Annual Electronic Filing Requirement for Small Exempt Organizations — Form 990-N

Most small tax-exempt organizations whose annual gross receipts are normally $50,000 or less are required to electronically submit Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required to File Form 990 or Form 990EZ.

  • Form 990-N must be completed and filed electronically. There is no paper form.
  • Form 990-N filers may choose to file a complete Form 990 or Form 990-EZ instead


Form 990-N filing due date

Form 990-N is due every year by the 15th day of the 5th month after the close of your tax yearYou cannot file the e-Postcard until after your tax year ends.

Example: If your tax year ended on December 31, the e-Postcard is due May 15 of the following year. If the due date falls on a Saturday, Sunday, or legal holiday, the due date is the next business day.

Filing Form 990-N Late

If your 990-N is late, the IRS will send a reminder notice to the last address we received.

While there is no penalty assessment for filing Form 990-N late, organizations that fail to file required Forms 990, 990-EZ or 990-N for three consecutive years will automatically lose their tax-exempt status. Revocation of the organization’s tax-exempt status will happen on the filing due date of the third consecutively-missed year. Watch this IRS YouTube presentation for more information


How to file form 990-N

To file 990-N on or before February 28, 2016:
The Urban Institute will continue to host Form 990-N at until February 28, 2016. If you file your organization’s tax-year 2015 990-N on or before February 28, 2016, you won’t be required to register for the new Form 990 submission process at until you file your tax-year 2016 Form 990-N in 2017.

To file 990-N on or after February 29, 2016:
The IRS will begin hosting Form 990-N on February 29, 2016. All form 990-N users (including users previously registered with Urban Institute) who file after February 28, 2016, will be required to register before completing the 990-N.

Register to File Form 990-N

This is a one-time registration. You won’t need to register each year.

In the unlikely event that technical issues delay implementation of the new Form 990-N submission process, systems are in place to prevent organizations from being penalized if their filing due dates occur before the system is in place. To avoid this, please consider filing your 2015 return prior to February 29.


Who must file Form 990-N

Most small tax-exempt organizations with gross receipts that are normally $50,000 or less must file the e-Postcard (see Who Must File FAQs). Exceptions to this requirement include:


Social Clubs and 501(c)7 Tax Exempt Status

What are Social Clubs under IRS Rules?

Social clubs are organized to provide pleasure or recreation to your members. Many different types of organizations may fall into this category. Typical examples include country clubs, college fraternities and sorority, dinner clubs, hobby clubs, golf and tennis clubs, swimming clubs, and amateur sport clubs. But that by no means is a complete list. A social club can be focused on just about any non-business recreation or social activity that a group of people might get together to enjoy. Social clubs that meet requirements are exempt from federal income tax under Section 501c(7) of Internal Revenue Code.


What are the Benefits of Social Club Status?

A social club that is exempt under Section 501c(7) generally does not pay tax on dues, fees, charges, or similar amounts that it’s members pay for the goods, facilities, or services that the club provides to the members and their family and guests. In the lingo of the tax code, this is called exempt function income. We’ll talk about it in more detail later. In this way, 501c(7)s are similar to other types of tax-exempt organizations.


What is Considered a Social Club by IRS?

They generally are not taxed on the income they generate that is substantially related to furthering their exempt purpose. For instance, a tax-exempt 501c(3) school generally is not taxed on the tuition its students pay. On the other hand, social clubs generally are taxed on all of their other income, called unrelated business taxable income, or UBTI. Generally, UBTI is income derived from outside the club membership, including amounts that non-members pay for the club’s services or facilities and from investment income, also called passive income. The tax on investment income is perhaps the most significant difference between the tax treatment of tax exempt social clubs and most other tax exempt organizations. Those other types of organizations generally are not taxed on their investment income. So the tax benefits granted to c(7)s are more limited than the tax benefits for most other types of tax-exempt organizations


How to maintain IRS Social Club Status?

The requirements for an organization to obtain and maintain exempt status under Section 501c(7) are; one, it must be a club; two, it must be organized for pleasure, recreation, or other non-profitable purposes;three, substantially all of its activities must be for such purposes; four, no part of it or net earnings can enure to the benefit of any private shareholder; and, five, it can’t have a written policy which discriminates against individuals seeking membership on the basis of race, color, or religion. Let’s talk about each of these five requirements in a little more detail. At the outset, though, I want to mention that, in particular the third factor, that substantially all of the social club’s activities must be for its exempt purpose of providing recreation or pleasure to its members may be of the most interest to you all today. But first, the first requirement is that the organization must be a club. That might sound obvious, but it’s worth talking about the characteristics of a club, because they help explain why some organizations do or do not qualify for c(7) status. In particular, you’ll see that this requirement helps us at the IRS to distinguish a c(7) organization from a regular commercial operation doing business with the public, which is not eligible for tax exempt status.


