Form 990 Instructions for 501c3 Nonprofits Filing Annual Return

Form 990 Instructions for 501c3 nonprofits who’d like to file on their own

These Form 990 Instructions provide specific explanations for each line-item of the form and for all of the form 990 schedules. In addition, they contain the following items to help exempt organizations successfully complete their information returns:

• Sequencing List – Provides step-by-step guidelines on a logical route through the form
• Glossary – Defines important terms included on the Form 990
• Appendices – Clarifies specialized topics and improves technical understanding of specific filing requirements
• Compensation Table – Explains locations on Form 990 for reporting various types of compensation
• Checklist of Required Schedules – Shows at a glance whether the organization has engaged in activities that require it to complete and file certain schedules

Step One: The Heading (Form 990 page 1)

This section is where you enter the basic information identifying the filing organization: its name, address, EIN, telephone number, website address, etc.

For name of organization, enter the organization’s legal name.  If the organization does business under a different name, enter that name on the next line.  Skip item G until Part VIII of the core form has been completed.

Step Two: Related Organizations (Schedule R)

An organization can be related because it controls or is controlled by the filing organization or by the same persons that control the filing organization. It can also be related through a 509(a)(3) supporting/supported organization relationship. A related organization may be an exempt organization, a taxable corporation, partnership or trust, or a disregarded entity. Related organizations are further defined in the glossary and the Schedule R instructions.

Step Three: Officers, Directors, Trustees, Key Employees, Five Highest Compensated Employees

Officers manage the organization’s daily operations and are defined by state law and the organization’s organizing document and bylaws. They must include the organization’s top management official and top financial official.

Directors and trustees are voting members of the organization’s governing body. Key employees and highest compensated employees are people who are not officers, directors, or trustees, but who meet certain tests regarding high levels of compensation.  Key employees also exercise a certain level of control or authority over the organization.

Officers, directors, trustees, key employees, and five highest compensated employees are further defined in the glossary and the Part VII instructions.

Step Four: Part VIII, Statement of Revenue

• Column A (Total Revenue): Filers report their gross receipts for all sources of revenue.
• Column B (Related or Exempt Function Revenue): Filers report all revenue from activities related to the organization’s exempt purpose as well as any revenue that is excludable from gross income other than by reason of IRC sections 512, 513, or 514. For example, interest on state and local bonds excluded from tax by section 103 is reported in column
• Column C (Unrelated Business Revenue): Filers report any revenue from an unrelated trade or business, whether or not regularly carried
• Column D: Filers report revenue excludable from unrelated business income by section 512, 513, or

All filers must complete column A. All filers except section 527 political organizations must also complete columns B, C, and D. Here are some clarifications on certain important lines:

Line 1.  On lines 1a through 1f, report all amounts received as voluntary contributions, gifts, or grants.  Voluntary contributions include any part of a payment for which the donor does not receive full retail value from the donee. Report gross amounts of contributions collected by fundraisers in the organization’s name; do not report a net amount after expenses. You will report all expenses of raising contributions later in Parts VIII and IX. Report the fair market value of a non-cash contribution at the time of the donation.

The following are not considered contributions and should not be reported in any section of Line 1:

• Grants or fees from governmental units, foundations, or other exempt organizations that represent a payment for a service, the use of a facility, or a product that primarily benefits the payer
• That portion of amounts received from any fundraising solicitation that represents payment for goods or services
• Donations of services or the use of materials, equipment, or facilities
• Un-reimbursed expenses of officers, employees, or volunteers

Line 1a.  (Federated Campaigns). On line 1a, enter the amount of contributions received through solicitation campaigns conducted by federated fundraising agencies, such as a United Way organization.

Line 1b. (Membership Dues).  On line 1b, enter membership dues that function as contributions, or dues paid primarily to support the organization rather than to receive goods or services in return. In determining whether an amount is a payment for goods and services, ignore insubstantial benefits such as free or discounted admission to the organization’s facilities or events or preferred access to goods or services.

Line 1c. (Fundraising Events). On line 1c, enter the amount of contributions received from fundraising events.

