Part VI requests information regarding an organization’s

governing body and management, governance policies, and disclosure practices. Although federal tax law generally doesn’t mandate particular management structures, operational policies, or administrative practices, every organization is required to answer each question in Part VI. For example, all organizations must answer lines 11a and 11b, which ask about the organization’s process, if any, it uses to review Form 990, even though the governing body isn’t required by federal tax law to review Form 990.

Even though the information on policies and procedures requested in Section B generally isn’t required under the Code, the IRS considers such policies and procedures to generally improve tax compliance. The absence of appropriate policies and procedures can lead to opportunities for excess benefit transactions, inurement, operation for nonexempt purposes, or other activities inconsistent with exempt status. Whether a particular policy, procedure, or practice should be adopted by an organization depends on the organization’s size, type, and culture. Accordingly, it is important that each organization consider the governance policies and practices that are most appropriate for that organization in assuring sound operations and compliance with tax law. For more governance information relating to charities, go to IRS.gov/Charities and click on Lifecycle of an exempt organization .

Section A. Governing Body and Management

Line 1a. The governing body is 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 ”).

Enter the number, as of the end of the organization’s tax year, of members of the governing body of the organization with power to vote on all matters that come before the governing body (other than when a conflict of interest disqualifies the member from voting). If members of the governing body don’t all have the same voting rights, explain material differences on Schedule O (Form 990).

If the organization’s governing body or governing documents delegated authority to act on its behalf to an executive committee or similar committee with broad authority to act on behalf of the governing body, and the committee held such authority at any time during the organization’s tax year, describe on Schedule O (Form 990) the composition of the committee, whether any of the committee’s members aren’t on the governing body, and the scope of the committee’s authority. The organization need not describe on Schedule O (Form 990)

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delegations of authority that are limited in scope to particular areas or matters, such as delegations to an audit committee, investment committee, or compensation committee of the governing body.

Example. A voluntary employees’ beneficiary association (VEBA) is a trust under state law. Bank B is the sole trustee of the trust. In completing line 1a, the VEBA will report one voting member of the governing body.

Line 1b. Enter the number of independent voting members of the governing body as of the end of the organization’s tax year. A member of the governing body is considered “independent” only if all four of the following 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)) except as provided in the religious exception discussed below. Nor was the member compensated by an unrelated organization or individual for services provided to the filing organization or to a related organization, if such compensation is required to be reported in Part VII, Section A.

2. The member didn’t receive total compensation exceeding $10,000 during the organization’s tax year (including a short year, regardless of whether such compensation is reported in Part VII) from the organization and 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 she or he also receives 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) that is required to be reported on Schedule L (Form

990. 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 (whether directly or indirectly through affiliation with another organization) of a type and amount that would be reportable on Schedule L (Form 990) if required to be filed by the related organization.

Note: The independence standard for purposes of Part VI isn’t the same as the “absence of conflict of interest” standard for purposes of the rebuttable presumption under Regulations section 53.4958-6, which focuses on conflicts with respect to a particular transaction.

A member of the governing body isn’t considered to lack independence merely because of the following circumstances.

1. The member is a donor to the organization, regardless of the amount of the contribution.

2. Religious exception: 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 (see Rev. Rul. 77-290, 1977-2 C.B. 26; and Rev. Rul. 80-332, 1980-2 C.B. 34); or (b) belongs to a religious order that receives sponsorship or payments from the organization or a related 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.

Example 1. B is a voting member of the organization’s board of directors. B is also a partner with a profits and capital interest greater than 35% in a law firm, C, that charged $120,000 to the organization for legal services in a court case. The transaction between C and the organization must be reported on Schedule L (Form 990) because it is a transaction between the organization and an entity of which B is a more-than-35% owner, and because the payment to C from the organization exceeded $100,000 (see the instructions for Schedule L (Form 990), Part IV, regarding both factors). Accordingly, B isn’t an independent member of the governing body because the $120,000 payment must be reported on Schedule L (Form 990) as an indirect business transaction with B. If B were an associate attorney (an employee) rather than a partner with a greater-than-35% interest, and not an officer, director, trustee, or owner of the law firm, the transaction wouldn’t affect B’s status as an independent member of the organization’s governing body.

Example 2. D is a voting member of both the organization’s governing body and the governing body of C, a related organization. D’s child, E, received $40,000 in taxable compensation as a part-time employee of C. D isn’t an independent member of the governing body, because E received compensation from C, a related organization to D, and the compensation was of a type (compensation to a family member of a member of C’s governing body) and amount (over $10,000) that would be reportable on Schedule L (Form 990) if the related organization, C, were required to file Schedule L (Form 990).

Example 3. C was Board Chair of X school during the tax year. X’s bylaws designate the following as officer positions: Board Chair, Secretary, and Treasurer. C set the agenda for board of directors meetings, officiated board meetings, coordinated development of board policy and procedure, was an ex-officio member of all committees of the board, conducted weekly staff meetings, and performed teacher and staff evaluations. X compensated C during the tax year for C’s services. This compensation was attributable to C’s board and committee activities, and to C’s non-director activities involving staff meetings and evaluations. Because X compensated C for services as an officer/employee, C isn’t an independent member of the governing body. See Rev. Rul. 68-597 and Rev. Rul. 57-246 for a description of the distinction between director services and officer services.

Example 4. The facts are the same as in Example 3, except that the Board Chair position wasn’t designated as an officer position under X’s bylaws, board resolutions, or state law. Nevertheless, because X compensated C for non-director activities involving staff meetings and evaluations during the tax year, C is deemed to have received compensation as an employee—not as a governing body member—for those activities. Therefore, C isn’t an independent member of the governing body.