Keeping IRS Social Club Status

It is a requirement that substantially all of the c(7)’s activities must be for exempt recreational pleasure or similar non-profit purposes. That means that substantially all the c(7) income must be from member fees, dues, assessment, or other payments for the traditional social activities or facility that the organization provides to its members. Another way to put this is that this requirement limits the amount of income a c(7) can earn from non-membership sources, including investment income.

Well traditional activity are those that are engaged with a member which further exempts purpose of the organization to provide pleasure, recreation, or other non-profit purposes. For example, a golf club income from green fees will be a traditional income, as with member payment for meals in a dining room of the social club or country club. Investment income is also treated as traditional income for this purpose, and so it is measured on the 35/15 test and not the more restricted standard. Non-traditional activities are those that will not further these purposes, even if conducted with members. For example, the sale of packaged liquors and food for takeout are not traditional activities.


Filing Tax Return as s Social Club?

A social club can file form 1024 to obtain the IRS’s recognition of the club status as a tax exempt 501c(7) organization. The club can show on the form 1024 how it is organized and how it is or will be operated so that it meets the five requirements for exemption; that it is a club organized for recreational, social, or similar purpose; substantially all the activities of which further its exempt purposes; that there is no inurement; and that it does not have a written discriminatory policy. If we determine the club meets the five requirements based on the form 1024, we’ll issue the club a determination letter confirming that we recognize the club as exempt under Section 501c(7). A club that gets a determination letter from the IRS after filing a form 1024 has the benefit of assurance from the IRS that as long as the club is organized and operated as described in the form 1024 application it is exempt.

Social Club IRS Exempt Status

However, a social club is not required to seek recognition of its exempt status from the IRS. A club that believes it meets the five requirements can take the position that it is tax exempt and operate as such, without receiving recognition of its status from the IRS. But the club still must file the annual returns required of a 501c(7) organization, which we will talk about momentarily. Additionally, and perhaps more importantly, the club will not have any assurance or comfort that the IRS agrees that the club is tax exempt under Section 501c(7). As a practical matter, this means that even though a club may operate and file returns for several years, claiming that it owes no tax, the IRS could examine the organization and determine that it did not meet the organizational and operational requirements for its past years.The club would then not only be prevented from claiming tax exempt status going forward but could be revoked for past years, and, therefore, owe tax on its income for those prior years.



IRS Form 990 Tax Exempt Organizations

As you probably know, the Form 990 is the information return that most large tax exempt organizations file with the IRS each year. There are variations such as the Form 990-PF for private foundations; the short form, 990-EZ for mid-size organizations; and the Form 990-N e-Postcard for smaller organizations.

This article uses terms like Form 990-series return for the Forms 990, 990-EZ, 990-N e-Postcard, and the Form 990-PF. However, when we say Form 990, we’re talking specifically about the Form 990 that must be filed by charitable organizations to be entitled to certain exempt organization tax benefits.


What is Form 990?

Unlike most IRS forms, Form 990-series returns are not tax forms. Their primary purpose is not to report financial information. Instead, the forms provide the IRS and the public with information about an organization’s programs, activities, relationships, transactions and governance, in addition to revenues, expenses and assets.


How do exempt organizations use form 990?

The IRS uses Form 990 returns to administer the tax laws and to ensure that exempt organizations abide by those laws. And because Form 990 is a publicly disclosable document, it’s also the public’s window into an organization’s operations. A properly completed and filed Form 990-series return will meet the filing obligations of the organization and show the IRS and the public that the organization is organized and operated as a tax-exempt entity – that it is in compliance with applicable tax laws; that it’s well governed and managed; that it furthers its mission through its exempt activities; and that it provides valuable services to the public.


Who Must File Form 990?

As you already know, certain types of organizations don’t have to file a Form 990-series return. These include churches, associations of churches, and integrated auxiliaries of churches. I repeat churches do not have to file the Form 990, 990-EZ or 990-N. However, they must file 990-T to report unrelated business income if they have more than $1,000 of gross unrelated business income in any taxable year.

