 and 3. Three years old or more and
To figure whether an organization has to determined that its gross receipts for the averaged $5,000 or less in gross receipts
file Form 990-EZ (or Form 990), apply the tax year were $54,000. for the immediately preceding 3 tax years
(including the year for which the return
$50,000 (or $5,000) gross receipts test
(below) using the following definition of
$50,000 Gross Receipts would be filed).
gross receipts and information in Figuring Test
Gross Receipts below. To determine whether an organization's
Appendix C. Special
Gross Receipts gross receipts are normally $50,000 or Gross Receipts Tests
less, apply the following test. An
Gross receipts are the total amounts the organization's gross receipts are for Determining Exempt
organization received from all sources
during its annual tax year (including short
considered normally to be $50,000 or
less if the organization is:
Status of Section 501(c)
years) without subtracting any costs or
expenses.
1. Up to a year old and has received, (7) and 501(c)(15)
Don't use the definition of gross
or donors have pledged to give, $75,000
or less during its first tax year;
Organizations
receipts described in Appendix Section 501(c)(7) organizations (social
!
CAUTION C. Special Gross Receipts Tests
2. Between 1 and 3 years old and
clubs) and section 501(c)(15)
averaged $60,000 or less in gross
for Determining Exempt Status of Section organizations (insurance companies)
receipts during each of its first 2 tax
501(c)(7) and 501(c)(15) Organizations, apply the same gross receipts test as
years; or
to figure gross receipts for this purpose. other organizations to determine whether
Those tests are limited to determining the 3. Three years old or more and they must file Form 990 or 990-EZ.
exempt status of section 501(c)(7) and averaged $50,000 or less in gross However, section 501(c)(7) and section
501(c)(15) organizations. receipts for the immediately preceding 3 501(c)(15) organizations also are subject
tax years (including the year for which the to separate gross receipts tests to
Gross receipts when acting as an return would be filed). determine whether they qualify as
agent. If a local chapter of a section If the organization's gross receipts are tax-exempt for the tax year. The following
501(c)(8) fraternal organization collects normally $50,000 or less, it must submit tests use a special definition of gross
insurance premiums for its parent lodge Form 990-N, Electronic Notice receipts for purposes of determining
and merely sends those premiums to the (e-Postcard) for Tax-Exempt whether these organizations are exempt
parent without asserting any right to use Organizations Not Required to File Form for a particular tax year.
the funds or otherwise deriving any 990 or 990-EZ, if it chooses not to file Section 501(c)(7). A section 501(c)(7)
benefit from them, the local chapter Form 990 or 990-EZ. In general, organization can receive up to 35% of its
doesn't include the premiums in its gross organizations excepted from filing Form gross receipts, including investment
receipts. The parent lodge reports them 990 or 990-EZ because of low gross income, from sources outside its
instead. The same treatment applies in receipts must submit Form 990-N. See membership and remain tax-exempt. Part
other situations in which one organization filing exceptions described in General of the 35% (up to 15% of gross receipts)
collects funds merely as an agent for Instructions, Section B. Organizations can be from public use of a social club's
another. Not Required To File Form 990 or facilities.
Figuring Gross Receipts 990-EZ, earlier. Gross receipts, for purposes of
Figure gross receipts for Form 990 and $5,000 Gross Receipts determining the tax-exempt status of
section 501(c)(7) organizations, are the
990-EZ as follows.
Test club's income from its usual activities and
Form 990. Gross receipts are the sum of include:
To determine whether an organization's
lines 6b(i), 6b(ii), 7b(i), 7b(ii), 8b, 9b, 10b,
gross receipts are normally $5,000 or • Charges,
and 12 (column (A)) of Form 990, Part
less, apply the following test. An • Admissions,
VIII.
organization's gross receipts are • Membership fees,
• Dues,
• Assessments, and

-78- Instructions for Form 990


• Investment income (dividends, rents, 1. Premiums (including deposits and • An inspection of a return, report,
and similar receipts), and normal assessments) without reduction for return notice, or exemption application at an
recurring capital gains on investments. premiums or premiums paid for IRS office.
Gross receipts for this purpose don't reinsurance;
The IRS can provide copies of exempt
include capital contributions (see 2. Gross investment income of a organization returns on DVD. Requesters
Regulations section 1.118-1), initiation non-life insurance company (as can order the complete set (for example,
fees, or unusual amounts of income (the described in section 834(b)); and all Forms 990 and 990-EZ or all Forms
sale of the clubhouse). 3. Other items that are included in 990-PF filed for a year) or a partial set by
College fraternities or sororities the filer's gross income under state or by month. If you are ordering a
or other organizations that Subchapter B, Chapter 1, Subtitle A of partial set on DVD, indicate the format
!
CAUTION charge membership initiation the Code. (Alchemy or raw), state(s), and month(s)
fees, but not annual dues, must include you are ordering. Sample DVD requests
This definition doesn't, however, include
initiation fees in their gross receipts. aren't available for individual states.
contributions to capital. For more
DVDs and sample DVDs aren't available
information, see Notice 2006-42.
Section 501(c)(15). If any section for individual exempt organizations.
Premiums. Premiums consist of all Complete information, including the cost,
501(c)(15) insurance company (other
amounts received as a result of entering is available on the IRS website. Search
than life insurance) meets both parts of
into an insurance contract. They are Copies of Scanned EO Returns Available
the following test, then the company can
file Form 990 (or Form 990-EZ, if reported on Form 990, Part VIII at IRS.gov/Charities & Non-Profits/
applicable). (Statement of Revenue), line 2, or on Copies of Scanned Returns Available.
Form 990-EZ, Part I, line 2.
1. The company's gross receipts Anti-abuse rule. The anti-abuse rule, The IRS can't disclose portions of an
must be equal to or less than $600,000, found in section 501(c)(15)(C), explains exemption application relating to any
and how gross receipts (including premiums) trade secrets, etc. Additionally, the IRS
2. The company's premiums must be from all members of a controlled group generally can't disclose the names and
more than 50% of its gross receipts. are aggregated in figuring the above tests addresses of contributors. See the
described in Appendix C. Instructions for Schedule B (Form 990,
If the company didn't meet this test and
990-EZ, or 990-PF) for more information
the company is a mutual insurance
company, then it must meet the Alternate
Appendix D. Public about the disclosure of that schedule.
test to qualify to file Form 990 (or Form Inspection of Returns Notice 2008-49, 2008-20 I.R.B. 979,
990-EZ, if applicable). Insurance Some members of the public rely on provides interim guidance regarding the
companies that don't qualify as Form 990, or 990-EZ, as the primary or requirement that section 501(c)(3)
tax-exempt must file Form 1120-PC, U.S. sole source of information about a organizations and the IRS make available
Property and Casualty Insurance particular organization. How the public for public inspection Form 990-T.
Company Income Tax Return, or Form perceives an organization in those cases
1120, U.S. Corporation Income Tax Forms 990 or 990-EZ can only be
may be determined by the information
Return, as taxable entities for the year. requested for section 527 organizations
presented on its returns.
See Notice 2006-42, 2006-19 I.R.B. 878. for tax years beginning after June 30,
Alternate test. If any section 501(c) An organization's completed Form 2000.
(15) insurance company (other than life 990 or 990-EZ is available for public
A return, report, notice, or exemption
insurance) is a mutual insurance inspection as required by section 6104.
application can be inspected at an IRS
company and it didn't meet the above Schedule B (Form 990, 990-EZ, or
office free of charge. Copies of these
test, then the company must meet both 990-PF), Schedule of Contributors, is
items also can be obtained through the
parts of the following alternate test. open for public inspection for section 527
organization as discussed in the following
1. The company's gross receipts organizations filing Form 990 or 990-EZ.
section.
must be equal to or less than $150,000. For other organizations that file Form 990
2. The company's premiums must be
or 990-EZ, the names and addresses of Through the
contributors listed on Schedule B aren't
more than 35% of its gross receipts. required to be made available for public Organization
If the company doesn't meet either test, inspection. All other information reported
on Schedule B, including the amount of Public inspection and distribution of
then it must file Form 1120-PC or Form
contributions, the description of noncash certain returns of unrelated business
1120 (if the company isn't entitled to
contributions, and any other information, income. Section 501(c)(3) organizations
insurance reserves) instead of Form 990
is required to be made available for that are required to file Form 990-T after
or 990-EZ.
public inspection unless it clearly August 17, 2006, must make Form 990-T
The alternate test doesn't apply if identifies the contributor. Form 990-T available for public inspection under
! any employee of the mutual filed after August 17, 2006, by a section section 6104(d)(1)(A)(ii).
CAUTION insurance company or a member
501(c)(3) organization to report any Public inspection and distribution of
of the employee's family is an employee unrelated business income, is also returns and reports for a political or-
of another company that is exempt under available for public inspection and ganization. Section 527 political
section 501(c)(15) (or would be exempt if disclosure. organizations required to file Form 990 or
this provision didn't apply).
990-EZ must, in general, make their
Gross receipts. To determine Through the IRS Forms 8871, 8872, 990, or 990-EZ
whether a section 501(c)(15) Use Form 4506-A, Request for Public available for public inspection in the
organization satisfies either of the above Inspection or Copy of Exempt or Political same manner as annual information
tests described in Appendix C, figure Organization IRS Form, to request: returns of section 501(c) organizations
gross receipts by adding: • A copy of an exempt or political are made available. See Public
organization's return, report, notice, or inspection and distribution of applications
exemption application; or for tax exemption and annual information

Instructions for Form 990 -79-


returns of tax-exempt organizations, Application for tax exemption A site isn't considered a regional or
later. Generally, Form 8871 and Form doesn't include: district office, however, if:
8872 are available for inspection and • Any application for tax exemption filed • The only services provided at the site
printing at IRS.gov under the Charities & before July 15, 1987, unless the further exempt purposes (daycare, health
Nonprofits tab. organization filing the application had a care, scientific or medical research); and
Note that a section 527 political
copy of the application on July 15, 1987; • The site doesn't serve as an office for
TIP organization (and an organization
• In the case of a tax-exempt management staff, other than managers
organization other than a private who are involved solely in managing the
filing Form 990-PF) must
foundation, the name and address of any exempt function activities at the site.
disclose their Schedule B (Form 990,
contributor to the organization; or
990-EZ, or 990-PF). See the Instructions
for Schedule B. The penalties discussed
• Any material that isn't available for Special Rules Relating
in General Instructions, Section H,
public inspection under section 6104.
to Public Inspection
Failure-to-File Penalties, earlier, also If there is no prescribed Permissible conditions on public
apply to section 527 political ! application form, see Regulations inspection. A tax-exempt organization:
organizations (Rev. Rul. 2003-49, CAUTION section 301.6104(d)-1(b)(3)(ii). • Can have an employee present in the
2003-20 I.R.B. 903). room during an inspection,
Annual information return includes:
• An exact copy of the Form 990 or • Must allow the individual conducting
Public inspection and distribution of the inspection to take notes freely during
applications for tax exemption and Form 990-EZ filed by a tax-exempt
organization as required by section 6033. the inspection, and
annual information returns of tax-ex-
• Any amended return the organization • Must allow the individual to photocopy
empt organizations. Under the document at no charge, if the
Regulations sections 301.6104(d)-1 files with the IRS after the date the
original return is filed (both the original individual provides photocopying
through 3, a tax-exempt organization equipment at the place of inspection.
must: and amended return are subject to the
public inspection requirements). Organizations that don't maintain
• Make its application for recognition of
exemption and its annual information • An exact copy of Form 990-T if one is permanent offices. A tax-exempt
filed by a section 501(c)(3) organization. organization with no permanent office:
returns available for public inspection
without charge at its principal, regional, The copy must include all information • Must make its application for tax
furnished to the IRS on Form 990, exemption and its annual information
and district offices during regular
990-EZ, or 990-T as well as all returns available for inspection at a
business hours;
reasonable location of its choice;
• Make each annual information return statements, attachments, and supporting
• Must permit public inspection within a
available for a period of 3 years documents, except for the name and
address of any contributor to the reasonable amount of time after receiving
beginning on the date the return is
organization. See the Instructions for a request for inspection (normally not
required to be filed (determined with
Schedule B (Form 990, 990-EZ, or more than 2 weeks) and at a reasonable
regard to any extension of time for filing)
990-PF). However, statements, time of day;
or is actually filed, whichever is later; and
• Provide a copy without charge (for attachments, and supporting documents • Can mail, within 2 weeks of receiving
filed with Form 990-T that don't relate to the request, a copy of its application for
Form 990-T, this requirement applies
the imposition of unrelated business tax exemption and annual information
only to Forms 990-T filed after August 17,
income tax aren't required to be made returns to the requester instead of
2006), other than a reasonable fee for
available for public inspection and allowing an inspection; and
reproduction and actual postage costs, of
all or any part of any application or return copying. See Notice 2008-49. • Can charge the requester for copying
and actual postage costs only if the
required to be made available for public Annual returns more than 3 years
requester consents to the charge.
inspection to any individual who makes a old. An annual information return doesn't
request for a copy in person or in writing include any return after the expiration of 3 An organization that has a permanent
(except as provided in Regulations years from the date the return is required office, but has no office hours, or very
sections 301.6104(d)-2 and -3). to be filed (including any extension of limited hours during certain times of the
time that has been granted for filing the year, must make its documents available
Definitions return) or is actually filed, whichever is during those periods when office hours
Tax-exempt organization is any later. are limited, or not available, as though it
organization that is described in section were an organization without a
If an organization files an amended
501(c) or (d) and is exempt from taxation permanent office.
return, however, the amended return
under section 501(a). The term
tax-exempt organization also includes
must be made available for a period of 3
years beginning on the date it is filed with
Special Rules Relating
any section 4947(a)(1) nonexempt the IRS. to Copies
charitable trust or nonexempt private Local or subordinate organizations. Time and place for providing
foundation that is subject to the reporting For rules relating to annual information copies in response to requests made
requirements of section 6033. returns of local or subordinate in person. A tax-exempt organization
Application for tax exemption organizations, see Regulations section must:
includes: 301.6104(d)-1(f)(2). • Provide copies of required documents
• Any prescribed application form (Form Regional or district offices. A under section 6104(d) in response to a
1023, 1023-EZ, Form 1024, or 1024-A), regional or district office is any office of a request made in person at its principal,
• All documents and statements the IRS tax-exempt organization, other than its regional, and district offices during
requires an applicant to file with the form, principal office, that has paid employees, regular business hours, and
• Any statement or other supporting whether part-time or full-time, whose • Provide copies to a requester on the
document submitted in support of the aggregate number of paid hours a week day the request is made, except for
application, and are normally at least 120. unusual circumstances (explained next).
• Any letter or other document issued by
the IRS concerning the application.

-80- Instructions for Form 990


Unusual circumstances. In the case • Requests received shortly before the Request for copies in writing. A
of an in-person request, where unusual end of regular business hours that tax-exempt organization must honor a
circumstances exist so that fulfilling the require an extensive amount of copying; written request for a copy of documents
request on the same business day or (or the requested part) required under
causes an unreasonable burden to the • Requests received on a day when the section 6104(d) if the request:
tax-exempt organization, the organization organization's managerial staff capable 1. Is addressed to (and delivered by
must provide the copies no later than the of fulfilling the request is conducting mail, electronic mail, facsimile, or a
next business day following the day that special duties (student registration or private delivery service, as defined in
the unusual circumstances cease to attending an off-site meeting or section 7502(f)) a principal, regional, or
exist, or the 5th business day after the convention, rather than its regular district office of the organization; and
date of the request, whichever occurs administrative duties).
first. 2. Sets forth the address to which the
Agents for providing copies. For
copy of the documents should be sent.
Unusual circumstances include: rules relating to use of agents to provide
• Requests received that exceed the copies, see Regulations sections
organization's daily capacity to make 301.6104(d)-1(d)(1)(iii) and -1(d)(2)(ii)
copies; (C).