Line 1d.  (Related Organizations). On line 1d, report amounts contributed by “related organizations,” including contributions received from a parent organization, a subordinate, or other organization with the same parent.

Include only contributions made to enable the organization to provide a service to the general public.  Do not include payments for services, facilities, or products that primarily benefit the payor.

Line 1e. (Government Grants). On line 1e, report grants from local, state, or federal government sources or foreign governments if the primary purpose of the grant is to enable the organization to provide a service for direct benefit of the public. Do not include grants that serve the direct and immediate needs of the governmental unit.

Line 1f.  (Other Contributions). On line 1f, report all other contributions not reported already on lines 1a through 1e.

Line 1g. (Noncash Contributions). On line 1g, enter the amount of non-cash contributions that were included on lines 1a through 1f. Non-cash contributions are anything other than cash, checks, money orders, credit card charges, wire transfers, and other transfers and deposits to a cash account of the organization.  More information about non-cash contributions is in the instructions to Schedule M, which the filer must complete if the amount on line 1g exceeds $25,000.

Line 2. (Program Service Revenue). On lines 2a-2e, enter the five largest sources of program service revenue. On line 2f, enter the total program service revenue from sources not listed in lines 2a-2e. Program services are activities that further the organization’s exempt purposes.

If you enter an amount anywhere on lines 2a-2e, you must also enter a business code from Appendix J, Business Activity Codes, or the NAICS website referenced in the instructions

Line 6a.  (Gross Rents). On line 6a, enter the amount of rental income received from investment property. Allocate revenue to real property or personal property. Do not report on line 6a rental income that is related to an exempt function; report such income on line 2 instead.

Line 8a.  (Gross Income from Fundraising Events).  Income from fundraising events is reported on line 8. Fundraising events are events conducted for the sole or primary purpose of raising funds to finance the organization’s exempt activities, and do not include events or activities that further an organization’s exempt purposes.  The latter are considered program services and revenue from such events is entered on line 2.

Typical fundraising events include charity balls, bazaars, and banquets, door- to-door sales of merchandise, concerts, carnivals, sporting events, and auctions.

Example:  As part of a fundraising event, an organization sends a book to anyone who contributes at least $40. The retail value of the book is $16 and the wholesale cost of the book is $8. A $40 contribution would be recorded as follows:

• $24 reported as a contribution on line 1c
• $16 reported as gross income from fundraising events on line 8a
• $8 reported as a direct expense on line 8b

Indirect fundraising expenses (such as advertising for a fundraising event) must be reported on the appropriate line in Part IX, column D, and not on line 8b.

Step Four Part IX – Statement of Functional Expenses

In completing Part IX, use the organization’s normal accounting method. If the normal accounting method does not allocate expenses, use any reasonable method of allocation, but be sure the method you use is documented in your records.  Also, do not report expenses reported with other revenue in Part VIII, such as rental expenses, direct fundraising, gaming expenses, or the cost of goods sold.

Column A:  All filers are required to complete column A, Total expenses; however, only section 501c3 and 501c4 organizations are required to allocate expenses to columns B through D.

Column B: Enter all program service expenses. Include lobbying expenses in column B if the lobbying is directly related to exempt purposes. Also include program service expenses for unrelated trade or business activities.

Column C:  Report expenses that are attributable to the management and general operations of the organization. Also, record expenses for all lobbying that is not directly related to exempt purposes. Other items that should be reported in this column include expenses associated with:

• Board of directors meetings
• Committee and staff meetings that do not directly involve a program service or fundraising activity
• General legal services
• Accounting and auditing
• Liability insurance
• Human resources
• Management of investments

Please refer to Limitation on lobbying activities of tax-exempt nonprofit organizations for more detail.

Column D: Enter expenses incurred in soliciting contributions, gifts, and grants. All expenses (except for direct expenses for fundraising events reported in Part VIII, line 8b), including allocable overhead costs, incurred in publicizing and conducting fundraising campaigns and events and soliciting grants from foundations or governmental units, should be reported as fundraising expenses.