There are also a few other exceptions to filing Form 990, mostly for governmental entities and political organizations. If you’re interested, Publication 557, Tax-exempt Status of Your Organization and the Form 990 and 990-EZ instructions list all of the exceptions.

New Organizations and Form 990

Newly formed organizations that don’t meet any of these exceptions are required to file a Form 990-series return, even if they haven’t yet applied for or received recognition of exemption from the IRS. It’s not enough that the organization claims to be exempt from taxation. You may be required to file a Form 990-series return.

If an organization has filed, or plans to file a Form 1023, but is not yet recognized by the IRS as tax exempt, then it should check the “application pending” box on page one of the Form 990 or Form 990-EZ.


501(c)(3) and Form 990

The annual information return an organization is required to file is determined by either its public charity status or its financial activity. For example, if an organization is exempt under 501(c)(3) and classified as a private foundation, it will file the Form 990-PF.

If a 501(c)(3) meets a public support test over a five-year period, it will qualify as public charity rather than private foundation, so it will complete one of the other Form 990- series returns, not the PF. If a 501(c)(3) organization doesn’t know whether it meets the public support test, then it should fill out Form 990, Schedule A, before going any further. In general, it meets the test if it has many contributors and/or other sources of support.


Form 990-EZ and the Form 990-N

Form 990-EZ is the annual information return that most mid-sized taxexempt organizations may file instead of the Form 990. The Form 990-EZ is kind of like the little cousin of the Form 990.

Form 990-N, the e-Postcard, is the newest member of the Form 990-series and it comes to us courtesy of the Pension Protection Act of 2006.

You’ll save a lot of time and aggravation if you delegate preparation of sections of the Form 990 to those with specific knowledge about the organization’s operations that a particular part of the form is asking about.


Filing Form 990

Before you file your Form 990, if you’re doing this in paper, you’ll want to assemble the package of forms and schedules and attachments in the following order. You’ll put the core form with all parts completed, parts one through 12 that will go first. Then the schedules that you completed as applicable – and you’ll file those in alphabetical order. Then you’ll attach any attachments that you’ve completed.

Many have asked why these schedules are necessary. The IRS believes that there’s a close link between good governance and tax compliance. Organizations that adopt and implement sound risk management policies greatly improve their ability to be tax compliant. Conversely, most violations of tax-exempt law that we have seen in examinations have resulted, in part, from failure to exercise good governance.


Unrelated business income, or UBI for Non-Profits

Organizations may have to report and pay tax on UBI. If UBI activities become a substantial part of an organization’s activities, it might jeopardize the organization’s exempt status.

So what is UBI? Well, there’s a three-part test. It is income from a trade or business that is regularly carried on and not substantially related to the organization’s exempt purpose. The first part of the test is that the activity must be a trade or business. An activity does not lose its identity as a trade or business merely because it is carried on within a larger group of similar activities that may be related to the organization’s exempt purpose.

For example, the regular sale of pharmaceutical supplies to the general public by a hospital pharmacy is a trade or business. However, sales to the hospital and patients are related, and therefore, not UBI. Likewise, a hospital cafeteria operated for the convenience of the hospital’s employees, patients, and the patients’ visitors is a related activity and also not UBI.


Business Activity of an Exempt Organization

The second part of the test is that the trade or business must be regularly carried on. A business activity of an exempt organization is generally considered to be regularly carried on if it shows a frequency and continuity that is conducted in a way generally similar to comparable businesses of non-exempt organizations. For example, a hospital auxiliary’s operation of a sandwich stand for a week at a state fair would likely not be regular conduct of a trade or business; however, operation of the sandwich stand daily at the hospital and open to the public would be considered regular conduct of a trade or business.


What is IRS Form 1099-G?

Form 1099-G is an information return that is used by federal, state and local government entities to report certain payments. You’re required to file and furnish Form 1099-G if you made the following types of payments: unemployment compensation; state or local income tax refunds, credits or offsets; ATAA and/or RTAA payments; taxable grants; agricultural payments; and you must also file this form if you received payments on a commodity credit corporation or CCC loan. More details on the types of payments reportable can be found in the instructions for Form 1099-G, also available via


What is 1099-G Furnishing Requirement?

In general the furnishing requirement is met by providing the recipient or payee with a paper copy of Form 1099-G by January 31 of the year following the year of payment. You must also file a copy of the 1099-G with the IRS before February 28, unless you file electronically, which allows for a due date of April 1 of the same year. The Internal Revenue Code and regulations allow for most information returns to be furnished electronically.