Time and Manner of Fulfilling Written Requests


IF the organization... THEN the organization...
Receives a written request for a copy, Must mail the copy of the requested documents (or the requested parts) within 30
days from the date it receives the request.
Mails the copy of the requested document, Is deemed to have provided the copy on the postmark date or private delivery
mark (if sent by certified or registered mail, the date of registration or the date of
the postmark on the sender's receipt).
Requires payment in advance, Is required to provide the copies within 30 days from the date it receives payment.
Receives a request or payment by mail, Is deemed to have received it 7 days after the date of the postmark, absent
evidence to the contrary.
Receives a request transmitted by electronic mail or facsimile, Is deemed to have received it the day the request is transmitted successfully.
Receives a written request without payment or with an insufficient payment, when Must notify the requester of the prepayment policy and the amount due within 7
payment in advance is required, days from the date of the request's receipt.
Receives consent from an individual making a request, Can provide a copy of the requested document exclusively by electronic mail (the
material is provided on the date the organization successfully transmits the
electronic mail).

Request for a copy of parts of a b. Request made in writing. If a granted for filing the return) or is actually
document. A tax-exempt organization tax-exempt organization charges a fee filed, whichever is later.
must fulfill a request for a copy of the for copying and postage, it must accept
organization's entire application for tax payment by certified check, money order, Documents Provided by
exemption or annual information return or
any specific part or schedule of its
and either personal check or credit card
for requests made in writing. The
Local and Subordinate
application or return. A request for a copy organization can accept other forms of Organizations
of less than the entire application or less payment.
Applications for tax exemption.
than the entire return must specifically Avoidance of unexpected fees. Except as otherwise provided, a
identify the requested part or schedule. Where a tax-exempt organization doesn't tax-exempt organization that didn't file its
Fees for copies. A tax-exempt require prepayment and a requester own application for tax exemption
organization can charge a reasonable fee doesn't enclose payment with a request, (because it is a local or subordinate
for providing copies. Before the an organization must receive consent organization covered by a group
organization provides the documents, it from a requester before providing copies exemption letter) must, upon request,
can require that the individual requesting for which the fee charged for copying and make available for public inspection, or
copies of the documents pay the fee. If postage exceeds $20. provide copies of, the application
the organization has provided an Documents to be provided by submitted to the IRS by the central or
individual making a request with notice of regional and district offices. Except parent organization to obtain the group
the fee, and the individual doesn't pay the as otherwise provided, a regional or exemption letter and those documents
fee within 30 days, or if the individual district office of a tax-exempt which were submitted by the central or
pays the fee by check and the check organization must satisfy the same rules parent organization to include the local or
doesn't clear upon deposit, the as the principal office for allowing public subordinate organization in the group
organization can disregard the request. inspection and providing copies of its exemption letter.
Form of payment. application for tax exemption and annual
a. Request made in person. If a information returns. However, if the central or parent
tax-exempt organization charges a fee organization submits to the IRS a list or
A regional or district office isn't directory of local or subordinate
for copying, it must accept payment by required, however, to make its annual
cash and money order for requests made organizations covered by the group
information return available for inspection exemption letter, the local or subordinate
in person. The organization can accept or to provide copies until 30 days after
other forms of payment, such as credit organization is required to provide only
the date the return is required to be filed the application for the group exemption
cards and personal checks. (including any extension of time that is ruling and the pages of the list or
directory that specifically refer to it. The

Instructions for Form 990 -81-


local or subordinate organization must not to exceed $50,000 for each return. organization or to another entity
permit public inspection, or comply with a The penalties for failure to comply with maintaining the Web page.
request for copies made in person, within the public inspection requirements for Reliability and accuracy. In order for
a reasonable amount of time (normally applications are the same as those for the document to be widely available
not more than 2 weeks) after receiving a annual returns, except that the $10,000 through an Internet posting, the entity
request made in person for public limitation doesn't apply (sections 6652(c) maintaining the Web page must have
inspection or copies and at a reasonable (1)(C) and (D)). Any person who willfully procedures for ensuring the reliability and
time of day. See Regulations section fails to comply with the public inspection accuracy of the document that it posts on
301.6104(d)-1(f) for further information. requirements for annual returns or the page and must take reasonable
Annual information returns. A local exemption applications will be subject to precautions to prevent alteration,
or subordinate organization that doesn't an additional penalty of $5,000 (section destruction, or accidental loss of the
file its own annual information return 6685). document when posted on its page. In
(because it is affiliated with a central or the event that a posted document is
parent organization that files a group Making Applications and altered, destroyed, or lost, the entity must
return) must, upon request, make Returns Widely Available correct or replace the document.
available for public inspection, or provide A tax-exempt organization isn't required Notice requirement. If a tax-exempt
copies of, the group returns filed by the to comply with a request for a copy of its organization has made its application for
central or parent organization. application for tax exemption or an tax exemption and/or an annual
However, if the group return includes annual information return if the information return widely available, it
separate statements for each local or organization has made the requested must notify any individual requesting a
subordinate organization included in the document widely available (see below). copy where the documents are available
group return, the local or subordinate (including the address on the Web, if
organization receiving the request can An organization that makes its applicable). If the request is made in
omit any statements relating only to other application for tax exemption and/or person, the organization must provide the
organizations included in the group annual information return widely available notice to the individual immediately. If the
return. must also make the document available request is made in writing, the notice
for public inspection as required under must be provided within 7 days of
The local or subordinate organization Regulations section 301.6104(d)-1(a). receiving the request.
must permit public inspection, or comply
with a request for copies made in person, A tax-exempt organization makes its
within a reasonable amount of time
Tax-Exempt Organization
application for tax exemption and/or an
(normally not more than 2 weeks) after annual information return widely available Subject to Harassment
receiving a request made in person for if the organization complies with the Campaign
public inspection or copies and at a Internet posting requirements and the Under section 6104(d)(4), if the Office of
reasonable time of day. notice requirements given below. Associate Chief Counsel (Tax Exempt
When a requester seeks inspection, Internet posting. A tax-exempt and Government Entities) determines
the local or subordinate organization can: organization can make its application for that the organization is being harassed, a
• Mail a copy of the applicable tax exemption and/or an annual tax-exempt organization isn't required to
documents to the requester within the information return widely available by comply with any request for copies that it
same time period instead of allowing an posting the document on a Web page reasonably believes is part of a
inspection, and that the tax-exempt organization harassment campaign.
• Charge the requester for copying and establishes and maintains, or by having Whether a group of requests is a
actual postage costs, if the requester the document posted, as part of a harassment campaign depends on the
consents to the charge. database of similar documents of other relevant facts and circumstances such
tax-exempt organizations, on a Web as:
If the local or subordinate organization
page established and maintained by • A sudden increase in requests;
receives a written request for a copy of its
another entity. The document will be • An extraordinary number of requests
annual information return, it must fulfill
considered widely available only if: by form letters or similarly worded
the request by providing a copy of the
group return in the time and manner • The Web page through which it is correspondence;
available clearly informs readers that the • Hostile requests;
specified in Request for copies in writing,
document is available and provides • Evidence showing bad faith or
earlier.
instructions for downloading it; deterrence of the organization's exempt
The requester has the option of • The document is posted in a format purpose;
requesting from the central or parent that, when accessed, downloaded,
organization, at its principal office, • Prior provision of the requested
viewed, and printed in hard copy, exactly documents to the purported harassing
inspection or copies of group returns filed reproduces the image of the application group; and
by the central or parent organization. The for tax exemption or annual information
central or parent organization must fulfill • A demonstration that the organization
return as it was originally filed with the routinely provides copies of its
the requests in the time and manner IRS, except for any information permitted documents upon request.
specified in Special Rules Relating to by statute to be withheld from public
Public Inspection and Special Rules disclosure; and A tax-exempt organization can
Relating to Copies, earlier. disregard any request for copies of all or
• Any individual with access to the
Failure to comply. Any person who Internet can access, download, view, and part of any document beyond the first two
doesn't comply with the public inspection print the document without special received within any 30-day period or the
requirements will be assessed a penalty computer hardware or software required first four received within any 1-year
of $20 for each day that inspection wasn't for that format (other than software that is period from the same individual or the
permitted, up to a maximum of $10,000 readily available to members of the public same address, whether or not the Office
for each return. Organizations with gross without payment of any fee) and without of Associate Chief Counsel (Tax Exempt
receipts exceeding $1 million will be payment of a fee to the tax-exempt and Government Entities) has
assessed a penalty of $100 for each day,

-82- Instructions for Form 990


determined that the organization is • Form 990, Part VI, lines 8a, 8b, 10b, b, and EIN of each subordinate organization
subject to a harassment campaign. and 12c. included in the group return. Additionally,
A tax-exempt organization can apply • Form 990, Schedule C (Political attach a list (not on Schedule O) showing
for a determination that it is the subject of Campaign and Lobbying Activities), Part the name, address, and EIN of each
a harassment campaign and that I-B, lines 3 and 4a. subordinate organization not included in
compliance with requests that are part of • Form 990, Schedule C, Part I-C, line 4. the group return. See Regulations section
the campaign wouldn't be in the public • Form 990, Schedule C, Part II-A, 1.6033-2(d)(2)(ii).
interest by submitting a signed line 1j. 6. Header Item K. Form of
application to the Office of Associate • Form 990, Schedule C, Part II-B, organization. Check “other” if the group
Chief Counsel (Tax Exempt and line 2d. has more than one form of organization.
Government Entities). See Rev. Proc. • Form 990, Schedule C, Part III-A, lines
1–3. 7. Header Item L. Year of
2018-1, 2018-1 I.R.B. 1, or as updated formation. Leave blank for group return.
annually. • Form 990, Schedule D (Supplemental
Financial Statements), Part I, lines 5 and 8. Header Item M. State of legal
In addition, the organization can 6. domicile. Leave blank for group return.
suspend compliance with any request it
• Form 990, Schedule D, Part II, lines 5 9. Part IV, lines 14b–19, 21–22,
reasonably believes to be part of the and 8.
harassment campaign until it receives a and 29, dollar thresholds. Apply the
• Form 990, Schedule E (Schools), lines dollar thresholds for the aggregate data
response to its application for a 1–4d and 7.
harassment campaign determination. for the group as a whole, not subordinate
• Form 990, Schedule F (Statement of by subordinate.
However, if the Office of Associate Chief Activities Outside the United States), Part
Counsel (Tax Exempt and Government 10. Part IV, line 20. Hospitals.
I, line 1.
Entities) determines that the organization Answer “Yes,” if any affiliate included
• Form 990, Schedule G (Supplemental within the group return operated a
didn't have a reasonable basis for Information Regarding Fundraising or
requesting a determination that it was hospital facility.
Gaming Activities), Part III, line 9a.
subject to a harassment campaign or 11. Part VI, line 2. Relationships
• Form 990, Schedule I (Grants and
reasonable belief that a request was part Other Assistance to Organizations, among officers, directors, trustees,
of the campaign, the officer, director, Governments, and Individuals in the and key employees. Describe on
trustee, employee, or other responsible United States), Part I, line 1. Schedule O (Form 990 or 990-EZ) only
individual of the organization remains relationships between officers,
• Form 990, Schedule J (Compensation
liable for any penalties for not providing Information), Part I, lines 1b and 2. directors, trustees, and key
the copies in a timely fashion. See employees of the same subordinate
• Form 990, Schedule M (Noncash
Regulations section 301.6104(d)-3. Contributions), Part I, line 31. organization, not relationships between
• Form 990, Schedule N (Liquidation, officers, directors, trustees, and key
Appendix E. Group Termination, Dissolution, or Significant employees of one subordinate and
Returns—Reporting Disposition of Assets), Part I, lines 3, officers, directors, trustees, and key
employees of another subordinate.
4a-b, 5, and 6a-c.
Information on Behalf of 12. Part VI, line 4. Significant
The following is a list of other special
the Group instructions for group returns:
changes to organizational
documents. Report only changes to
Except where otherwise instructed, 1. Header Item B. Final return/ standardized organizational documents
where a line calls for a dollar amount or terminated. If the central organization maintained by the central organization
numerical data, the central is terminating its group exemption and that subordinates are required to adopt.
organization filing the group return filing its final group return, don't check
must aggregate the data from all the 13. Part VI, line 5. Significant
the Final return/terminated box. Refer to diversion of assets. In determining
subordinate organizations included in Rev. Proc. 80-27, 1980-1 C.B. 677, as
the group return and report the aggregate whether a diversion of a subordinate’s
modified, for procedures for terminating assets meets the 5%/$250,000 reporting
number. For example, in answering Form the group exemption.
990, Part I, line 6, the total number of threshold, consider only the total assets
2. Header Item C. Name. Enter the and gross receipts of that subordinate,
volunteers for all of the subordinate
name of the group exemption. Note that not of the parent or other subordinates.
organizations would be reported.
the group exemption may have a different 14. Part VI, line 20. Person who
For purposes of Form 990, Part III, name than the central organization's possesses books and records. Identify
summarize the mission and activities of name. the person who possesses the
all of the subordinate organizations as if 3. Header Item D. EIN. Use the information furnished by the subordinate
all of the subordinate organizations were special EIN (separate from the central organizations used in compiling the
one entity. organization's EIN) that is issued solely group return.
for the purposes of the group return. The 15. Part VII. Compensation of
In general, if a line requires a Yes/No central organization must have received
answer and the answer isn't the same for officers, directors, trustees, key
a group exemption letter before it can file employees, and highest
all subordinate organizations to which the a group ruling.
line applies, then check “Yes,” and compensated employees. File a single
explain the answer in the schedule's 4. Header Items E, F, J. Enter consolidated Form 990, Part VII, showing
supplemental information section (if information for the central organization the officers, directors, trustees, and key
applicable) or in Schedule O (Form 990 only. employees of each subordinate included
or 990-EZ). For the following lines, 5. Header Item H. Group returns. If in the group return, and a single
however, check “No” if the answer is “No” the organization answers “Yes” on line consolidated Schedule J (Form 990),
for any of the subordinates to which the H(a) but “No” to line H(b) (not all Compensation Information, Part II, for all
line applies, and explain in Schedule O. subordinate organizations are included in officers, directors, trustees, and key
• Form 990, Part V, lines 1c, 2b, 3b, 5c, the group return), then attach a list (not in employees above the compensation
6b, 7b, 7g, and 7h. Schedule O) showing the name, address, thresholds. Report the five highest