Step Four: Part X – Balance Sheet

The balance sheet of an exempt organization is similar to the balance sheet of a for-profit entity, with one major exception.  For-profit entities maintain capital or equity accounts that trace partners’ or shareholders’ interests in the entity. This is generally irrelevant for 501c3 organizations as inurement of net earnings is prohibited and private benefit must be insubstantial.

All organizations must complete Part X; a substitute balance sheet will not be accepted.

In column A, enter the amounts from the previous year’s column B. If the organization was not required to file a Form 990 the previous year, enter the amounts that the organization would have entered in column B had it been required to file the previous year. If the organization is in its first year of existence, enter zeros on lines 16, 26, 33, and 34 in column A.  If the organization is making a final return, enter zeros on lines 16, 26, 33, and 34 in column B.

Step Five: Item G

Go back to the heading on page 1 and complete item G, Gross receipts.  The instructions tell you which lines of Part VIII to add to compute gross receipts.

Step Six: Part III- Statement of Program Service Accomplishments

The statement of program service accomplishments allows the organization to tell its story – to explain its mission, describe its programs and services, and trumpet its accomplishments.  Organizations are encouraged to be expansive in describing program services.  A staff person or administrator can create considerable goodwill for being open and candid about an organization’s operations and activities.

A program service is a major activity, usually ongoing, that furthers the organization’s mission.

Preparers are not limited to the spaces provided in Part III. Particularly discursive filers can also make use of Schedule O to continue their descriptions. Schedule O is essentially a blank page where organizations can include information not mentioned elsewhere.

Step Six: Part V – Statements Regarding Other IRS Filings and Tax Compliance

The questions in Part V serve two purposes: First, they alert an organization they might have other reporting obligations and other forms to file besides Form 990.  Second, they ask whether the organization is engaged in certain kinds of activities and, if so, whether it satisfied the tax law obligations that accompany such activities.

The preparer should keep the following questions and corresponding facts in mind when completing this section:

Question: Was the organization a party to a prohibited tax shelter transaction and, if so, did it file Form 8886-T? (Line 5)

Fact: An organization that is a party to a prohibited tax shelter transaction is required to file Form 8886-T to disclose that it is a party to such transaction, and to identify any other party to the transaction that it knows of.

Question: If it is a section 501c3 or other sponsoring organization maintaining a donor advised fund or a supporting organization, did the organization or the fund have excess business holdings? (Line 8)

Fact:  Donor advised funds and certain supporting organizations are treated as private foundations for the purposes of the section 4943 excise tax on excess business holdings and, consequently, must indicate whether they had excess business holdings at any time during the year.

Question: Did the organization make any taxable distributions under section 4966? (Line 9a)

Fact: Any distribution from a donor advised fund to an individual – whether a grant, reimbursement, payment of compensation for services, or other distribution – is subject to an excise tax under section 4966.  Sponsoring organizations and fund managers liable for the tax must file Form 4720.

Question: Did the organization make distributions to a donor, donor advisor, or related person under section 4967? (Line 9b)

Fact:  If an organization makes a distribution from a donor advised fund on the advice of a donor, donor advisor, family member, or 35 percent controlled entity of any of the above persons, and the distribution directly or indirectly benefits one of such persons, section 4967 imposes a tax on the person upon whose advice the distribution was made, the beneficiary of the distribution, and a fund manager for knowingly agreeing to make the distribution. The persons liable for the section 4967 tax must file Form 4720 to pay the tax.

Step Six: Part VII – Compensation of Officers, Directors, Trustees, Key Employees, Highest Compensated Employees, and Independent Contractors

“Current” refers to any time during the tax year for which the return is being filed.  For additional information, see definitions of officers, directors, trustees, key employees, and highest compensated employees listed in Step 6 of the Sequencing list, above.