Allowable Returns and 1099-G

A complete list of allowable returns is found on pages 30 and 31 of the Pub 1179, again under Section 4.6, Electronic Delivery of Recipient Statements. The most common returns used by FSLG entities are the Form 1099-G for certain government payments; Form 1099-INT for interest income; Form 1099-MIS, miscellaneous income; the Form 1099-R, distributions from pensions, annuities, retirement or profit sharing plans, IRAs, insurance contracts, etc. – I know that’s a long title; Form 1098-E for student loan interest statements; Form 1098-T for tuition statements; and lastly, Form W-2G, for certain gambling winnings.


Why migrate to furnishing Form 1099-G electronically?

There are quite a few advantages to it. Your entity may recognize significant cost benefits that result when paper and printing costs are reduced, mailing processes and fees are reduced if not eliminated, paper handling costs from filing, sorting, storing and shredding are reduced; eliminating re-typing and/or editing of documents reduces costs; and finally, accessibility is a factor. Distribution via secure web access and email is usually most cost-effective and convenient.


After Filing 1099-G

Once your organization commits to electronically furnished 1099-G, how must it be done? We would like to take this opportunity to review the requirements for setting up a system for furnishing 1099-G electronically. In general, the entity will request affirmative consent, receive and document the consent, provide required notifications, and furnish statements to consenting payees electronically

Section 401 of the Jobs Creation and Worker Assistance Act of 2002 established that, in order to use electronic deliveries and information returns to payees, the payer must obtain an affirmative consent from each recipient to whom a statement will be furnished electronically. The consent must be made by the recipient electronically in a way that confirms that the recipient can access the statement in the same electronic format in which it will be furnished. For example, if the Form 1099-G will be delivered as a portable document format, or PDF file, then the affirmative consent document format should also be in PDF. In addition, the payer must make certain notifications to each consenting individual.


Form 1099-G Deadlines

The government entity must place electronically posted Forms 1099-G on the applicable web site by January 31, the due date, and the statement must remain available until at least October 15 of that year. When Forms 1099-G are posted, the issuing entity must notify the consenting payees, either electronically or by mail. For payees who do not provide consent, or who withdraw their consent to receive the Form 1099-G electronically before the statement is furnished, the payer must provide a paper payee statement within the regular deadline. And again, that would be January 31 for the Form 1099-G. As a payer, you should have a record of the payee consent for every statement that you furnish electronically. If you fail to furnish the information in the required manner, this could result in the payee neglecting to report the income on their individual federal, state or local income tax returns. And this could subject them to enforcement actions, including penalties and possibly interest, by multiple government taxing authorities on any taxes that were due and owing. The affirmative consent requirement ensures that each payee will either receive the statement on paper, or agrees to the electronic delivery.

Now here are a few reminders. One, the recipient must not have withdrawn the consent before the statement is furnished. Two, if the recipient subsequently withdraws his or her consent, your system must notify you and a paper reporting requirement must be resumed. You must provide a paper payee statement within the regular deadline, and again that of course is January 31 for Form 1099-Gs. Three, remember, a new consent to receive the statement electronically is required after any new hardware or new software is put into service. And four, all electronic statements must be in a format that conforms to the requirements as stated in Publication 1179.



Additional board member Compensation allowances

Is reimbursing members for their mileage to board and/or committee meetings taxable if held on-site?

The answer is that commuting is defined as travel between home and work and is considered an employee’s personal expense. And therefore If the government entity reimburses a board member for commuting, that reimbursement is taxable to the board member and subject to employment taxes.  What if the government employee takes someone with them on a business trip?  What, if any, tax impact would that have?


What is not a taxable Fringe Benefit?

Any money paid or incurred with respect to a spouse, dependent, or other individual accompanying an employee on business travel is considered a taxable fringe benefit.  However, there are some exceptions.


What is not a Taxable Fringe Benefit?

It is not a taxable fringe benefit if:

  • The accompanying individual is an employee of the employer,
  • The travel of the accompanying individual is for a valid business purpose, or
  • The travel expenses otherwise would be deductible by the accompanying individual

The term other individual does not include a business associate with valid travel expenses that otherwise would be a valid business expense.

The expenses must also meet the normal rules for travel expenses.  That means that there must be a real business purpose for the individual’s presence.  Based on court decisions, the presence of the spouse or other traveling companion on a trip must be necessary, not merely helpful, to establish the requisite business purpose.