Instructions for Form 990 -83-


compensated employees and organization, then provide aggregate persons, not payments between
independent contractors above data in Part V. interested persons and the parent or
$100,000 for the whole group of 21. Schedule B (Form 990, 990-EZ, other subordinates.
subordinates, not for each subordinate. If or 990-PF). Contributors. Report a 27. Schedule N (Form 990 or
one or more officers, directors, trustees, consolidated Schedule B (Form 990, 990-EZ). Liquidation or significant
key employees, or highest compensated 990-EZ, or 990-PF) for all subordinates disposition of assets. Explain on
employees received compensation from included in the group return. Apply the Schedule N (Form 990 or 990-EZ), Part
more than one organization in the group, dollar and percentage thresholds III, which of the subordinates have
the person's compensation from the (including the greater of $5,000 or 2% undergone a liquidation, termination,
several organizations must be reported in threshold for section 501(c)(3) dissolution, or significant disposition of
column (D). organizations described in sections assets during the tax year.
16. Part VII. Compensation from 509(a)(1) and 170(b)(1)(A)(vi)) 28. Schedule R (Form 990). Related
related organizations. Report subordinate by subordinate, not on a organizations. See the instructions for
compensation from an organization that group basis. Schedule R (Form 990) to determine
is included in the group ruling but that 22. Schedule C (Form 990 or when related organizations of a member
isn't among the subordinates included in 990-EZ). Part II-A. Lobbying of a group exemption must be included
the group return as compensation from a expenditures and affiliated groups. on Schedule R (Form 990). In general,
related organization in column (E), even if Complete Part II-A, column (b) for the central organizations and subordinate
the related organization isn't required to group as a whole. In column (a), except organizations of a group exemption
be reported on Schedule R (Form 990), on lines 1g and 1h, include the amounts aren't required to be listed as related
Related Organizations and Unrelated that apply to all electing members of the organizations on Schedule R (Form
Partnerships. group if they are included in the group 990), Part II; and all other related
17. Part XII, lines 2a-2b. Compiled, return. If the group return includes organizations of the central organization
reviewed, or audited financial organizations that belong to more than or of a subordinate organization are
statements. Answer “Yes” only if all the one affiliated group, enter in column (b) required to be listed on Schedule R
subordinates in the group had their the totals for all the groups. (Form 990) in the applicable part. Even if
financial statements compiled, reviewed, 23. Schedule D (Form 990). Part X. a related organization isn't required to be
or audited individually (rather than on a Other liabilities. The filing organization listed in Part II of Schedule R (Form 990),
consolidated basis). can summarize that portion, if any, of the the organization must report its
18. Schedule A (Form 990 or FIN 48 (ASC 740) footnote that applies to transactions with the related organization
990-EZ). Part I. Reason for public the liability of multiple organizations in Part V, as described in the instructions
charity status. If the subordinates don't including the organization (for example, for that Part.
all have the same public charity status, as a member of a group with
then check the public charity status box consolidated financial statements), to Appendix F.
for the largest number of subordinates in
the group, and explain on Schedule A
describe the filing organization's share of
the liability.
Disregarded Entities
(Form 990 or 990-EZ), Public Charity 24. Schedule H (Form 990). and Joint
Status and Public Support, Part IV.
However, if any section 509(a)(3)
Hospitals. Complete one Schedule H for
all of the hospitals operated by
Ventures—Inclusion of
organizations are among the
subordinates in the group return, also
subordinates in the group, and report Activities and Items
aggregate data from all the hospitals. In
answer lines 11e through 11g. Part V, Section A, list each of the Disregarded Entities
19. Schedule A (Form 990 or organization’s hospital facilities
990-EZ). Parts II and III. Support separately. List in Section A the name A disregarded entity, as described in
statements. Report aggregate data for and EIN of the subordinate hospital Regulations sections 301.7701-1 through
all subordinates with the public charity organization that operates the hospital 301.7701-3, is generally treated as a
status corresponding to Parts II or III. facility. Complete separate Sections B branch or division of its parent
and C for each of the hospital facilities or organization for federal tax purposes (but
20. Schedule A (Form 990 or see TIP below for treatment of
990-EZ). Parts IV through VI. In facility reporting groups listed in
Section A. disregarded entities as separate entities
addition to Part I in paragraph 18 above, for employment tax purposes). Therefore,
if any section 509(a)(3) organizations are 25. Schedule J (Form 990). financial and other information applicable
among the subordinates in the group Compensation from related to a disregarded entity must be reported
return, also complete the relevant organizations. See the Appendix E, Part as the parent organization's information,
sections of Parts IV and V. If an answer in VII instructions, earlier. except on Form 990, Part VI, lines 10a
Part IV requires more information with 26. Schedule L (Form 990 or and 10b, and on Schedule R (Form 990),
respect to any section 509(a)(3) 990-EZ). Transactions with Interested in which disregarded entities must be
organizations, then answer with respect Persons. On Schedule L (Form 990 or separately reported.
to those organizations and provide that 990-EZ), Part IV, report only transactions
additional information in Part VI. For An organization must report on its
between a subordinate organization and Form 990, including Parts VIII through X,
instance, if the group includes 50 section its interested persons—not transactions
509(a)(3) organizations, and one of them all of the revenues, expenses, assets,
between a subordinate organization and liabilities, and net assets or funds of a
doesn't list all of its supported the interested persons of other
organizations by name in its governing disregarded entity of which it is the sole
subordinates. In determining whether a member. The disregarded entity is
documents, then answer “No,” to Part IV, transaction between the subordinate and
Section A, line 1, and explain in Part VI. If deemed to have the same accounting
its interested persons meets the financial period as its parent for federal tax
the group includes more than one Type III reporting thresholds of Schedule L, Part
non-functionally-integrated supporting purposes. The organization must also
IV, consider only the payments between report the activities of a disregarded
the subordinate and its interested entity in the appropriate parts (including

-84- Instructions for Form 990


Schedules) of the Form 990. For and accomplishments of all disregarded employee or highest compensated
example, support of a disregarded entity entities when answering this part. employee of the filing organization by
must be taken into account by the filing 4. Part IV, line 12. Audited virtue of compensation paid by the
organization for purposes of the public financial statements. The organization disregarded entity, or the person's
support tests set forth on Schedule A shouldn't answer “Yes,” to this question responsibilities and authority over
(Form 990 or 990-EZ). Similarly, political merely because it received audited operations of the disregarded entity when
campaign activity or lobbying activity financial statements of one or more compared to the filing organization as a
conducted by a disregarded entity of disregarded entities, if the audited whole. See the instructions for Form 990,
which the organization is the sole financial statements of the organization Part VII, Section A.
member must be reported on Schedule C weren't audited. 12. Part XII, lines 2a–2b. Financial
(Form 990 or 990-EZ), Political statements. If the organization included
Campaign and Lobbying Activities. 5. Part IV, lines 31–32. Liquidation
or significant disposition of assets. financial information from its disregarded
A disregarded entity is treated as See the Appendix F instructions for entity or entities in its financial
TIP a separate entity for purposes of Schedule N (Form 990 or 990-EZ) in this statements, but didn't consolidate any
employment tax and certain Appendix, later. other entity's information in its financial
excise taxes. For wages paid after statements, it should check the box for
6. Part IV, lines 35–36. “Separate basis” but not the box for
January 1, 2009, a disregarded entity is Transactions with related
required to use its name and employer “Consolidated basis” or “Both
organizations. See Appendix F consolidated and separate basis.”
identification number (EIN) for reporting instructions for Schedule R (Form 990) in
and payment of employment taxes. this Appendix, later. 13. Part XII, line 3. Uniform
Guidance, 2 C.F.R. Part 200, Subpart
A single-member LLC is treated 7. Part V, lines 1–2. Forms 1096 F. The organization must check “Yes” if a
generally as a disregarded entity and W-3. The total number of information
!
CAUTION of its sole member/owner unless returns and employees to be reported,
disregarded entity was required to
undergo an audit or audits.
it elects to be treated as a separate and compliance with backup withholding
association. It may elect to be treated rules, includes all backup withholding, Note. The Single Audit Act of 1984 and
separately by filing Form 8832, Entity information returns and employees of any OMB Circular A-133 are superseded by
Classification Election, or by claiming disregarded entity, whether or not the Uniform Guidance, 2 C.F.R. Part 200,
tax-exempt status in its own right (by disregarded entity has a separate EIN for Subpart F, and now requires states, local
filing a Form 1023, 1023-EZ, 1024, or employment tax and information governments, and nonprofit
1024-A, application for recognition of reporting purposes. organizations that spend $750,000
tax-exempt status or a Form 990, 8. Part V, line 7. Organizations (previously $500,000) or more of federal
990-EZ, 990-N, or 990-T using its own that can receive deductible awards in a year to obtain an annual
name and EIN). Once the IRS determines contributions. For purposes of Form audit.
a single-member LLC to be exempt, it is 990 reporting, lines 7a through 7h are to 14. Schedule L (Form 990 or
no longer eligible to be treated as a be answered by taking into account any 990-EZ). Transactions with interested
disregarded entity until the determination contributions made to a disregarded persons. Reportable transactions
of exemption is revoked and the LLC entity. include transactions involving interested
subsequently files a Form 8832 electing 9. Part VI, lines 1a–9. Members of persons who have such status because
disregarded entity status. Similarly, a the governing body, officers, directors, of their relationship with a disregarded
single-member LLC that claims trustees, and employees of a disregarded entity (such as an employee of the
exemption but hasn't been determined to entity won't be treated as governing disregarded entity who qualifies as a key
be exempt isn't eligible to be treated as body members, officers, directors, or employee of the organization as a
disregarded until the claim is withdrawn trustees of the filing organization, but a whole). A transaction between an
or rejected and the LLC files a Form 8832 person can be a key employee or interested person and a disregarded
electing disregarded entity status. See highest compensated employee of the entity of the organization is reportable on
Regulations section 301.7701-3(c)(1)(v) filing organization by virtue of Schedule L.
(A). compensation paid by the disregarded 15. Schedule N (Form 990 or
entity, or the person's responsibilities and 990-EZ). Liquidation or significant
The following is a list of special
authority over operations of the disposition of assets. The organization
instructions for the Form and Schedules
disregarded entity when compared to the shouldn't prepare Part I to report a
regarding the reporting of a disregarded
filing organization as a whole. See the termination, liquidation, or dissolution of a
entity of which the organization is the sole
instructions for Form 990, Part VII, disregarded entity if the filing
member. These items are described to
Section A, Disregarded entities, earlier. organization continues to operate.
illustrate special applications of the rule
described above that a disregarded 10. Part VI, Section B, lines 10a– Transfers to (or by) a filing organization
entity's activities and items must be 16b. Policies. The organization should by (or to) its disregarded entity aren't to
reported on the organization's Form 990 check “Yes,” or “No,” based on the filing be reported in Part II, but transfers by or
and applicable schedules. organization's policies, but for each “Yes” contractions of a disregarded entity are to
response they must report on be taken into account to determine
1. Part I, line 5. Number of
Schedule O (Form 990 or 990-EZ) whether a reportable event (based on
employees. See instructions for Part V,
whether the policy applies to all of the 25% of the filing organization's net
lines 1 and 2 below.
organization's disregarded entities (if assets, including those of its disregarded
2. Part I, line 6. Number of any). entities) has occurred.
volunteers. The total number of
11. Part VII, line 1a. Definitions of 16. Schedule R (Form 990), Part V,
volunteers to be reported can, but isn't
key employee and highest line 2. Transactions with related
required to, include volunteers of any
compensated employee. An officer, organizations. Specified payments to a
disregarded entity.
director, trustee, and employee of a disregarded entity by a controlled entity
3. Part III. Program service disregarded entity can constitute a key of the filing organization, and transfers by
accomplishments. Consider activities

Instructions for Form 990 -85-


a disregarded entity to an exempt 7. Part IV, line 20. Hospitals. See venture, to the extent of the
non-charitable entity, are to be reported instructions for Schedule H in this organization's proportionate interest in
on Schedule R (Form 990), Part V, line 2. Appendix, later. the joint venture. See the instructions for
8. Part IV, lines 21–22. Grants in Schedule H, Part IV, to determine how to
Joint Ventures Treated the United States. See instructions for report an organization's interest in joint
ventures and management companies.
as a Partnership for Schedule I in this Appendix, later.
22. Schedule I (Form 990). Grants
9. Part IV, lines 26–28. Loans,
Federal Income Tax grants, and business transactions in the United States. Include grants
from a joint venture to organizations,
Purposes involving interested persons. See
instructions for Schedule L in this governments, or individuals in the United
If the organization participates as a Appendix, later. States.
partner or member of a joint venture, 23. Schedule J (Form 990).
10. Part IV, line 32. Disposition of
partnership, LLC, or other entity treated Compensation. If an officer, director,
25% of assets. See instructions for
as a partnership for federal tax purposes trustee, or employee of the organization
Schedule N in this Appendix, later.
(referred to here as a “joint venture”), as receives compensation from a joint
described in Regulations sections 11. Part IV, lines 34–37. Related venture, the compensation isn't treated
301.7701-1 through 301.7701-3, then the organizations and unrelated as paid pro rata by the organization. The
organization in general must report the partnerships. See instructions for compensation may need to be reported,
activities of the joint venture as its own Schedule R in this Appendix, later. however, as compensation from a related
activities, and report the joint venture’s 12. Part V, line 3a. Unrelated organization if the joint venture is a
revenue, expenses, and assets, to the business income. Include the related organization.
extent of the organization's proportionate organization's distributive share (whether 24. Schedule K (Form 990), Part III,
interest in the joint venture. For example, or not distributed) of income or loss of the line 1. Private business use. Report
a proportionate share of the political joint venture that is unrelated business certain joint ventures that owned property
campaign activity or lobbying activity income in determining the organization's financed by tax-exempt bonds.
conducted by a joint venture of which the gross unrelated business income.
organization is a member must be 25. Schedule L (Form 990 or
13. Part VI. Governance, 990-EZ), Parts II–IV. Loans, grants,
reported on Schedule C (Form 990 or management, and disclosure. Don't
990-EZ), Political Campaign and and business transactions involving
take into account a joint venture for interested persons. Report loans,
Lobbying Activities. If the joint venture is purposes of Part VI (except for lines 16a
a member of a second joint venture, grants, and business transactions
and 16b). between the organization and a joint
which is a member of a third joint venture,
etc., the activities similarly pass through 14. Part VII. Compensation. See venture, if the joint venture is an
all joint ventures to the organization, instructions for Schedule J in this interested person for purposes of
according to the organization's Appendix, later. Schedule L, and if the transaction meets
proportionate share in each of the joint 15. Parts VIII, IX, and X. Financial the applicable reporting thresholds
ventures. statements. Report in accordance with described in the Schedule L instructions.
the organization's books and records. Also report certain joint ventures with
The following is a list of special interested persons as provided in the
16. Part XII. Financial statements
instructions for the Form and Schedules Schedule L, Part IV, instructions, as
and reporting. Disregard a joint venture.
regarding the reporting of a joint venture business transactions themselves.
of which the organization is a member. 17. Schedule C (Form 990 or
26. Schedule N (Form 990 or
990-EZ). Political campaign and
1. Part I, line 2. Disposition of 25% 990-EZ), Part II. Disposition of 25% of
lobbying activities. Report the
of assets. See instructions for assets. In determining whether the
organization's share of political campaign
Schedule N in this Appendix, later. organization made a disposition of more
or lobbying activities conducted by a joint
2. Part I, lines 7a–7b. Unrelated than 25% of its assets, take into account
venture.
business income. Include the its share of dispositions by a joint
18. Schedule D (Form 990), Part II. venture.
organization's distributive share (whether Conservation easements. Include
or not distributed) of income or loss of the 27. Schedule R (Form 990). Related
conservation easements held by a joint
joint venture that is unrelated business organizations. Report relationships with
venture formed for the purpose of holding
income in determining the organization's certain joint ventures in Parts III and VI,
the easements.
gross and net unrelated business and certain transactions with joint
income. 19. Schedule F (Form 990). ventures in Part V.
Activities outside the United States.
3. Part IV, lines 3–5. Political
campaign and lobbying activities. See
Include activities of a joint venture, Appendix G. Section
including grants to organizations or
instructions for Schedule C in this
Appendix, later.
individuals outside the United States. 4958 Excess Benefit
4. Part IV, line 7. Conservation
20. Schedule G (Form 990 or
990-EZ). Fundraising and gaming.
Transactions
easements. See instructions for Include activities of a joint venture and The intermediate sanction regulations are
Schedule D in this Appendix, later. the organization's share of revenues and important to the exempt organization
5. Part IV, lines 14–16. Activities expenses. On Part III, line 12, check community as a whole, and for ensuring
outside the United States. See “Yes” if the joint venture was formed to compliance in this area. The rules
instructions for Schedule F in this administer charitable gaming. provide a roadmap by which an
Appendix, later. organization can steer clear of situations
21. Schedule H (Form 990). that may give rise to inurement.
6. Part IV, lines 17–19. Hospitals. Report activities, expenses,
Fundraising and gaming. See and revenue of hospital facilities and Under section 4958, any disqualified
instructions for Schedule G in this other programs operated by any joint person who benefits from an excess
Appendix, later. benefit transaction with an applicable