Section A requires organizations to list the name and title of:

• Every current officer, director, and trustee of the organization, even those that received no compensation during the tax year.
• Current key employees – those persons, other than officers, directors, and trustees, who (a) had reportable compensation exceeding $150,000 from the filing organization and related organizations for the calendar year ending with or within the organization’s tax year (the $150,000 test); (b) had or shared organization-wide control or influence similar to that of an officer, director, or trustee, or managed or had authority or control over at least ten percent of the organization’s activities (the responsibility test); and (c) were within that group of the organization’s top 20 highest paid persons for the year who satisfied both the $150,000 test and the responsibility test described in (a) and (b).
• The five highest compensated current employees, not including persons already identified as an officer, director, trustee, or key employee, and not including any employee who received $100,000 or less of reportable compensation from the organization and any related organizations. To determine the five highest compensated employees, consider only the amount of compensation paid in the calendar year ending with or within the organization’s tax
• Any former officer, key employee, or highest compensated employee who received more than $100,000 of reportable compensation in the calendar year ending with or within the organization’s tax year from the organization and any related organizations.
• Any former director or trustee who received, for services provided in that person’s former capacity as director or trustee, more than $10,000 of reportable compensation in the calendar year ending with or within the organization’s tax year from the organization and any related

For purposes of Part VII, “former” refers only to individuals that the organization reported (or should have reported) in any of the above- mentioned categories in one or more of its information returns for the previous 5 years.

For each person listed in section A, the organization must include his or her reportable compensation. The reportable compensation of officers and other employees is generally the amount reported in box 5 of Form W-2.  The reportable compensation of directors and trustees is generally the amount reported in box 7 of Form 1099-MISC.

All organizations are required to report compensation for the calendar year ending with or within their fiscal year and should use amounts reported on Form W-2 or Form 1099-MISC for that calendar year. In addition, organizations must report an estimate of other compensation, including deferred compensation not currently reportable on Form W-2 or Form 1099- MISC and nontaxable benefits such as health benefits, retirement plan benefits, and other nontaxable fringe benefits, but excluding certain working condition and fringe benefits.

The instructions to Part VII include a table that explains whether to report and where to report items of compensation and benefits in Part VII, section A, and Schedule J.

Part VII, Section B requires organizations to list the five highest compensated independent contractors that received more than $100,000 in compensation from the organization for services during the calendar year ending with or within the tax year, whether or not the organizations issue Forms 1099 to those contractors. Section B also requires descriptions of the services provided and listing of the amounts paid to each contractor. “Independent contractors” can be corporations or other entities as well as individuals who are not employees, and include management companies, lawyers, accountants, and professional fundraisers that provide services to the organization.

Step Six: Part XI & XII – Reconciliation of Net Assets ,Financial Statements & Reporting (Form 990 Page 11)

Part XI is a new section added that asks filers to reconcile their beginning-of-year and end-of-year net assets.

Part XII is short and straightforward.  Its primary purpose is to capture the organization’s financial oversight process. Specifically, it asks the organization to disclose the extent to which it used an independent accountant for compilation, review, or audit of its financial statements.

An organization with substantial assets or revenue should consider obtaining an audit of its financial statements by an independent auditor. It should also consider establishing an independent audit committee to select the independent auditor and review its performance.

Step Seven: Schedule L, Transactions with Interested Persons

Read the instructions to Schedule L, Transactions with Interested Persons, and complete some or all parts of the schedule to the extent required.

Transactions reportable on Schedule L include:

• Excess benefit transactions involving a 501c3 or 501c4 organization and a disqualified person
• Loans that any type of filing organization makes to, or receives from, an “interested person” (which includes a current and former directors, officers, trustees, key employees, and highest compensated employees)
• Grants or similar economic assistance provided by an organization to any interested person
• Direct and indirect business transactions between an organization and any interested person (which includes current and former officers, directors, trustees, key employees, their family members, and entities they own or control) during the tax year

If any member of the organization’s governing body was involved in a financial transaction that should be reported, complete Schedule L before you start on Part VI of the core form. At a minimum, you will need to know the number of governing body members involved in transactions reportable on Schedule L so you can answer line 1b of Part VI regarding independence of governing body members.