You can find more travel reimbursement information on the FSLG website at


FICA Replacement Plans and Government Employees

Before we discuss FICA Replacement Plans, it may be helpful to discuss the ways in which a government employer and their employees do participate in Social Security and/or Medicare.


What is a Government Employer for FICA?

A government employer (when serving as the “Common Law” employer), is responsible for the appropriate social security and/or Medicare coverage.  Such coverage of the Government entities’ current and/or future employees, under the Federal Insurance Contributions Act (FICA), social security and/or Medicare, is determined in three ways:

  1. Full FICA coverage, social security and Medicare, is extended through a voluntary plan and agreement through your State Social Security Administrator.  These agreements are commonly referred to as “Section 218” agreements. [Section 218 of the Social Security Act (Act)].
  2. For employment services performed after July 1, 1991, full FICA coverage, social security and Medicare, is a requirement for employees whose services are not covered under a Section 218 agreement or by a qualified, employer’s retirement system. This coverage is commonly referred to as “mandatory FICA”.
  3. Medicare only coverage is a requirement for political subdivision employees whose services are not covered for social security under a Section 218 agreement or under mandatory FICA, but who were hired after March 31, 1986.  This coverage constitutes Medicare qualified government employment.

First question on the flow chart: Is this position or service covered for Social Security and Medicare under a Section 218 Agreement?  If yes you withhold Social Security and Medicare, unless there is a position that is excluded within the Section 218 Agreement.

If the answer is No, then you have to ask the question “is the employee a qualified member of a public retirement system?’ (We will take a more in depth look at what a qualified member means later in this phone forum).  If the employee is not a qualified member of a public retirement system then you withhold Mandatory Social Security and Medicare, unless some exclusion applies.


Qualified member of a public retirement system

If the answer is yes the employee is a qualified member of a public retirement system, then you have to determine if the employee is in a position that is covered by a Section 218 Agreement that provides Medicare-only coverage for employees hired prior to April 1, 1986.  If the employee is a qualified member of a public retirement system and is covered for Medicare by a Section 218 Agreement then you would withhold Medicare for that employee unless an exclusion applies.  However you would not withhold Social Security in this instance.

If in this instance there is no Section 218 Agreement for Medicare-Only, then would the Medicare Continuing Employment exception apply?  If yes, then no Social Security or Medicare is withheld.  If the continuing employment exception does not apply, then you withhold Medicare only for all hires after March 31, 1986.


What are IRS 501(c)(4) Organizations?

Nonprofit status is a state law concept. An organization usually becomes a nonprofit under state law by filing organizing documents with the state, such as Articles of Incorporation, which indicate the organization is formed under the state’s Nonprofit Corporation Act. Nonprofit status may make an organization eligible for certain benefits, such as exemption from property, income and state sales tax. This is on the State level and filing requirements and benefits vary state by state.


What are IRS 501(c)(4) Organizations?

Section 501(c)(4) organizations include civic leagues, social welfare organizations and local associations of employees. A social welfare organization, under 501(c)(4), must be organized exclusively for the promotion of social welfare. A 501(c)(4) organization operates primarily to further the common good and general welfare of people of the community, such as by bringing about civic betterment and social improvements. In this group — this includes groups formed to educate and inform the public about particular issues. Some more examples of section 501(c)(4)s include volunteer fire companies, civic leagues and community associations. And we also do want to point out that option 501(c)(4)s conduct activities that are very similar to those of 501(c)(3) organizations, however, 501(c)(4)s are not constrained by many of the restrictions and prohibitions placed on (c)(3)s


Applying for 501(c)(4) Status

Organizations applying for exemption under 501(c)(4) use Form 1024, called Application for Recognition of Exemption under section 501(a). Form 1024 is also used to apply for recognition of exemption under 501(c)(5), (c)(6), and the rest of the sections we discussed today.


More IRS Information on 501(c)(4) Organizations

The promotion of social welfare does not include direct or indirect participation or intervention in political campaigns on behalf of or in opposition to any candidate for public office. However, a section 501(c)(4) social welfare organization may engage in some political activities, so long as that is not its primary activity. However, any expenditure it makes for political activities may be subject to tax under section 527(f). For further information regarding political and lobbying activities of section 501(c) organizations, see Election Year IssuesPolitical Campaign and Lobbying Activities of IRC 501(c)(4), (c)(5), and (c)(6) Organizations, and Revenue Ruling 2004-6.