-86- Instructions for Form 990


tax-exempt organization is liable for a over the affairs of the organization. This operating budget, or compensation for
25% tax on the excess benefit. The would include, for example, voting employees.
disqualified person is also liable for a members of the governing body, and • The person manages a discrete
200% tax on the excess benefit if the persons holding the power of: segment or activity of the organization
excess benefit isn't corrected by a certain • Presidents, chief executive officers, that represents a substantial portion of
date. Also, organization managers who or chief operating officers. the activities, assets, income, or
participate in an excess benefit • Treasurers and chief financial officers. expenses of the organization, as
transaction knowingly, willfully, and A disqualified person also includes compared to the organization as a whole.
without reasonable cause are liable for a certain family members of a disqualified • The person owns a controlling interest
10% tax on the excess benefit, not to person, and 35% controlled entities of (measured by either vote or value) in a
exceed $20,000 for all participating a disqualified person. corporation, partnership, or trust that is a
managers on each transaction. disqualified person.
The following persons are considered
• The person is a nonstock organization
Applicable Tax-Exempt disqualified persons for the following
organizations, along with certain family
controlled directly or indirectly by one or
Organization members and 35% controlled entities
more disqualified persons.
Facts and circumstances tending to
These rules only apply to certain associated with them:
show no substantial influence.
applicable section 501(c)(3), 501(c)(4), • For a transaction involving a donor
advised fund, a donor or donor advisor • The person is an independent
and 501(c)(29) organizations. An contractor whose sole relationship to the
applicable tax-exempt organization is of that donor advised fund,
organization is providing professional
a section 501(c)(3), 501(c)(4), or 501(c) • For a donor advised fund sponsoring
organization, an investment advisor of advice (without having decision-making
(29) organization that is tax exempt under authority) for transactions from which the
section 501(a), or was an organization at the sponsoring organization, and
independent contractor won't
any time during a 5-year period ending • For a supported organization of a
section 509(a)(3) supporting economically benefit.
on the day of the excess benefit • The person has taken a vow of
transaction. organization, the disqualified persons of
the section 509(a)(3) supporting poverty.
An applicable tax-exempt organization. • Any preferential treatment the person
organization doesn't include: receives based on the size of the
See the Instructions for Form 4720, person's donation is also offered to
• A private foundation as defined in Schedule I, for more information others making comparable widely
section 509(a),
regarding these disqualified persons. solicited donations.
• A governmental entity that is exempt
from (or not subject to) taxation without Who isn't a disqualified person? The • The direct supervisor of the person
regard to section 501(a) or relieved from rules also clarify which persons aren't isn't a disqualified person.
filing an annual return under Regulations considered to be in a position to exercise • The person doesn't participate in any
section 1.6033-2(g)(6), and substantial influence over the affairs of an management decisions affecting the
organization as a whole or a discrete
• Certain foreign organizations. organization. They include:
segment of the organization that
• An employee who receives benefits
An organization isn't treated as a that total less than the highly represents a substantial portion of the
section 501(c)(3), 501(c)(4), or 501(c) compensated amount ($120,000 in activities, assets, income, or expenses of
(29) organization for any period covered 2015–2018, and $125,000 in 2019) and the organization, as compared to the
by a final determination that the who doesn't hold the executive or voting organization as a whole.
organization wasn't tax exempt under powers just mentioned; isn't a family What about persons who staff affili-
section 501(a), so long as the member of a disqualified person; and ated organizations? In the case of
determination wasn't based on private isn't a substantial contributor; multiple affiliated organizations, the
inurement or one or more excess benefit • Tax-exempt organizations described determination of whether a person has
transactions. in section 501(c)(3); and substantial influence is made separately
Disqualified Person • Section 501(c)(4) organizations for for each applicable tax-exempt
transactions engaged in with other organization. A person may be a
Most section 501(c)(3), 501(c)(4), or section 501(c)(4) organizations. disqualified person for more than one
501(c)(29) organization employees and organization in the same transaction.
independent contractors won't be Who else can be considered a dis-
affected by these rules. Only the few qualified person? Other persons not
described above also can be considered
Excess Benefit
influential persons within these
organizations are covered by these rules disqualified persons, depending on all Transaction
when they receive benefits, such as the relevant facts and circumstances. An excess benefit transaction
compensation, fringe benefits, or Facts and circumstances tending to generally is a transaction in which an
contract payments. The IRS calls this show substantial influence. economic benefit is provided by an
class of covered individuals disqualified • The person founded the organization. applicable tax-exempt organization,
persons. • The person is a substantial contributor directly or indirectly, to or for the use of
to the organization under the section any disqualified person, and the value
A disqualified person, regarding any 507(d)(2)(A) definition, only taking into of the economic benefit provided by the
transaction, is any person who was in a account contributions to the organization applicable tax-exempt organization
position to exercise substantial influence for the past 5 years. exceeds the value of the consideration
over the affairs of the applicable • The person's compensation is (including the performance of services)
tax-exempt organization at any time primarily based on revenues derived from received for providing the benefit, but see
during a 5-year period ending on the date the activities of the organization that the the special rules below for donor
of the transaction. Persons who hold person controls. advised funds and supporting
certain powers, responsibilities, or • The person has or shares authority to organizations. An excess benefit
interests are among those who are in a control or determine a substantial portion transaction also can occur when a
position to exercise substantial influence of the organization's capital expenditures,

Instructions for Form 990 -87-


disqualified person embezzles from the from the person. A substantial contributor This is the section 162 standard that will
exempt organization. includes the grantor of a trust. apply in determining the reasonableness
The excess benefit for substantial of compensation. The fact that a bonus or
To determine whether an excess revenue-sharing arrangement is subject
contributors and parties related to those
benefit transaction has occurred, all to a cap is a relevant factor in
contributors includes the amount of the
consideration and benefits exchanged determining the reasonableness of
grant, loan, compensation, or similar
between a disqualified person and the compensation.
payment. For additional information, see
applicable tax-exempt organization, and
the Instructions for Form 4720. For determining the reasonableness
all entities it controls, are taken into
of compensation, all items of
account. When does an excess benefit trans-
compensation provided by an applicable
action usually occur? For federal
For purposes of determining the value tax-exempt organization in exchange for
income tax purposes, an excess benefit
of economic benefits, the value of the performance of services are taken
transaction occurs on the date the
property, including the right to use into account in determining the value of
disqualified person receives the
property, is the fair market value (FMV). compensation (except for certain
economic benefit from the organization.
FMV is the price at which property, or the economic benefits that are disregarded,
However, when a single contractual
right to use property, would change as discussed in What benefits are
arrangement provides for a series of
hands between a willing buyer and a disregarded? in this Appendix, later).
compensation payments or other
willing seller, neither being under any Items of compensation include:
payments to a disqualified person during
compulsion to buy, sell, or transfer the disqualified person's tax year, any • All forms of cash and noncash
property or the right to use property, and compensation, including salary, fees,
excess benefit transaction for these
both having reasonable knowledge of bonuses, severance payments, and
payments occurs on the last day of the
relevant facts. deferred and noncash compensation;
disqualified person’s tax year.
• The payment of liability insurance
Donor advised funds. For a donor In the case of the transfer of property premiums for, or the payment or
advised fund, an excess benefit subject to a substantial risk of forfeiture, reimbursement by the organization of
transaction includes a grant, loan, or in the case of rights to future taxes or certain expenses under section
compensation, or similar payment from compensation or property, the 4958, unless excludable from income as
the fund to a: transaction occurs on the date the a de minimis fringe benefit under section
• Donor or donor advisor, property, or the rights to future 132(a)(4). (A similar rule applies in the
• Family member of a donor or donor compensation or property, isn't subject to private foundation area.) Inclusion in
advisor, a substantial risk of forfeiture. Where the compensation for purposes of
• 35% controlled entity of a donor or disqualified person elects to include an determining reasonableness under
donor advisor, or amount in gross income in the tax year of section 4958 doesn't control inclusion in
• 35% controlled entity of a family transfer under section 83(b), the excess income for income tax purposes;
member of a donor or donor advisor. benefit transaction occurs on the date the • All other compensatory benefits,
For these transactions, the excess disqualified person receives the whether or not included in gross income
benefit is defined as the amount of the economic benefit for federal income tax for income tax purposes;
grant, loan, compensation, or similar purposes. • Taxable and nontaxable fringe
payment. For additional information, see Section 4958 applies only to benefits, except fringe benefits described
the Instructions for Form 4720. post-September 1995 transactions. in section 132; and
Supporting organizations. For any Section 4958 applies the general rules to • Foregone interest on loans.
supporting organization defined in excess benefit transactions occurring on Written intent required to treat bene-
section 509(a)(3), an excess benefit or after September 14, 1995. Section fits as compensation. An economic
transaction includes grants, loans, 4958 doesn't apply to any transaction benefit isn't treated as consideration for
compensation, or similar payment occurring pursuant to a written contract the performance of services unless the
provided by the supporting organization that was binding on September 13, 1995, organization providing the benefit clearly
to a: and at all times thereafter before the indicates its intent to treat the benefit as
• Substantial contributor, transaction occurs. The special rules compensation when the benefit is paid.
• Family member of a substantial relevant to transactions with donor
An applicable tax-exempt organization
contributor, advised funds and supporting
(or entity that it controls) is treated as
• 35% controlled entity of a substantial organizations apply to transactions
clearly indicating its intent to provide an
contributor, or occurring after August 17, 2006, except
economic benefit as compensation for
• 35% controlled entity of a family that taxes on certain transactions
services only if the organization provides
member of a substantial contributor. between supporting organizations and
written substantiation that is
Additionally, an excess benefit their substantial contributors apply to
contemporaneous with the transfer of the
transaction includes any loans provided transactions occurring on or after July 25,
economic benefits under consideration.
by the supporting organization to a 2006.
Ways to provide contemporaneous
disqualified person (other than an
organization described in section 509(a) What Is Reasonable written substantiation of its intent to
provide an economic benefit as
(1), (2), or (4)). Compensation? compensation include:
A substantial contributor is any person Reasonable compensation is the • The organization produces a signed
who contributed or bequeathed an valuation standard that is used to written employment contract;
aggregate of more than $5,000 to the determine if there is an excess benefit in • The organization reports the benefit as
organization, if that amount is more than the exchange of a disqualified person's compensation on an original Form W-2,
2% of the total contributions and services for compensation. Reasonable Form 1099, or Form 990, or on an
bequests received by the organization compensation is the value that would amended form filed before the start of an
before the end of the tax year of the ordinarily be paid for like services by like IRS examination; or
organization in which the contribution or enterprises under like circumstances. • The disqualified person reports the
bequest is received by the organization benefit as income on the person's original

-88- Instructions for Form 990


Form 1040 or Form 1040-SR or on an exchange for the provision of specified the transaction that was approved and
amended form filed before the start of an services or property. those who voted on it;
IRS examination. A fixed formula can, in general, c. The comparability data obtained
incorporate an amount that depends and relied upon by the authorized body
Exception. To the extent the economic upon future specified events or and how the data was obtained;
benefit is excluded from the disqualified contingencies, as long as no one has
person's gross income for income tax d. Any actions by a member of the
discretion when calculating the amount of authorized body having a conflict of
purposes, the applicable tax-exempt a payment or deciding whether to make a
organization isn't required to indicate its interest; and
payment (such as a bonus).
intent to provide an economic benefit as e. Documentation of the basis for the
compensation for services. (For example: Treatment as new contract. A binding determination before the later of the next
employer-provided health benefits and written contract providing that it can be meeting of the authorized body or 60
contributions to qualified plans under terminated or canceled by the applicable days after the final actions of the
section 401(a).) tax-exempt organization without the other authorized body are taken, and approval
party's consent (except as a result of of records as reasonable, accurate, and
What benefits are disregarded? The substantial nonperformance) and without complete within a reasonable time
following economic benefits are substantial penalty, is treated as a new thereafter.
disregarded for purposes of section contract, as of the earliest date that any
4958. termination or cancellation would be Special rebuttable presumption rule
• Nontaxable fringe benefits. An effective. Also, a contract in which there for nonfixed payments. As a general
economic benefit that is excluded from is a material change, which includes an rule, in the case of a nonfixed payment,
income under section 132. extension or renewal of the contract no rebuttable presumption arises until the
• Benefits to volunteers. An economic (except for an extension or renewal exact amount of the payment is
benefit provided to a volunteer for the resulting from the exercise of an option determined, or a fixed formula for
organization if the benefit is provided to by the disqualified person), or a more calculating the payment is specified, and
the general public in exchange for a than incidental change to the amount the three requirements creating the
membership fee or contribution of $75 or payable under the contract, is treated as presumption have been satisfied.
less per year. a new contract as of the effective date of However, if the authorized body
• Benefits to members or donors. An the material change. Treatment as a new approves an employment contract with a
economic benefit provided to a member contract can cause the contract to fall disqualified person that includes a
of an organization due to the payment of outside the initial contract exception, and nonfixed payment (for example,
a membership fee, or to a donor as a it thus would be tested under the FMV discretionary bonus) with a specified cap
result of a deductible contribution, if a standards of section 4958. on the amount, the authorized body can
significant number of nondisqualified establish a rebuttable presumption as to
persons make similar payments or Rebuttable Presumption the nonfixed payment when the
contributions and are offered a similar
economic benefit. of Reasonableness employment contract is entered into by,
in effect, assuming that the maximum
• Benefits to a charitable beneficiary. An Payments under a compensation amount payable under the contract will
economic benefit provided to a person arrangement are presumed to be be paid, and satisfying the requirements
solely as a member of a charitable class reasonable and the transfer of property giving rise to the rebuttable presumption
that the applicable tax-exempt (or right to use property) is presumed to for that maximum amount.
organization intends to benefit as part of be at FMV, if the following three
the accomplishment of its exempt conditions are met. An IRS challenge to the presumption
purpose. of reasonableness. The IRS can refute
1. The transaction is approved by an
• Benefits to a governmental unit. A authorized body of the organization (or
the presumption of reasonableness only
transfer of an economic benefit to or for if it develops sufficient contrary evidence
an entity it controls), which is composed to rebut the probative value of the
the use of a governmental unit, as
of individuals who don't have a conflict of comparability data relied upon by the
defined in section 170(c)(1), if exclusively
interest concerning the transaction. authorized body. This provision gives
for public purposes.
2. Before making its determination, taxpayers added protection if they
Is there an exception for initial con- the authorized body obtained and relied faithfully find and use contemporaneous
tracts? Section 4958 doesn't apply to upon appropriate data as to persuasive comparability data when they
any fixed payment made to a person comparability. There is a special safe provide the benefits.
pursuant to an initial contract. This is a harbor for small organizations. If the
very important exception, since it would Organizations that don't establish a
organization has gross receipts of less
potentially apply, for example, to all initial presumption of reasonableness. An
than $1 million, appropriate comparability
contracts with new, previously unrelated organization can still comply with section
data includes data on compensation paid
officers and contractors. 4958 even if it didn't establish a
by three comparable organizations in the
An initial contract is a binding written presumption of reasonableness. In some
same or similar communities for similar
contract between an applicable cases, an organization may find it
services.
tax-exempt organization and a person impossible or impracticable to fully
3. The authorized body adequately implement each step of the rebuttable
who wasn't a disqualified person documents the basis for its determination
immediately before entering into the presumption process. In those cases, the
concurrently with making that organization should try to implement as
contract. determination. The documentation many steps as possible, in whole or in
A fixed payment is an amount of cash should include: part, in order to substantiate the
or other property specified in the a. The terms of the approved reasonableness of benefits as timely and
contract, or determined by a fixed transaction and the date approved; as well as possible. If an organization
formula that is specified in the contract, doesn't satisfy the requirements of the
which is to be paid or transferred in b. The members of the authorized
body who were present during debate on rebuttable presumption of
reasonableness, a facts and