Step Eight: Part VI – Governance, Management and Disclosure Overview

The questions in Part VI reflect the IRS’s interest in learning about the governance policies and practices of exempt organizations. The IRS believes an organization with an articulated mission, a knowledgeable and dedicated governing body and management team, and sound managerial and financial practices is best equipped to comply with the tax laws, safeguard its assets, and succeed in its mission.

Because Form 990 is one of the principal vehicles by which the IRS and the public learn about the organization and its activities, the governing body of the organization should consider reviewing the organization’s Form 990 before it is filed.

Part VI is divided into three sections, which capture the organization’s management structure, policies, and disclosure practices.

Section A concerns the governing body – the group of persons authorized under state law to exercise ultimate control of the organization.  The governing body of a corporation or association is its board of directors; the governing body of a trust is its trustees. Directors are encouraged to actively oversee the management of their organization, stay informed about its activities and financial status, and avoid actions or situations that are incompatible with an obligation to act solely in the best interests of the organization.

Line 1 asks for the number of voting members on the governing body of the organization (e.g., director, trustee). It then asks how many voting members are independent.  “Independent” means the director:

• Was not compensated as an officer or employee of the organization or of a related organization;
• Did not receive total compensation or other payments exceeding $10,000 from the organization and related organizations as an independent contractor, other than reasonable compensation for services provided in his or her capacity as a director; and
• Was not involved (nor were any of the director’s family members involved) in a transaction with the organization or a related organization that is reportable on Schedule L (or would be reportable on Schedule L if filed by the related organization).

No matter the size, a governing board generally should not be dominated by individuals with family or business relationships. Independent board members are important because their presence increases the likelihood that decisions will be made in the best interests of the organization and the community it serves, rather than the best interests of the individuals on the board.

To summarize, a member is considered independent if he or she:

• Is not compensated as an employee/officer of the organization;
• Has total compensation of $10,000 or less as an independent contractor of the organization; and
• Was not involved in a Schedule L-reportable transaction with the organization or a related

Other questions in Section A inquire about business and family relationships between and among the organization’s officers, directors, trustees, and key employees, whether and what control is exercised over the organization by governing members, and whether the organization contemporaneously documented its board and committee meetings and actions.

An important part of governance is transparency, which includes nonprofit public disclosure of internal fraud or criminal activity. Line 5 asks if, during the reporting year, the organization became aware of a significant diversion of its assets, such as by fraud or embezzlement, whether such diversion occurred during the year or earlier. A diversion is considered material if the gross value of all diversions (not taking into account restitution, insurance, or similar recoveries) discovered during the organization’s tax year exceeds the lesser of:

• 5 percent of the organization’s gross receipts for its tax year,
• 5 percent of the organization’s total assets as of the end of its tax year, or
• $250,000.

The questions in Section B ask whether the organization has adopted certain governance policies or procedures, such as a conflicts of interest policy, a whistle blower policy, a document retention and destruction policy, a joint venture policy, and a process for determining executive compensation. While the adoption of such policies is not mandated, the IRS nevertheless encourages exempt organizations to consider the merits of implementing these or similar policies and procedures to promote compliance with federal tax-exempt law and to minimize the risk of non-compliance.

Section C involves organizational disclosure.  More specifically, it asks organizations to explain what information they make available to the public and how they make it available.

An exempt organization is required to make a copy of its exemption application (Form 1023 or 1024) and its three most recent Form 990-series returns available for public inspection during normal business hours at its principal office and at its regional or district offices, and to provide copies of such forms upon request or make them publicly available (e.g., on the organization’s website).

Organizations are encouraged to establish procedures to ensure such forms are made available to the public upon request.

Step Nine: Parts I and IV. Part I – Summary

Although the summary is located at the beginning of the form, it should be one of the last pieces of the core form that you complete because it requires you to provide key financial, governance, and operational information from other parts of the form as well as from the prior tax year.

Complete Part IV, Checklist of Required Schedules, to determine which schedules or parts of schedules you need to complete.

Step Ten & Eleven: Schedules and Signature

Complete Part II of Form 990, Signature Block.