Examples of exempt as social welfare organizations

Homeowners associations and volunteer fire companies may be recognized as exempt as social welfare organizations if they meet the requirements for exemption. Organizations that engage in substantial lobbying activities sometimes also are classified as social welfare organizations.

Information about Schedule K (Form 990)

Schedule K is used by 501(c)(3) organizations to report on their tax exempt obligations. The Internal Revenue Code permits tax exemption for the interest paid on qualified 501(c)(3) bonds as long as the bonds also meet the other requirements in the code applicable to this type bond.


Filing Form 990

Under Section 6033 of the Internal Revenue Code, organizations described in Section 501(a) are required to file an annual information return unless specifically exempted. 501(a) refers to organizations that are tax-exempt under Section 501(c) and to religious and apostolic organizations that are tax exempt under Section 501(d). Section 501(c) of course covers a wide variety of non-profit organizations including charitable organizations exempt under Section 501(c)(3). Under the statute, certain organizations are exempt from the filing requirements of Section 6033 including churches, conventions or associations of churches and certain governmental entities.


How to Fill out Form 990

There are four different forms in the 990 series. The Form 990, the short Form 990-EZ and Form 990-PF which I’ll refer to as Form 990 series returns. Also, there’s a Form 990-N also known as an e-postcard, which is an annual electronically filed notice, not a return. An organization that’s eligible to submit the e-postcard and voluntarily file a Form 990-EZ or 990 instead and an organization eligible to file the Form 990-EZ may voluntarily file the full Form 990. Private foundations must use Form 990-PF. Only Form 990 contains Schedule K which is the main topic of this presentation. If an organization is not required to file Form 990, for example if the organization could file Form 990-EZ or submitted 990-N, but it chooses to file Form 990 then it must file a complete return and include all required schedules, including Schedule K if applicable.


Penalties for Not Filing Form 990

There are monetary penalties for non-filing, late filing, and incomplete filing of Form 990 and Form 990-EZ. These penalties apply against the organization and, in certain cases, against responsible individuals. More importantly, under Section 6033-j if an organization fails to file an annual Form 990 series return or submit a Form 990-N e-postcard notice for three consecutive years, its tax-exempt status is automatically revoked. The automatic revocation of exemption is effective as of the due date of the third required annual filing or notice. If an organization’s exemption is automatically revoked, it appears on the auto-revocation list on  If the organization was previously recognized as exempt under 501(c)(3) of the Code, it is no longer eligible to receive tax-deductible contributions under code Section 170.


Organizations Losing Tax Exempt Status and Form 990

Organizations that lose their tax exempt status may need to file income tax returns and pay income tax. They may apply for reinstatement of exemption, usually by reapplying for exemption using Form 1023 for 501(c)(3) organizations or Form 1024 for other entities exempt under 501(a). If granted, the exemption will normally be retroactive to the date of application for reinstatement, not to the effective date of auto-revocation unless the organization establishes reasonable cause for failing to file the Form 990 series return, for not just one, but for three consecutive years. For additional information, go to the IRS website pages for exempt organizations at On the first page is a link to pages dealing with auto-revocation. By following the links to frequently asked questions about auto-revocation, you can find information on the potential impact of auto-revocation on an organization’s tax-exempt bonds.


Different Parts of Form 990

The Form 990 has 12 parts, including the signature block, plus 16 schedules to be completed by specific types of organizations with specific types of activities. The schedules are designated as schedules A through O plus R. In the core form, the reporting entity addresses program service accomplishments, governance, compensation to management and key employees, revenue, functional expenses, balance sheet items, and other IRS filings and tax compliance, such as appropriate backup withholding, filing of employment returns, and payment of unrelated business income tax. Part IV of the core Form 990 includes trigger questions for separate schedules. For example, schools are directed to complete Schedule E. Entities operating hospitals must complete Schedule H. Before we finish discussing the core Form 990, I want to take this opportunity to emphasize one thing. Under Section 6104 of the Code, the information on Form 990, 990-EZ and 990-PF must be made available to the public upon request, both by the IRS and by organizations that file one of these Form 990 series returns.


Public Inspecting Form 990 of Organizations

Members of the public also have the right to inspect the 990 series return at the location of the organization. So, it’s very important that the return not contain any social security numbers in this era of increased identity theft. 990 series returns do not require reporting of any social security numbers. This concludes my overview of the core Form 990. You can find additional information, including the detailed instructions for Form 990, on the Internal Revenue Service website,, under information for charities and non-profits