Instructions for Form 990 -89-


circumstances approach will be followed, manager isn't considered to have by the IRS can be held in a donor
using established rules for determining participated in an excess benefit advised fund.
reasonableness of compensation and transaction where the manager has
Property. With the agreement of the
benefit deductions in a manner similar to opposed the transaction in a manner
applicable tax-exempt organization, a
the established procedures for section consistent with the fulfillment of the
disqualified person can make a payment
162 business expenses. manager's responsibilities to the
by returning the specific property
organization. For example, a director who
Section 4958 Taxes votes against giving an excess benefit
previously transferred in the excess
benefit transaction. The return of the
would ordinarily not be subject to this tax.
Tax on disqualified persons. An property is considered a payment of cash
excise tax equal to 25% of the excess A person participates in a transaction (or cash equivalent) equal to the lesser
benefit is imposed on each excess knowingly if the person has actual of:
benefit transaction between an knowledge of sufficient facts so that, • The FMV of the property on the date
applicable tax-exempt organization based solely upon the facts, the the property is returned to the
and a disqualified person. The transaction would be an excess benefit organization, or
disqualified person who benefited from transaction. Knowing doesn't mean • The FMV of the property on the date
the transaction is liable for the tax. If the having reason to know. The organization the excess benefit transaction occurred.
25% tax is imposed and the excess manager ordinarily won't be considered
knowing if, after full disclosure of the Insufficient payment. If the payment
benefit transaction isn't corrected within resulting from the return of the property is
the taxable period, an additional excise factual situation to an appropriate
professional, the organization manager less than the correction amount, the
tax equal to 200% of the excess benefit is disqualified person must make an
imposed. relied on the professional's reasoned
written opinion on matters within the additional cash payment to the
If a disqualified person makes a organization equal to the difference.
professional's expertise or if the manager
payment of less than the full correction
relied on the fact that the requirements Excess payment. If the payment
amount, the 200% tax is imposed only on
for the rebuttable presumption of resulting from the return of the property
the unpaid portion of the correction
reasonableness have been satisfied. exceeds the correction amount described
amount. If more than one disqualified
Participation by an organization manager above, the organization can make a cash
person received an excess benefit from
is willful if it is voluntary, conscious, and payment to the disqualified person equal
an excess benefit transaction, all the
intentional. An organization manager's to that difference.
disqualified persons are jointly and
participation is due to reasonable cause if
severally liable for the taxes.
the manager has exercised responsibility Churches and Section
To avoid the imposition of the 200% on behalf of the organization with
tax, a disqualified person must correct ordinary business care and prudence. 4958
the excess benefit transaction during the The regulations make it clear that the IRS
taxable period. The taxable period begins Correcting an Excess will apply the procedures of section 7611
on the date the transaction occurs and
ends on the earlier of the date the Benefit Transaction when initiating and conducting any
inquiry or examination into whether an
statutory notice of deficiency is issued or A disqualified person corrects an excess benefit transaction has occurred
the section 4958 taxes are assessed. excess benefit transaction by undoing between a church and a disqualified
This 200% tax can be abated if the the excess benefit to the extent possible, person.
excess benefit transaction subsequently and by taking any additional measures
is corrected during a 90-day correction necessary to place the organization in a Revenue-Sharing
period. financial position not worse than that in
which it would be if the disqualified Transactions
Tax on organization managers. An
person were dealing under the highest Proposed intermediate sanction
excise tax equal to 10% of the excess
fiduciary standards. The organization regulations were issued in 1998. The
benefit can be imposed on the
isn't required to rescind the underlying proposed regulations had special
participation of an organization manager
agreement; however, the parties may provisions covering “any transaction in
in an excess benefit transaction between
need to modify an ongoing contract for which the amount of any economic
an applicable tax-exempt organization
future payments. benefit provided to or for the use of a
and a disqualified person. This tax, which
disqualified person is determined in
can't exceed $20,000 for any single A disqualified person corrects an whole or in part by the revenues of one or
transaction, is only imposed if the 25% excess benefit by making a payment in more activities of the organization.” —
tax is imposed on the disqualified person, cash or cash equivalents equal to the so-called revenue-sharing transactions.
the organization manager knowingly correction amount to the applicable Rather than setting forth additional rules
participated in the transaction, and the tax-exempt organization. The correction on revenue-sharing transactions, the final
manager's participation was willful and amount equals the excess benefit plus regulations reserve this section.
not due to reasonable cause. There is the interest on the excess benefit; the Consequently, until the IRS issues new
also joint and several liability for this tax. interest rate can be no lower than the regulations for this reserved section on
An organization manager can be liable applicable federal rate. There is an revenue-sharing transactions, these
for both the tax on disqualified persons anti-abuse rule to prevent the disqualified transactions will be evaluated under the
and on organization managers in person from effectively transferring general rules (for example, the fair
appropriate circumstances. property other than cash or cash market value standards) that apply to all
An organization manager is any equivalents. contractual arrangements between
officer, director, or trustee of an applicable tax-exempt organizations
applicable tax-exempt organization, or Exception. For a correction of an
and their disqualified persons.
any individual having powers or excess benefit transaction described in
responsibilities similar to officers, Donor advised funds (discussed earlier),
directors, or trustees of the organization, no amount repaid in a manner prescribed
regardless of title. An organization

-90- Instructions for Form 990


Revocation of • View Internal Revenue Bulletins (IRBs) Schedule B (Form 990, 990-EZ, or
published in the last few years. 990-PF). Schedule of Contributors.
Exemption and Section • Sign up to receive local and national
Schedule C (Form 990 or 990-EZ).
tax news by email.
4958 Political Campaign and Lobbying
Section 4958 doesn't affect the Ordering forms, instructions, Activities.
substantive standards for tax exemption TIP and publications. Schedule D (Form 990). Supplemental
under section 501(c)(3), 501(c)(4), or Financial Statements.
501(c)(29), including the requirements • You can download items from the IRS
that the organization be organized and website at IRS.gov/OrderForms to order Schedule E (Form 990 or 990-EZ).
operated exclusively for exempt current-year forms, instructions, and Schools.
purposes, and that no part of its net publications, and prior-year forms and Schedule F (Form 990). Statement of
earnings inure to the benefit of any instructions. You should receive your Activities Outside the United States.
private shareholder or individual. The order within 10 days.
legislative history indicates that in most Schedule G (Form 990 or 990-EZ).
instances, the imposition of this Supplemental Information Regarding
How to Get Tax Help Fundraising or Gaming Activities.
intermediate sanction will be in lieu of
revocation. The IRS has indicated that Tax reform. Major tax reform legislation Schedule H (Form 990). Hospitals.
the following factors will be considered impacting individuals, businesses, and
(among other facts and circumstances) in Schedule I (Form 990). Grants and
tax-exempt entities was approved by Other Assistance to Organizations,
determining whether to revoke an Congress in the Tax Cuts and Jobs Act
applicable tax-exempt organization's Governments, and Individuals in the
on December 22, 2017. Go to IRS.gov/ United States.
exemption status where an excess TaxReform for information and updates
benefit transaction has occurred: on how this legislation affects your taxes. Schedule J (Form 990). Compensation
• The size and scope of the Information.
organization's regular and ongoing Getting answers to your tax law ques-
activities that further exempt purposes tions. On IRS.gov, get answers to your Schedule K (Form 990). Supplemental
before and after the excess benefit tax questions anytime, anywhere. Information on Tax-Exempt Bonds.
transaction or transactions occurred; • Go to IRS.gov/Help or IRS.gov/ Schedule L (Form 990 or 990-EZ).
• The size and scope of the excess LetUsHelp pages for a variety of tools Transactions With Interested Persons.
benefit transaction or transactions that will help you get answers to some of
(collectively, if more than one) in relation the most common tax questions. Schedule M (Form 990). Noncash
to the size and scope of the • Go to IRS.gov/Ita for the Interactive Contributions.
organization's regular and ongoing Tax Assistant, a tool that will ask you Schedule N (Form 990 or 990-EZ).
activities that further exempt purposes; questions on a number of tax law topics Liquidation, Termination, Dissolution, or
• Whether the organization has been and provide answers. You can print the Significant Disposition of Assets.
involved in multiple excess benefit entire interview and the final response for
transactions with one or more persons; your records. Schedule O (Form 990 or 990-EZ).
• Access tax law information in your Supplemental Information to Form 990 or
• Whether the organization has 990-EZ.
implemented safeguards that are electronic filing software.
reasonably calculated to prevent excess • Apply for an Employer Identification Schedule R (Form 990). Related
benefit transactions; and Number (EIN). Go to IRS.gov and enter Organizations and Unrelated
• Whether the excess benefit Apply for an EIN in the search box. Partnerships.
transaction has been corrected, or the • Read the Internal Revenue Code,
Regulations, or other official guidance. Forms W-2 and W-3. Wage and Tax
organization has made good faith efforts
• Read Internal Revenue Bulletins. Statement; and Transmittal of Wage and
to seek correction from the disqualified
Tax Statements.
person(s) who benefited from the excess Getting tax forms and publications.
benefit transaction. Go to IRS.gov/Forms to view, download, Form W-9. Request for Taxpayer
Identification Number and Certification.
Appendix H. Forms and or print all of the forms and publications
you may need. You can also download Form 720. Quarterly Federal Excise Tax
Publications To File or and view popular tax publications and Return.
instructions on mobile devices as an
Use eBook at no charge. Or, you can go to The Patient-Centered Outcomes
IRS.gov/OrderForms to place an order ! Research fee is imposed on
CAUTION issuers of specified health
How To Get Forms and and have forms mailed to you within 10
business days. insurance policies (section 4375) and
Publications plan sponsors of applicable self-insured
Internet. You can access the Phone. If you have questions and/or health plans (section 4376) for policy and
IRS website at IRS.gov 24 hours need help completing Form 990 or Form plan years ending on or after October 1,
a day, 7 days a week to: 990-EZ, please call 877-829-5500. This 2012. See Form 720 and section 4376 for
toll-free telephone service is available more information.
• Download forms, including talking tax Monday through Friday.
forms, instructions, and publications. In addition to various federal excise taxes
• Order IRS products online. Other Forms That May Be that are paid with the filing of Form 720,
• Research your tax questions online. Required the Patient-Centered Outcomes
• Search publications online by topic or Research fee that is imposed on issuers
keyword. Schedule A (Form 990 or 990-EZ). of specified health insurance policies and
• Use the online Internal Revenue Code, Public Charity Status and Public Support. plan sponsors of applicable self-insured
Regulations, or other official guidance. health plans is payable annually and
reported on the Form 720 that is filed for

Instructions for Form 990 -91-


the second quarter of each year, which is interest, qualified tuition and related Form 5768. Election/Revocation of
due no later than July 31 of the calendar expenses received, and a contribution of Election by an Eligible Section 501(c)(3)
year immediately following the last day of a qualified vehicle that has a claimed Organization To Make Expenditures To
the policy year or plan year to which the value of more than $500. Influence Legislation.
fee applies.
Form 1099 series. Information returns Form 7004. Application for Automatic
Form 926. Return by a U.S. Transferor to report acquisitions or abandonments of Extension of Time To File Certain
of Property to a Foreign Corporation. secured property, proceeds from broker Business Income Tax, Information, and
and barter exchange transactions, Other Returns.
Form 940. Employer's Annual Federal
cancellation of debt, dividends and
Unemployment (FUTA) Tax Return. Form 8038 series. Tax-exempt bonds.
distributions, certain government and
Form 941. Employer's QUARTERLY state qualified tuition program payments, Form 8274. Certification by Churches
Federal Tax Return. Used to report social taxable distributions from cooperatives, and Qualified Church-Controlled
security, Medicare, and income taxes interest payments, payments of long-term Organizations Electing Exemption From
withheld by an employer and social care and accelerated death benefits, Employer Social Security and Medicare
security and Medicare taxes paid by an miscellaneous income payments, Taxes.
employer. distributions from an HSA, Archer MSA
or Medicare Advantage MSA, original Form 8282. Donee Information Return.
Form 943. Employer's Annual Federal Required of the donee of charitable
issue discount, distributions from
Tax Return for Agricultural Employees. deduction property who sells,
pensions, annuities, retirement or
Form 990-T. Exempt Organization profit-sharing plans, IRAs, insurance exchanges, or otherwise disposes of
Business Income Tax Return. Filed contracts, etc., and proceeds from real donated property within 3 years after
separately for organizations subject to estate transactions. Also, use certain of receiving it. The form is also required of
UBTI that have total gross income from these returns to report amounts that were any successor donee who disposes of
all of their unrelated trades or received as a nominee on behalf of the charitable deduction property within 3
businesses of $1,000 or more for the tax another person. years after the date that the donor gave
year. The Form 990-T is also filed to pay the property to the original donee. It
Form 1120-POL. U.S. Income Tax doesn't matter who gave the property to
the section 6033(e)(2) proxy tax. For
Return for Certain Political Organizations. the successor donee. It may have been
Form 990, see Part V, line 3, and its
instructions; for Form 990-EZ, see Part V, Form 1128. Application To Adopt, the original donee or another successor
line 35, and its instructions. Change, or Retain a Tax Year. donee.
Form 990-W. Estimated Tax on Form 2848. Power of Attorney and Form 8283. Noncash Charitable
Unrelated Business Taxable Income for Declaration of Representative. Contributions.
Tax-Exempt Organizations. Form 8300. Report of Cash Payments
Form 3115. Application for Change in
Form 1023. Application for Recognition Accounting Method. Over $10,000 Received in a Trade or
of Exemption Under Section 501(c)(3) of Business. Used to report cash amounts
Form 3520. Annual Return To Report in excess of $10,000 that were received
the Internal Revenue Code.
Transactions With Foreign Trusts and in a single transaction (or in two or more
Form 1023-EZ. Streamlined Application Receipt of Certain Foreign Gifts. related transactions) in the course of a
for Recognition of Exemption Under trade or business (as defined in section
Form 4506. Request for Copy of Tax
Section 501(c)(3) of the Internal Revenue 162).
Return.
Code.
Form 4506-A. Request for Public However, if the organization receives
Form 1024. Application for Recognition a charitable cash contribution in excess
Inspection or Copy of Exempt or Political
of Exemption Under Section 501(a). of $10,000, it isn't subject to the reporting
Organization IRS Form.
Form 1024-A. Application for requirement since the funds weren't
Form 4562. Depreciation and received in the course of a trade or
Recognition of Exemption Under Section
Amortization. business.
501(c)(4) of the Internal Revenue Code.
Form 4720. Return of Certain Excise Form 8328. Carryforward Election of
Form 1040. U.S. Individual Income Tax
Taxes Under Chapters 41 and 42 of the Unused Private Activity Bond Volume
Return.
Internal Revenue Code. Cap.
Form 1040-SR. U.S. Income Tax Return
Form 5471. Information Return of U.S. Form 8718. User Fee for Exempt
for Seniors.
Persons With Respect to Certain Foreign Organization Determination Letter
Form 1041. U.S. Income Tax Return for Corporations. Request.
Estates and Trusts. Required of section
Form 5500. Annual Return/Report of Form 8821. Tax Information
4947(a)(1) nonexempt charitable trusts
Employee Benefit Plan. Employers who Authorization.
that also file Form 990 or 990-EZ.
maintain pension, profit-sharing, or other
However, if the trust doesn't have any Form 8822-B. Change of Address or
funded deferred compensation plans
taxable income under Subtitle A of the Responsible Party—Business. Used to
generally are required to file the Form
Code, it can file Form 990 or 990-EZ, and notify the IRS of a change in mailing
5500. This requirement applies whether
doesn't have to file Form 1041 to meet its address that occurs after the return is
or not the plan is qualified under the
section 6012 filing requirement. If this filed.
Internal Revenue Code and whether or
condition is met, complete Form 990 or
not a deduction is claimed for the current Form 8868. Application for Automatic
990-EZ, and don't file Form 1041.
tax year. Extension of Time To File an Exempt
Form 1096. Annual Summary and Organization Return.
Form 5578. Annual Certification of
Transmittal of U.S. Information Returns.
Racial Nondiscrimination for a Private Form 8870. Information Return for
Form 1098 series. Information returns School Exempt From Federal Income Transfers Associated With Certain
to report mortgage interest, student loan Tax. Personal Benefit Contracts. Used to