Form 990 Schedules Instructions

Form 990  Schedule A – Public Charity Status and Public Support

What? Schedule A collects information about an organization’s public charity status and public support.

Who? If you are a section 501c3 organization and you file a Form 990 or Form 990-EZ, you must also file a Schedule A. Non-501c3 organizations should not file Schedule A.

How? Schedule A contains two separate support schedules:

• The support schedule in Part II is used to compute the public support of charities under sections 509(a)(1) and 170(b)(1)(A)(vi).
• The support schedule in Part III is used to compute the public support of charities under section 509(a)(2).

Both support schedules feature a 5-year testing period, which includes the current tax year.

In completing Schedule A, you must use the same accounting method you used to complete the core form (e.g., the method you checked in Part XII, line 1 of the core form, whether cash or accrual).

Form 990 Schedule B – Schedule of Contributors

What?  Schedule B provides information on certain contributors of contributions the organization reported on line 1 of Form 990, Part VIII or Form 990-EZ, Part I.

Who? All organizations must attach a completed Schedule B to their Form 990 or 990-EZ unless they certify that they do not meet the filing requirements of Schedule B by checking the “No” box on Form 990, Part IV, line 2 or Box H in the heading of Form 990-EZ.

An organization is required to file Schedule B if it is:

• A section 501c3 organization that met the 33 ? percent support test under sections 509(a)(1) and 170(b)(1)(A)(vi) and received one or more contributions that exceeded the greater of $5,000 or 2 percent of the amount on line 1h of Form 990, Part VIII from any one contributor;
• A section 501c3 organization that did not meet the 33 ? percent support test under sections 509(a)(1) and 170(b)(1)(A)(vi) and received one or more contributions of $5,000 or more from any one contributor;
• A section 501(c)(7), (8), or (10) organization that received during the tax year
  1. contributions of any amount for use exclusively for religious, charitable, literary, or educational purposes, or for prevention of cruelty to children or animals, or
  2. contributions of $5,000 or more not exclusively for such purposes from any one contributor; or
• Any other organization that received, during the year, a contribution of $5,000 or more from any one contributor.

How?  Part I asks for the name and address of the contributor, the aggregate amount of the contribution, and the type of contribution. Non-cash contributions must be described, and a fair market value stated, in Part II.

Except for section 527 political organizations, an organization may elect not to disclose the names and addresses of contributors listed on Schedule B when making its Form 990 available for public inspection.

Note: “Contributor” includes individuals, fiduciaries, partnerships, corporations, associations, trusts, tax-exempt organizations, and government units.

Form 990 Schedule D – Supplemental Financial Statements

Schedule D is a collection of financial statements to supplement the financial reporting on Part X of the core form, including reporting of donor advised funds, conservation easements, escrow accounts, endowment funds, and art and museum collections. Other information on Schedule D had previously been solicited as statements whose layouts were left largely to the discretion of each filer. Schedule D places these statements in a single schedule and gives each a consistent format.

Form 990 Schedule M – Non-Cash Contributions

Schedule M is devoted exclusively to the reporting of non-cash contributions. It must be completed by any organization that reported more than $25,000 of aggregate non-cash contributions during the year in Part VIII, line 1g of the core form, or that received contributions of art, historical treasures, or qualified conservation contributions.  Schedule M requires reporting of all non-cash contributions, not just charitable contributions deductible under section 170 of the Code, made to any tax organizations required to file Schedule M, not just those organizations eligible to receive tax-deductible contributions.

Note that Schedule M reports the types of non-cash contributions received during the year.  There are 24 different types of property listed on separate lines in Part I of the schedule with four additional lines to add types that are not specifically listed in lines 1-24.

NOTE: If you’d like to receive the following organizing documents:

• Nonprofit Articles of Incorporation,
• Nonprofit Bylaws,
• Nonprofit Conflict of Interest Policy,
• Conflict of Interest Policy Acknowledgment,
• Form 1023 Attachment with all the answers,
• Form 1023 Expedite Letter template,
• and Donor Contribution Form

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