-92- Instructions for Form 990


identify those personal benefit contracts more details, including the definition of organizations, but some other types of
for which funds were transferred to the responsible persons. section 501(c) organizations are also
organization, directly or indirectly, as well affected. If the organization uses Form
Pub. 15-A. Employer's Supplemental
as the transferors for, and beneficiaries 990 or 990-EZ to satisfy state or local
Tax Guide.
of, those contracts. filing requirements, such as those under
Pub. 463. Travel, Entertainment, Gift, state charitable solicitation acts, note the
Form 8871. Political Organization
and Car Expenses. following discussions.
Notice of Section 527 Status.
Pub. 525. Taxable and Nontaxable Determine state filing requirement.
Form 8872. Political Organization
Income. The organization can consult the
Report of Contributions and
appropriate officials of all states and
Expenditures. Pub. 526. Charitable Contributions.
other jurisdictions in which it does
Form 8886. Reportable Transaction Pub. 538. Accounting Periods and business to determine their specific filing
Disclosure Statement. Methods. requirements. Doing business in a
jurisdiction can include any of the
Form 8886-T. Disclosure by Pub. 557. Tax-Exempt Status for Your
following:
Tax-Exempt Entity Regarding Prohibited Organization.
Tax Shelter Transaction. • Soliciting contributions or grants by
Pub. 561. Determining the Value of mail or otherwise from individuals,
Form 8899. Notice of Income From Donated Property. businesses, or other charitable
Donated Intellectual Property. Used to organizations;
Pub. 598. Tax on Unrelated Business
report net income from qualified
Income of Exempt Organizations. • Conducting programs;
intellectual property to the IRS and the • Having employees within that
donor. Pub. 892. How To Appeal an IRS jurisdiction;
Form 8940. Request for Miscellaneous
Decision on Tax-Exempt Status. • Maintaining a checking account; or
Determination, Under Section 507, Pub. 946. How To Depreciate Property. • Owning or renting property there.
509(a), 4940, 4942, 4945, and 6033 of Monetary tests can differ. Some or all
Pub. 1771. Charitable
the Internal Revenue Code. of the dollar limitations applicable to Form
Contributions—Substantiation and
Disclosure Requirements. 990 or 990-EZ when filed with the IRS
Form 8963. Report of Health Insurance
may not apply when using Form 990 or
Provider Information.
Pub. 1828. Tax Guide for Churches and 990-EZ in place of state or local report
Form 8976. Notice of Intent to Operate Religious Organizations. forms. Examples of the IRS dollar
Under Section 501(c)(4). limitations that don't meet some state
Pub. 3079. Tax-Exempt Organizations
Form SS-4. Application for Employer and Gaming. requirements are the normally $50,000
Identification Number. gross receipts minimum that creates an
Pub. 3386. Tax Guide for Veterans' obligation to file with the IRS and the
FinCEN Form 114. Report of Foreign Organizations. $100,000 minimum for listing
Bank and Financial Accounts. independent contractors on Form 990,
Pub. 3833. Disaster Relief, Providing
Assistance Through Charitable Part VII, Section B.
Helpful Publications Organizations. Additional information may be re-
Pub. 15. (Circular E), Employer's Tax Pub. 4220. Applying for 501(c)(3) quired. State or local filing requirements
Guide. Tax-Exempt Status. can require the organization to attach to
Form 990 or 990-EZ one or more of the
Trust Fund Recovery Penalty. Pub. 4221-PC. Compliance Guide for following:
! If certain excise, income, social
CAUTION security, and Medicare taxes that
501(c)(3) Public Charities. • Additional financial statements, such
Pub. 4221-PF. Compliance Guide for as a complete analysis of functional
must be collected or withheld aren't
501(c)(3) Private Foundations. expenses or a statement of changes in
collected or withheld, or these taxes
net assets;
aren't paid to the IRS, the trust fund
recovery penalty can apply. The trust
Pub. 4302. A Charity's Guide to Vehicle • Notes to financial statements;
fund recovery penalty can be imposed on
Donations. • Additional financial statements;
all persons (including volunteers) who the Pub. 4303. A Donor's Guide to Vehicle • A report on the financial statements by
Donations. an independent accountant; and
IRS determines were responsible for
collecting, accounting for, and paying • Answers to additional questions and
Pub. 4386. Compliance Checks. other information.
over these taxes, and who acted willfully
in not doing so. Pub. 4573. Group Exemptions. Each jurisdiction can require the
additional material to be presented on
Pub. 4630. Exempt Organizations
This penalty doesn't apply to volunteer forms they provide. The additional
Products & Services Navigator.
unpaid members of any board of trustees information shouldn't be submitted with
or directors of a tax-exempt organization,
if these members are solely serving in an
Appendix I. Use of Form the Form 990 or 990-EZ filed with the
IRS, unless included in Schedule O
honorary capacity, don't participate in the 990 or 990-EZ To Satisfy (Form 990 or 990-EZ).
day-to-day or financial activities of the
organization, and don't have actual State Reporting Even if the Form 990 or 990-EZ that
the organization files with the IRS is
knowledge of the failure to collect,
account for, and pay over these taxes.
Requirements accepted by the IRS as complete, a copy
Some states and local governmental of the same return filed with a state won't
However, the preceding sentence fully satisfy that state's filing requirement
doesn't apply if it results in no person units will accept a copy of Form 990 or
990-EZ in place of all or part of their own if (1) required information isn't provided,
being liable for the penalty. including any of the additional information
financial report forms. The substitution
The penalty is equal to the unpaid trust applies primarily to section 501(c)(3) discussed in this Appendix, or (2) the
fund tax. See Pub. 15 (Circular E) for state determines that the form wasn't

Instructions for Form 990 -93-


completed by following the applicable organizations and donors for report certain information on noncash
Form 990 or 990-EZ instructions or contributions. See also Pub. 526, contributions.
supplemental state instructions. In that Charitable Contributions, and Pub. 1771, Dispositions of donated property.
case, the state may ask the organization Charitable Contributions—Substantiation If an organization receives a charitable
to provide the missing information or to and Disclosure Requirements. contribution of property and within 3
submit an amended return. years sells, exchanges, or otherwise
Schedule B (Form 990, 990-EZ, or
Use of audit guides may be required. 990-PF). Many organizations that file disposes of the property, the organization
To ensure that all organizations report Form 990, 990-EZ, or 990-PF must file may need to file Form 8282, Donee
similar transactions uniformly, many Schedule B to report on tax-deductible Information Return. See Form 990, Part
states require that contributions, gifts, and non-tax-deductible contributions. V, lines 7c and 7d.
grants, similar amounts, and functional See Schedule B and its instructions to Donated property over $5,000. If the
expenses be reported according to the determine whether Schedule B must be organization received from a donor a
AICPA Audit and Accounting Guide, filed, and for the public inspection rules partially completed Form 8283, Noncash
Not-for-Profit Entities (2018), applicable to that form. Charitable Contributions, the donee
supplemented, as applicable, by the organization generally should complete
Solicitation of nondeductible contri- the Form 8283 and return it so the donor
Standards of Accounting and Financial
bution. See the instructions to Form can get a charitable contribution
Reporting for Voluntary Health and
990, Part V, line 6a and 6b, for rules on deduction. The organization should keep
Welfare Organizations issued jointly by
public notice of non-deductibility when a copy for its records. See Form 8283 for
the National Health Council, Inc., the
soliciting nondeductible contributions. more details.
National Assembly of Voluntary Health
and Social Welfare Organizations, and Keeping fundraising records for Qualified intellectual property. An
the United Way of America (1998). tax-deductible contributions. A organization described in section 170(c)
section 501(c) organization that is eligible (except a private foundation) that
Donated services and facilities. Even receives or accrues net income from a
to receive tax-deductible contributions
though donated services and facilities qualified intellectual property contribution
under section 170(c) must keep sample
may be reported as items of revenue and must file Form 8899, Notice of Income
copies of its fundraising materials, such
expense in certain circumstances, many From Donated Intellectual Property. See
as:
states and the IRS don't permit the Form 990, Part V, line 7g. The
inclusion of those amounts in Parts VIII
• Dues statements,
• Fundraising solicitations, organization must file Form 8899 for any
and IX of Form 990, Part I of Form tax year that includes any part of the
990-EZ, or (except for donations by a
• Tickets,
• Receipts, or 10-year period beginning on the date of
governmental unit) in Schedule A (Forms contribution but not for any tax years in
990 and 990-EZ). The optional reporting
• Other evidence of payments received
in connection with fundraising activities. which the legal life of the qualified
of donated services and facilities is intellectual property has expired or the
discussed in the instructions for Part III property failed to produce net income.
for Form 990. IF.... THEN....
A donee organization reports all
Amended returns. If the organization The It must keep samples of the income from donated qualified
submits supplemental information or files organization advertising copy. intellectual property as income other than
an amended Form 990 or 990-EZ with advertises its
contributions (for example, royalty
fundraising
the IRS, it must also send a copy of the income from a patent). A donee isn't
events,
information or amended return to any required to report as contributions on
state with which it filed a copy of Form The It must keep samples of scripts, Form 990 (including statements) any of
990 or 990-EZ originally to meet that organization transcripts, printouts of emails
the additional deductions claimed by
state's filing requirement. If a state uses radio, and Web pages, or other
television, or evidence of solicitations in the
donors under section 170(m)(1). See
requires the organization to file an Pub. 526, Charitable Contributions.
Internet to media.
amended Form 990 or 990-EZ to correct solicit Motor vehicles, boats, and
conflicts with the Form 990 or 990-EZ contributions, airplanes. Special rules apply to
instructions, the organization must also charitable contributions of motor
The It must keep samples of the
file an amended return with the IRS. vehicles, boats, or airplanes with a
organization fundraising materials used by
Method of accounting. Most states uses outside the outside fundraisers. claimed value of more than $500. See
require that all amounts be reported fundraisers, Form 990, Part V, line 7h; section 170(f)
based on the accrual method of (12); Pub. 4302, A Charity’s Guide to
accounting. See also General Instruction Vehicle Donations; and the Instructions
D. For each fundraising event, the for Form 1098-C, Contributions of Motor
organization must keep records to show Vehicles, Boats, and Airplanes.
Time for filing can differ. The deadline
the portion of any payment received from
for filing Form 990 or 990-EZ with the IRS Substantiation and disclosure
patrons that isn't deductible; that is, the
differs from the time for filing reports with requirements for charitable
retail value of the goods or services
some states. contributions.
received by the patrons. See Disclosure
Public inspection. The Form 990 or statement for quid pro quo contributions, Recordkeeping for cash, check, or
990-EZ information made available for later. other monetary charitable gifts. To
public inspection by the IRS can differ deduct a contribution of a cash, check, or
Noncash contributions. other monetary gift (regardless of the
from that made available by the states.
Form 990 Schedules. An organization amount), a donor must maintain a bank
Appendix J. may be required to file Schedule M to
report certain noncash (property)
record or a written communication from
the donee organization showing the
Contributions contributions; see the instructions for donee's name, date, and amount of the
This Appendix discusses certain federal Schedule M on who must file. Also, an contribution. See section 170(f)(17) and
tax rules that apply to exempt organization that files Schedule B must Regulations section 1.170A-15 for more

-94- Instructions for Form 990


information. In the case of a text disregarded entity), which is treated as a Goods or services with
message contribution, the donor's phone disregarded entity of (organization's insubstantial value. Generally, under
bill meets the section 170(f)(17) name) for federal tax purposes. No section 170, the deductible amount of a
recordkeeping requirement of a reliable goods or services were provided in contribution is determined by taking into
written record if it shows the name of the exchange for your contribution.” See account the fair market value (FMV),
donee organization and the date and Notice 2012-52, 2012-35 I.R.B. 317. not the cost to the charity, of any benefits
amount of contribution. Exception. The written that the donor received in return.
Acknowledgment to substantiate acknowledgment need not include a However, the cost to the charity may be
charitable contributions. A donee good faith estimate of value for goods or used in determining whether the benefits
organization should be aware that a services given to the donor if they are: are insubstantial. See below.
donor of a charitable contribution of $250 1. Goods or services with Cost basis. If a taxpayer makes a
or more (including a contribution of insubstantial value. payment of $55.50 or more to a charity
unreimbursed expenses) can't take an and receives only token items in return,
income tax deduction unless the donor 2. Certain membership benefits. the items have insubstantial value if they:
obtains the organization’s 3. Goods or services described in (1) • Bear the charity’s name or logo, and
acknowledgment to substantiate the or (2) given to the employees of a donor • Have an aggregate cost to the charity
charitable contribution. See section organization or the partners of a donor of $11.10 or less (low-cost article amount
170(f)(8) and Regulations section partnership. of section 513(h)(2)).
1.170A-13(f). A charitable organization 4. Intangible religious benefits. Fair market value basis. If a
that receives a payment made as a taxpayer makes a payment to a
contribution is treated as the donee These exceptions are defined below. charitable organization in a fundraising
organization for this purpose even if the Disclosure statement for quid pro campaign and receives benefits with a
organization (according to the donor’s quo contributions. If the organization FMV of not more than 2% of the amount
instructions or otherwise) distributes the receives a quid pro quo contribution of of the payment, or $111, whichever is
amount received to one or more charities. more than $75, the organization must less, the benefits received have
provide a disclosure statement to the insubstantial value in determining the
The organization's acknowledgment donor. See section 6115. taxpayer’s contribution.
must:
The organization’s disclosure The dollar amounts given above
1. Be written. statement must: are applicable to tax year 2019
2. Be contemporaneous.
!
CAUTION under Rev. Proc. 2018-57, sec.
1. Be written.
3. State the amount of any cash it 3.34, 2018-49 I.R.B. 827. They are
2. Estimate in good faith the value of
received. adjusted annually for inflation.
the organization’s goods or services
4. State: given in return for the donor’s
When a donee organization provides
a. Whether the organization gave the contribution.
a donor only with goods or services
donor any intangible religious benefits 3. Describe, but need not value, having insubstantial value under Rev.
(no valuation needed). certain goods or services given to the Procs. 2018-57, 2018-18 (and any
b. Whether the organization gave the donor’s employees or partners. successor documents), the
donor any goods or services in return for 4. Inform the donor that a charitable contemporaneous written
the donor’s contribution (a quid pro quo contribution deduction is limited as acknowledgment may indicate that no
contribution). follows: goods or services were provided in
exchange for the donor’s payment.
5. Describe goods or services the Donor’s contribution
organization: Certain membership benefits. Other
Less goods or services that are disregarded
a. Received (no valuation needed). The organization’s money, goods, and for substantiation and disclosure
b. Gave (good faith estimate of value services given in return purposes are annual membership
needed). Equals benefits offered to a taxpayer in
Donor’s deductible charitable exchange for a payment of $75 or less
If the organization accepts a contribution. per year that consist of:
contribution in the name of one of its Exceptions: No disclosure statement
activities or programs, then indicate the is required if the organization gave only 1. Any rights or privileges that the
organization's name in the the following: taxpayer can exercise frequently during
acknowledgment as well as the the membership period such as:
1. Goods or services with
program's name. For example: “Thank a. Free or discounted admission to
insubstantial value,
you for your contribution of $300 to the organization's facilities or events,
(organization's name) made in the name 2. Certain membership benefits,
b. Free or discounted parking.
of our Special Relief Fund program. No 3. Goods or services described in (1)
goods or services were provided in or (2) given to the employees of a donor 2. Admission to events that are:
exchange for your contribution.” organization or the partners of a donor a. Open only to members, and
Similarly, if a domestic organization partnership, or b. Within the low-cost article
owns and controls a domestic 4. Intangible religious benefits. limitation, per person.
disregarded entity, and the disregarded
These exceptions are defined below. Example 1. E offers a basic
entity receives a contribution, then
See also Regulations sections 1.170A-1, membership benefits package for $75.
indicate the organization's name in the
1.170A-13, and 1.6115-1. The package gives members the right to
acknowledgment as well as the
buy tickets in advance, free parking, and
relationship with the disregarded entity. Certain goods or services disregar- a gift shop discount of 10%. E’s $150
For example: “Thank you for your ded for substantiation and disclosure preferred membership benefits package
contribution of $300 to (organization's purposes. also includes a $20 poster. Both the
name) made in the name of (name of

Instructions for Form 990 -95-


basic and preferred membership • To obtain an organization's written organization must be careful to satisfy the
packages are for a 12-month period and acknowledgment substantiating the section 6115 written disclosure statement
include about 50 productions. E offers F, donation. requirement in a timely manner because
a patron of the arts, the preferred There is no prescribed format for the of the penalties involved.
membership benefits in return for a organization's written acknowledgment of Quid pro quo contribution. A quid
payment of $150 or more. F accepts the a donation. Letters, postcards, or pro quo contribution is a payment that is
preferred membership benefits package computer-generated forms may be made both as a contribution and as a
for $300. E’s written acknowledgment acceptable. The acknowledgment must, payment for goods or services provided
satisfies the substantiation requirement if however, provide sufficient information to by the donee organization.
it describes the poster, gives a good faith substantiate the amount of the deductible Example. A donor gives a charity
estimate of its FMV ($20), and disregards contribution. The organization may either: $100 in consideration for a concert ticket
the remaining membership benefits. • Provide separate statements for each valued at $40 (a quid pro quo
Example 2. In Example 1, if F contribution of $250 or more, or contribution). In this example, $60 would
received only the basic membership • Furnish periodic statements be deductible. Because the donor’s
package for its $300 payment, E’s substantiating contributions of $250 or payment exceeds $75, the organization
acknowledgment need state only that no more. must furnish a disclosure statement even
goods or services were provided. Separate contributions of less than $250 though the taxpayer’s deductible amount
aren't subject to the requirements of doesn't exceed $75. Separate payments
Example 3. G Theater Group of $75 or less made at different times of
section 170(f)(8), whether or not the sum
performs four plays. Each play is the year for separate fundraising events
of the contributions made by a taxpayer
performed twice. Non-members can won't be aggregated for purposes of the
to a donee organization during a tax year
purchase a ticket for $15. For a $60 $75 threshold.
equals $250 or more.
membership fee, however, members are
Contemporaneous. A written Good faith estimate. An organization
offered free admission to any of the
acknowledgment is contemporaneous if may use any reasonable method in
performances. H makes a payment of
the donor obtains it on or before the making a good faith estimate of the value
$350 and accepts this membership
earlier of: of goods or services provided by that
benefit. Because of the limited number of
performances, the membership privilege • The date the donor files the original organization in consideration for a
return for the tax year in which the taxpayer’s payment to that organization.
can't be exercised frequently. Therefore,
contribution was made; or A good faith estimate of the value of
G’s acknowledgment must describe the
free admission benefit and estimate its • The due date (including extensions) goods or services that aren't generally
for filing the donor’s original return for that available in a commercial transaction
value in good faith.
year. may be determined by reference to the
Certain goods or services provided FMV of similar or comparable goods or
to donor’s employees or partners. Substantiation of payroll
contributions. An organization may services. Goods or services may be
Certain goods or services provided to similar or comparable even though they
employees of donor organizations or substantiate an employee’s contribution
by deduction from its payroll by: don't have the unique qualities of the
partners of donor partnerships may be goods or services that are being valued.
disregarded for substantiation and • A pay stub, Form W-2, or other
document showing a contribution to a Goods or services. Goods or
disclosure purposes. Nevertheless, the
donee organization, together with services include:
donee organization's disclosure
statement must describe the goods or • A pledge card or other document from • Cash,
services. A good faith estimate of value the donee organization that shows its • Property,
isn't needed. name. For contributions of $250 or more, • Services,
the document must state that the donee • Benefits, and
Example. Museum J offers a basic organization provides no goods or • Privileges.
membership benefits package for $40. It services for any payroll contributions. In consideration for. A donee
includes free admission and a 10% gift The amount withheld from each payment organization provides goods or services
shop discount. Corporation K makes a of wages to a taxpayer is treated as a in consideration for a taxpayer’s payment
$50,000 payment to J and in return, J separate contribution. if, at the time the taxpayer makes the
offers K’s employees free admission, a Substantiation of matched payment to the donee organization, the
t-shirt with J’s logo that costs J $4.50, payments. If a taxpayer’s payment to a taxpayer receives, or expects to receive,
and a 25% gift shop discount. Because donee organization is matched by goods or services in exchange for that
the free admission is a privilege that can another payor, and the taxpayer receives payment.
be exercised frequently and is offered in goods or services in consideration for its Goods or services a donee
both benefit packages, and the value of payment and some or all of the matching organization provides in consideration for
the t-shirts is insubstantial, Museum J's payment, those goods or services will be a payment by a taxpayer include goods
disclosure statement need not value or treated as provided in consideration for or services provided in a year other than
mention the free admission benefit or the the taxpayer’s payment and not in the year in which the donor makes the
t-shirts. However, because the 25% gift consideration for the matching payment. payment to the donee organization.
shop discount to K’s employees differs Disclosure statement. An
from the 10% discount offered in the Intangible religious benefits.
organization must provide a written Intangible religious benefits are provided
basic membership benefits package, J's disclosure statement to donors who
disclosure statement must describe the only by organizations organized
make a “quid pro quo contribution” in exclusively for religious purposes.
25% discount, but need not estimate its excess of $75 (section 6115). This
value. Examples include:
requirement is separate from the written
substantiation acknowledgment a donor
• Admission to a religious ceremony,
Definitions needs for deductibility purposes. While,
and
Substantiation. It is the responsibility in certain circumstances, an organization
• De minimis tangible benefits, such as
of the donor: wine provided in connection with a
may be able to meet both requirements
• To value a donation, and religious ceremony.
with the same written document, an

-96- Instructions for Form 990


Penalties. A charity that knowingly penalty of $10 per contribution, not to Missing & Exploited Children ®
provides a false substantiation exceed $5,000 per fundraising event or (NCMEC). Photographs of missing
acknowledgment to a donor may be mailing. The charity may avoid the children selected by the Center may
subject to the penalties under section penalty if it can show that the failure was appear in instructions on pages that
6701 and/or section 7206(2) for aiding due to reasonable cause (section 6714). would otherwise be blank. You can help
and abetting an understatement of tax bring these children home by looking at
liability. Photographs of Missing the photographs and calling
Charities that fail to provide the required
disclosure statement for a quid pro quo
Children 1-800-THE-LOST (1-800-843-5678) if
you recognize a child.
contribution of more than $75 will incur a The Internal Revenue Service is a proud
partner with the National Center for

Instructions to Form 990 -97-


Index

Appendix E, Group Returns— Business activities 40


$10,000–per-item exception 28 Reporting Information on Behalf of Business Activity Codes 53
$10,000–per-related organization the Group 83 Business code 41
exception 28 Appendix F, Disregarded Entities and Business relationship 21, 55
35% controlled entity 17, 54 Joint Ventures—Inclusion of
Activities and Items 84
Appendix G, Section 4958 Excess C
A Benefit Transactions 86 Calendar year 5
Accountable plan 20, 54 Appendix H, Forms and Publications Capital contributions 17
Accountant 51 to File or Use 91 Capital gains 41
Accounting: Appendix I, Use of Form 990 or Capital stock accounts 50
Fees 46 990-EZ To Satisfy State Reporting Capital surplus 51
Period 5 Requirements 93 Cash 48
Accounting fees 46 Appendix J, Contributions 94 Cash contributions 55
Accounting method 51 Applicable tax-exempt organization 54, Cash receipts and disbursements 5
Accounting period 5, 8 87 Central organization 7, 55
Accounts payable 50 Application for recognition of CEO 21
Accounts receivable 49 exemption 92 CEO, executive director, or top
Accrual 5 Application pending 9 management official 55
Activities 11 Art 12, 54 Certified historic structure 56
Activities conducted outside the United Articles of incorporation 22 Change of address 92
States 54 ASC 2016–14 54 Changes in net assets 93
Activities outside the United States 54 ASC 740 54 Charitable risk pools 3
Address: ASC 958 13, 54 Child care organizations 3
Change in 9 Assessments 39 Children 97
Website 10 Asset(s): Church 3, 56
Address Change 8 Net 50 Church-affiliated organization 4
Administrative 20 Total 50 Closely held stock 56
Advance ruling period 4 Assistance to individuals 45 Club 17
Advertising 47 Attachments 8 Code(s) 3
Affiliate/affiliates 47, 86 Attorney 11 Collectibles 56
Expenses 47 Audit 54, 85 Collections of works of art, historical
Payments 47 Audit committee 20, 55 treasures, and other similar assets 56
Purchases 47 Audited financial statements 13, 54 College 79
State or national organizations 47 Audit guides 94 Committee 4
Affiliated organizations 87 Automatic revocation 7 Compensation 14, 26, 37, 56, 83
Allocations: Current officers 45
Grants, and 11 Disqualified persons 26, 46
Alternate test 79 B Former officers 26
Amended Return 9 Backup withholding 15 Other persons 26
Description of amendment 6 Balance sheet 48 Reasonable 88
Name change amendment 6 Bank account 16 Reportable 28
Annual information return 80 Bank or financial institution trustee Table 32
Anti-abuse rule 79 Exception 31 Compilation (compiled financial
Appendix: Benefits: statements) 13, 56
Appendix A, Exempt Organizations Disregarded 31 Completing the heading 8
Reference Chart 77 Employee 46 Conflict of interest policy 56
Appendix B, How to Determine Members 45, 89 Conflicts of interest policy 22, 24
Whether an Organization's Gross Membership 40 Conservation easement 12, 57
Receipts Are Normally $50,000 (or Bingo 43, 55 Consolidated financial statement 13, 84
$5,000) or Less 78 Black lung benefit trust 4 Contemporaneous 88
Appendix C, Special Gross Receipts Board-designated endowment 55 Contracts 89
Tests for Determining Exempt Board designated endowment (quasi) 13 Contributing employer 64, 72
Status of Section 501(c)(7) and Bond issue 41, 55 Contributions 12, 38, 40, 57
501(c)(15) Organizations 78 Bonds, tax-exempt 50 Disclosure statement 16
Appendix D, Public Inspection of Bonus 89 Donation of services 39
Returns 79 Books and records 5 Donor advised funds 88
Books of account 5 Government 39
Book value 49 Government grants 39

-98- Instructions for Form 990


Membership dues 11, 39 Of vehicles 17 Expenses 41
Noncash 40 Donor advised fund 61 Allocating indirect 44
Nondeductible 16 Donor advised fund(s): Direct 42
Quid pro quo 16 Disqualified person 87 Functional 43
Contributor 2 Donor advisor 17 Fundraising 42, 44
Contributors, Schedule of 40 Exceptions 90 Indirect expenses 44
Control 15, 58 Excess benefit transaction 88 Management and general 44
Controlled entity 15, 58 Grants 88 Occupancy 47
Controlling organization: Sponsoring organization 3 Political 12
Section 512(b)(13) 3 Donor advisor 61 Postage 47
Controlling organization under section Donor contributions: Printing 47
512(b)(13) 59 Acknowledgment 17 Program service 43, 48
Cooperative service organizations 3 Donor-Imposed Restriction 61 Shipping 47
Copies 8 Donor-Restricted Endowment fund 61 Supplies 47
Core form 59 Dues 39 Telephone 47
Corporation 10 Club 33 Extension of time to file 6
Credit counseling services 59 Membership 40, 47
Current year 59 Paid to affiliates 47
F
Facility/facilities 11
D E Facts and circumstances 82
Debt management plan services 59 Economic benefit 87 Fair market value 88
Defeasance escrow 41, 59 Disregarded 89 Fair market value (FMV) 63
Deferred charges 49 Nontaxable fringe benefits 89 Family:
Deferred compensation 59 EIN 61 Family member 87
Deferred revenue 50 Electronic filing 6 Family member, family relationship 63
Defined benefit plan 32 Email subscription 2 FASB ASC 958 38, 50
Nonqualified 32 Employee 62 Federal unemployment tax (FUTA) 92
Qualified 32 Employee(s) 27 Federated fundraising agencies 39
Defined contribution plan: Employee benefit plan 4 Federated fundraising organizations 45
Qualified 32 Employee benefits 46 Fees 46
De minimis fringe benefit 88 Employees, key 27 Accounting 46
Dependent care assistance 33 Employer identification number (EIN): Copies 81
Depreciation 48 Disregarded entities 85 Fundraising 46
Determination letter 3 Section 501(c)(9) organizations 9 Government agencies 40
Direct expenses 42 Employment tax return 6 Initiation 79
Director 14, 59 Endowment fund 13, 62 Legal 46
Director or trustee 27, 59 Endowment funds 13 Membership 78
Disclosure 16 EO Determinations 11 Registration 40
Conflict of interest 24 e-Postcard (see also Form 990–N) 78 Figuring gross receipts 78
Disqualified person(s) 21 Equipment 49 FIN 48 84
Excess business holdings 17 Escrow or custodial account 50, 62 FIN 48 (ASC 740) 63
Statement 16 Estates 38 Final return 6, 9
Disclosure of excess business Estimate, reasonable 10 Financial account 16
holdings 17 Excess benefit transaction 62, 86–88 Financial statements 51, 63
Disqualified person 59 Churches 90 Fiscal year 5, 63
Disqualified persons 87 Correction 90 Five highest compensated
Disregarded benefits 31, 32 Donor advised funds 90 employees 26
Disregarded entities 8, 29, 84 Excess payment 90 Fixed payment 89
Disregarded entity or entities 60 Excise tax 90 Foreign 16
Dissolution 85 Insufficient payment 90 Accounts 16
Distributions 46 Revenue sharing transactions 90 Organization 4
Dividends 40 Revocation of exemption 91 Foreign government 63
Document retention and destruction Section 4958 86 Foreign individual 63
policy 24 Excess business holdings 17 Foreign organization 63
Domestic government 60 Excise taxes 90 Form 8963, Report of Health Insurance
Domestic individual 60 Executive director 24 Provider Information 93
Domestic organization 61 Exempt bond 62 Form 8976. Notice of Intent to Operate
Donations 39 Exempt function 40 Under Section 501(c)(4) 93
Of services 39 Exempt organizations, types of 77 Forms:
Of use of materials, equipment or Exempt purposes 11, 22, 43 FinCEN Form 114 93
facilities 39

Instructions for Form 990 -99-


Form 1023, Application for Expenditures To Influence Form 940, Employer's Annual Federal
Recognition of Exemption Under Legislation 92 Unemployment (FUTA) Tax
Section 501(c)(3) 92 Form 7004, Application for Automatic Return 92
Form 1023-EZ, Streamlined Extension of Time to File Certain Form 941, Employer's Quarterly
Application for Recognition of Business Income Tax, Information, Federal Tax Return 92
Exemption Under Section 501(c) and Other Returns 92 Form 943, Employer's Annual Tax
(3) of the Internal Revenue Form 720, Quarterly Federal Excise Return for Agricultural
Code. 92 Tax Return 91 Employees 92
Form 1024, Application for Form 8038 series, Tax Exempt Form 990–BL, Information and Initial
Recognition of Exemption Under Bonds 92 Excise Tax Return for Black Lung
Section 501(a) 92 Form 8274, Certification by Churches Benefit Trusts and Certain Related
Form 1024-A, Application for and Qualified Church-Controlled Persons 4
Recognition of Exemption under Organizations Electing Exemption Form 990–EZ, Short Form Return of
Section 501(c)(4) of the Internal from Employer Social Security and Organization Exempt From Income
Revenue Code 92 Medicare Taxes 92 Tax 10
Form 1040, U.S. Individual Income Form 8282, Donee Information Form 990–N, Electronic Notice
Tax Return 92 Return 92 (e-Postcard) for Tax-Exempt
Form 1040-SR, U.S.Income Tax Form 8283, Noncash Charitable Organizations Not Required To File
Return for Seniors 92 Contributions 92 Form 990 or 990–EZ 3
Form 1041, U.S. Income Tax Return Form 8300, Report of Cash Payments Form 990–PF, Return of Private
for Estates and Trusts 92 Over $10,000 Received in a Trade Foundation or Section 4947(a)(1)
Form 1065, U.S. Return of Partnership or Business 92 Nonexempt Charitable Trust
Income 4 Form 8328, Carryfoward Election of Treated as a Private Foundation 4
Form 1096, Annual Summary and Unused Private Activity Bond Form 990–T, Exempt Organization
Transmittal of U.S. Information Volume Cap 92 Business Income Tax Return 92
Returns 92 Form 8718, User Fee for Exempt Form 990–W, Estimated Tax on
Form 1098 series 92 Organization Determination Letter Unrelated Business Taxable
Form 1120–POL, U.S. Income Tax Request 92 Income for Tax-Exempt
Return for Certain Political Form 8821, Tax Information Organizations 92
Organizations 92 Authorization 92 Form SS-4, Application for Employer
Form 1128, Application To Adopt, Form 8822-B, Change of Address or Identification Number 93
Change or Retain a Tax Year 92 Responsible Party—Business 92 Form W-2, Wage and Tax
Form 2848, Power of Attorney and Form 8868, Application for Automatic Statement 91
Declaration of Representative 92 Extension of Time to File an Forms and publications 15
Form 3115, Application for Change in Exempt Organization Return 92 Foundations 27
Accounting Method 92 Form 8870, Information Return for Fringe benefits 89
Form 3520, Annual Return To Report Transfers Associated With Certain De minimis 88
Transactions with Foreign Trusts Personal Benefit Contracts 92 Nontaxable 89
and Receipt of Certain Foreign Form 8871, Political Organization Functional expenses 43
Gifts 92 Notice of Section 527 Status 93 Allocating indirect 44
Form 4506, Request for Copy of Tax Form 8872, Political Organization Fundraising 44
Return 92 Report of Contributions and Management and general 44
Form 4506–A, Request for Public Expenditures 93 Program service 43
Inspection or Copy of Exempt or Form 8886, Reportable Transaction Fund Balances 50, 51
Political Organization IRS Form 92 Disclosure Statement 93 Fundraising 39, 63
Form 4562, Depreciation and Form 8886–T, Disclosure by Activities 13
Amortization 92 Tax-Exempt Entity Regarding Events 39
Form 4720, Return of Certain Excise Prohibited Tax Shelter Expenses 44
Taxes Under Chapters 41 and 42 Transaction 93 Fees 46
of the Internal Revenue Code 92 Form 8899, Notice of Income From Records for tax deductible
Form 5471, Information Return of U.S. Donated Intellectual Property 93 contributions 7
Persons With Respect to Certain Form 8940, Request for Fundraising activities 63
Foreign Corporations 92 Miscellaneous Determination, Fundraising events 42, 64
Form 5500, Annual Return/Report of Request for Miscellaneous Funds 50
Employee Benefit Plan 92 Determination, under Section 507,
Form 5578, Annual Certification of 509(a), 4940, 4942, 4945, and
Racial Nondiscrimination for a 6033 of the Internal Revenue G
Private School Exempt From Code 93 GAAP 64
Federal income Tax. 92 Form 926, Return by a U.S. Transferor Gaming 42, 64
Form 5768, Election/Revocation of of Property to a Foreign GEN (Group exemption number) 10
Election by an Eligible Section Corporation 92 Generally accepted accounting
501(c)(3) Organization To Make principles 12

-100- Instructions for Form 990


Generally accepted accounting Grassroots 46
principles/GAAP 64 I In-house expenditures 46
Gifts 38, 40 Income: Joint ventures 86
Goods 42 Exempt function 11 Lobbying activities 67
Goods or services 42 Investment 41 Lobbying expenditures 84
Goods sold, cost of 43 Rental 40 Local governmental unit 50
Governance 86 Unrelated business 15 Lotteries 42
Governing body 64, 85 Incomplete return 7
Governing documents 23 Independent contractor 38, 65
Government: M
Independent voting member of governing
Agency 40 Maintaining offices, employees, or
body 20, 66
Contracts 40 agents 67
Indoor tanning services 18
Contributions 39 Management 85
Information return 80
Fees 40 Management and general expenses 44
Information technology 46, 47
Grants 39, 44 Management company 22, 67
Initial contract 66, 89
Official 47 Medicaid 40
Instant bingo 43, 66
Organization 4 Medical research 67, 80
Institutional trustee 27, 66
Governmental issuer 41, 64 Medicare 92
Insurance 48
Governmental unit 50, 64 Meetings 47
Insurance contract 79
Governmental Unit 64 Member of the governing body 20, 67
Integrated auxiliary 3
Government official 64 Membership 47
Intellectual property 16
Grants 11, 38, 45 Assessments 39
Interest 41, 47
Allocations, and 11 Benefits 41
Mortgage 47
Contributions 11 Dues 39, 47
Tax-exempt 18
Government contributors 39 Merger, articles of 8
Interested persons 85
Payable 50 Miscellaneous 5
Interest income 40, 41
Receivable 48 Expenses 48
Notes and loans receivable 41
Grants and other assistance 64 Mission 4
Securities 41
Grants and other assistance outside the Mission society 4
Inventory 43
United States 13 Money market funds 48
Investment 41
Gross proceeds 65 Mutual or cooperative electric
Committee 20
Gross receipts 65, 78 companies 18
Dividend 41
$50,000 or less 78 Income 79
Acting as agent 78 Interest 41 N
Figuring 78 Management 22 Net assets 50
Gross receipts test: Program-related 41 Net Assets with donor restrictions 68
$5,000 78 Rents 41 Net Assets without Donor Restrictions 68
$50,000 78 Savings and temporary cash 48 Noncash contribution 40
Gross rents 41 Investments 49 Noncash contributions 68
Gross revenue 15 Nonexempt charitable trust 68
Gross sales price 41 Nonfixed payments 89
Group exemption 65, 81 J
Nonprofit health insurance issuer 4
Central/parent organization 81 Joint costs 48
Nonqualified deferred compensation 68
Group return 65, 83 Joint venture 66, 86
Nonqualified defined benefit plan 32
Nonqualified defined contribution
H K plan 32, 35
Heading 8 Key employee 27, 67 Nontaxable fringe benefit 89
Health benefits 32 Notes receivable 49
Helpful hints 2 Number of employees 85
L Nursing homes 40
Highest compensated employee 65, 85 Land 49
Historical treasure 12, 65 Late filing 7
Hospital 84 Legal fees 46 O
Hospital/hospital facility 65 Legislation 67 Occupancy 47
Hospital (or cooperative hospital service Liabilities, total 50 Expense 47
organization) 65 Liquidation 84 Officer 26, 68
Hospital organization 65 List of states 5 Offices 80
Hours per week 30 Loans: OMB Circular A-133 51
Household goods 65 Receivable 49 “On behalf of” issuer 68
Lobbying 67 Ordinary course of business 21
Activity/Activities 12 Organization(s) 4, 90
Expenses 84 Affiliated 87

Instructions for Form 990 -101-


Form of 10 Program service 11 Pub. 557, Tax-Exempt Status for Your
Not required to file 4 Program service accomplishments, Organization 93
Organizational documents 83 statement of 11 Pub. 561, Determining the Value of
Organization manager 68, 90 Program service expenses 43 Donated Property 93
Organizations: Program service revenue 40 Pub. 598, Tax on Unrelated Business
Foreign countries, in 4 Government agency 40 Income of Exempt
Other assets 49 Insurance premiums 40 Organizations 93
Other compensation 28 Interest income 40 Pub. 892, How to Appeal an IRS
Ownership 15 Medicaid 40 Decision on Tax Exempt Status 93
Medicare 40 Pub. 946, How To Depreciate
Membership fees 40 Property 93
P Program-related investments 40 Pub. 947, Practice Before the IRS and
Paid-in capital 51 Rental income 40 Power of Attorney 11
Paid preparer 10 Section 501(c)(9) organization 40 Public charity 70, 84
Paperwork Reduction Act Notice 51 Unrelated trade or business Public Inspection 79
Partnership 86 activities 40 Public interest law firm 12
Payables 50 Prohibited tax shelter transactions 16 Publicly traded securities 49, 70
Payments: Proxy tax 12 Public support 91
Cash 92 PTIN 10, 11 Pull tabs 70
Compensation 88 Pub. 3079, Tax-Exempt Organizations Pull-tabs 43
Nonfixed 89 and Gaming 64 Purchases from affiliates 47
Severance 46 Publications 15 Purpose of Form 2
To affiliates 47 Compliance Checks 93
Payroll taxes 46 Group Exemptions 93
Penalties 7, 16 Pub. 15, (Circular E) Employer's Tax Q
Failure to file 7 Guide 93 Qualified 501(c)(3) bond 70
Perjury 7 Pub. 15–A, Employer's Supplemental Qualified conservation contribution 70
Pension plan contributions 46 Tax Guide (Fringe Benefits) 93 Qualified defined benefit plan 32
Personal benefit contracts 16 Pub. 1771, Charitable Contributions– Qualified defined contribution plan 32
Phone help 2 Substantiation and Disclosure Qualified intellectual property 16
Photographs of Missing Children 97 Requirements 93 Qualified state or local political
Pledges receivable 48 Pub. 1779, Independent Contractor or organization 3, 71
Policies: Employee 38 Quasi-endowment 71
Conflicts of interest 22 Pub. 1828, Tax Guide for Churches Quid pro quo contribution:
Document retention and and Religious Organizations 93 Disclosure statement 16
destruction 24 Pub. 3079, Tax-Exempt Organizations
Joint venture 25 and Gaming 93
Nondiscrimination 92 R
Pub. 3386, Tax Guide for Veterans Racial nondiscrimination 92
Whistleblower 24 Organizations 93
Political: Raffles 42
Pub. 3833, Disaster Relief, Providing Reasonable:
Expenses 85 Assistance Through Charitable
Political campaign activities 69 Amount 80
Organizations 93 Belief 83
Political organization 4 Pub. 4220, Applying for 501(c)(3)
Penalties 80 Burden 81
Tax-Exempt Status 93 Cause 7
Public inspection 79 Pub. 4221–PC, Compliance Guide for
Section 527 3 Compensation 20
501(c)(3) Public Charities 93 Effort 21, 22, 31
State or local 3 Pub. 4221–PF, Compliance Guide for
Political subdivision 69 Estimate 10
501(c)(3) Private Foundations 93 Fee 80
Possession of the United States 69 Pub. 4302, A Charity's Guide to
Postage cost 80 Knowledge 88
Vehicle Donations 93 Relationship 40
Power of attorney 92 Pub. 4303, A Donor's Guide to Vehicle
Premiums 79 Reasonable compensation 71
Donations 93 Reasonable effort 71
Prepaid expenses 49 Pub. 463, Travel, Entertainment, Gift,
Principal officer 69 Reasonableness, rebuttable presumption
and Car Expenses 93 of 89
Printing 47 Pub. 4630, Exempt Organizations
Private business use 69, 86 Receivable 14
Products and Services Account 48
Private delivery services 6 Navigator 93
Private foundation 69, 87 Grants 48
Pub. 525, Taxable and Nontaxable Pledges 48
Privileged relationship 21 Income 93
Proceeds 41, 69 Reconciliation 5
Pub. 526, Charitable Contributions 93 Reconciliation of net assets 51
Professional fundraising services 46, 69 Pub. 538, Accounting Periods and
Program-related investment 40, 69 Recordkeeping 7
Methods 93

-102- Instructions for Form 990


Refunding escrow 14, 71 Membership dues 40 Top management official 27, 74
Refunding issue 72 Section 501(c)(6): Total assets 49, 74
Reimbursement: Lobbying expenses 12 Total liabilities 50
Of expenses 20 Membership dues 40 Transfers 15
Of taxes 88 Section 501(c)(7) 17, 86 Personal benefit contracts 16
Related organization 20, 26, 72 Section 501(c)(9) 9 To controlled entities 15
Religious order 20, 72 Section 6033(e) 12 Travel expense 47
Rent/rental 41 Securities 49 Trust 9
Expense 41 Security/Securities 41 Trustee 74
Income 40 Security/securities 73 Trustee(s) 10, 14, 20, 27
Reportable compensation 14, 72 Sequencing list to complete the form and Institutional 27
Reporting information from third schedules 4 Trust fund recovery penalty:
parties 8 Severance payments 46 Penalties 93
Required electronic filing by exempt Shipping 47 Tuition assistance 32
organizations 1 Short accounting period 5, 73
Requirements for a properly completed Short period 73
Form 990 7 Short year and final returns 31 U
Research 44 Short year and final returns. 32 U.S. possession 3, 75
Retained earnings 51 Signature 10 U.S. Treasury bills 48
Returns and allowances 43 Signature block 10 Uncollectible pledges 38
Revenue 43, 50 Significant disposition of assets 85 Uniform Prudent Management of
Deferred 50 Significant disposition of net assets 73 Institutional Funds Act (UPMIFA) 50
Gross 15 Social club 17 Unincorporated association 9
Program service 40 Social security: United States 10, 74
Special events 42 Tax 46 University/universities 13
Sweepstakes, raffles, and lotteries 42 Solicitations of nondeductible Unrelated business 15, 74
Revenue-sharing transactions 90 contributions 16 Income 38
Review of financial statement 72 SOP 98-2 48 Income tax 80
Review of financial statements 13 Special events 42 Revenue 41
Revocation of exemption 91 Specific instructions for Form 990 8 Unrelated business gross income 74
Rounding off to whole dollars 8 Sponsoring organization 3, 73 Unrelated business income 44, 74
Royalties 41 State: Unrelated organization 14, 74
Filing requirement 93 Unrelated trade or business 75
Reporting requirements 5 Activities 40
S Statement(s) 93 Gross income 86
Salaries 46 Activities outside of United States 13
Sales 43 Audited financial 84
Of inventory 40 V
Financial 51 Vehicle donations 94
Sarbanes-Oxley 24 Functional expenses 43
Savings 48 Voluntary employees' beneficiary
Position 98–2 48 association 9
Savings accounts 48 Program service accomplishments 11
Schedule of contributors 12 Volunteer 10, 75
Revenue 38 Volunteer exception 31
Scholarships 13 State of legal domicile 10, 74
School 73 Voting member of the governing body 75
Subordinate organization 74, 81 Voting member of the governing body/
Section 4947(a)(1) trusts 11, 18 Substantial contributor 62, 87
Section 4958 86, 90, 91 board 20
Substantial influence 87
Section 4958, excise taxes: Supported organization 74, 87
Disqualified persons 87 Supporting organization 74, 88 W
Organization managers 90 Sweepstakes 42 Wages 46
Section 4960 2 Website address 10
Section 4968 2, 18, 19 Whistleblower policy 24
Section 501(c)(12) 17 T Widely available 82
Section 501(c)(15) 3, 78 Tax-exempt bond 74 Withholding:
Section 501(c)(3) 3 Tax shelter transaction 16 Backup 15
Applicable organization 87 Tax year 27, 74 Works of art 12, 75
Disclosure of transactions and TE/GE EO Determinations 79
relationships 19 Telephone number 9
Section 501(c)(4): Term endowment 74 Y
Applicable organization 87 Terminated 9 Year of formation 10, 75
Section 501(c)(5): Text message contribution 95
Lobbying expenses 12 Top financial official 27, 74

Instructions for Form 990 -103-

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