Example 5. The facts are the same as in Example 3, except that (1) C conducted only director and committee activities during the tax year; (2) C didn’t conduct staff meetings and evaluations; and (3) X compensated C a reasonable amount for C’s Board Chair services during the tax year, but didn’t provide any other compensation to C in any other capacity. C’s independence as a Board member isn’t compromised by receiving compensation from X as a Board member (and not as an officer or employee).

Also see Examples 2 and 3 in the instructions for Part VII, Section A, line 5, later.

Reasonable effort. The organization need not engage in more than a reasonable effort to obtain the necessary

20 2025 Instructions for Form 990

information to determine the number of independent voting members of its governing body and can rely on information provided by such members. For instance, the organization can rely on information it obtains in response to a questionnaire sent annually to each member of the governing body that includes the member’s name and title, blank lines for the member’s signature and signature date, and the pertinent instructions and definitions for line 1b to determine whether the member is or isn’t independent.

Line 2. Answer “Yes” if any of the organization’s current officers, directors, trustees, or key employees, as reported in Part VII, Section A, had a family relationship or business relationship with another of the organization’s current officers, directors, trustees, or key employees, as reported in Part VII, Section A, at any time during the organization’s tax year . For each family and business relationship, identify the persons and describe their relationship on Schedule O (Form 990). It is sufficient to enter “family relationship” or “business relationship” without greater detail.

Business relationship. Business relationships between two persons include any of 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, even if that organization is tax exempt. However, don’t report a person’s employment by the filing organization as a business relationship.

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, whichever is greater) of a corporation, profits or capital interest in a partnership or an LLC (whichever is greater), 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 may be ownership through multiple tiers of entities.

Privileged relationship exception. For purposes of line 2, a business relationship doesn’t include a relationship between an attorney and client, a medical professional (including psychologist) and patient, or a priest/clergy and penitent/ communicant.

Example 1. B is an officer of the organization, and C is a member of the organization’s governing body. B is C’s sister’s spouse. The organization must report that B and C have a family relationship.

Example 2. D and E are officers of the organization. D is 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, director, or trustee of the accounting firm. D’s accounting firm provides services to E in the ordinary course of the accounting firm’s business, on terms generally offered to the public, and receives $100,000 in fees during the year. The relationship between D and E isn’t a reportable business relationship, either because (1) it is in the ordinary course of business on terms

generally offered to the public, or (2) D doesn’t hold a greater-than-35% interest in the accounting firm’s profits or capital.

Example 3. F and G are trustees of the organization. F is the owner and CEO of an automobile dealership. G purchased a $45,000 car from the dealership during the organization’s tax year in the ordinary course of the dealership’s business, on terms generally offered to the public. The relationship between F and G isn’t a reportable business relationship because the transaction was in the ordinary course of business on terms generally offered to the public.

Example 4. H and J are members of the organization’s board of directors. Both are CEOs of publicly traded corporations and serve on each other’s board. The relationship between H and J is a reportable business relationship because each is a director or officer in the same business entity.

Example 5. K is an officer of the organization, and L is on its board of directors. L is a greater-than-35% partner of a law firm that charged $60,000 during the organization’s tax year for legal services provided to K that were worth $600,000 at the law firm’s ordinary rates. Thus, the ordinary course of business exception doesn’t apply. However, the relationship between K and L isn’t a reportable business relationship because of the privileged relationship of attorney and client.

Reasonable effort. The organization isn’t required to provide information about a family or business relationship between two officers, directors, trustees, or key employees if it is unable to secure the information after making a reasonable effort to obtain it. An example of a reasonable effort would be for the organization to distribute a questionnaire annually to each such person that includes the name and title of each person reporting information, blank lines for those persons’ signatures and signature dates, and the pertinent instructions and definitions for line 2.

Line 3. Answer “Yes” if, at any time during the organization’s tax year, the organization used a management company or other person (other than persons acting in their capacities as officers, directors, trustees, or key employees ) to perform any management duties customarily performed by or under the direct supervision of officers, directors, trustees, or key employees . Such management duties include, but aren’t limited to, hiring, firing, and supervising personnel; planning or executing budgets or financial operations; or supervising exempt operations or unrelated trades or businesses of the organization. Management duties don’t include administrative services (such as payroll processing) that don’t involve significant managerial decision making. Management duties also don’t include investment management unless the filing organization conducts investment management services for others.

If “Yes” on Schedule O (Form 990), list the name(s) of the management company or companies or other person(s) performing management duties; describe the services they provided to the organization; list any of the organization’s current or former officers, directors, trustees, key employees, and highest compensated employees listed in Part VII, Section A, who were compensated by the management company or companies or other person(s) during the calendar year ending with or within the organization’s tax year; and list the amounts of reportable and other compensation they received from the management company or companies or other person(s) for services provided to the filing organization and related organizations during that year.

Line 4. The organization must report significant changes to its organizing or enabling document by which it was created (articles of incorporation, association, or organization; trust instrument; constitution; or similar document), and to its rules governing its affairs commonly known as bylaws (or regulations,

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operating agreement, or similar document). Report significant changes that weren’t reported on any prior Form 990, and that were made before the end of the tax year . Don’t report changes to policies described or established outside of the organizing or enabling document and bylaws (or similar documents), such as adoption of, or change to, a policy adopted by resolution of the governing body that doesn’t entail a change to the organizing document or bylaws.

Examples of significant changes to the organizing or enabling document or bylaws include changes to:

• The organization’s exempt purposes or mission;

• The organization’s name (also see the instructions under Specific Instructions, Item B, earlier);

• The number, composition, qualifications, authority, or duties of the governing body’s voting members;

• The number, composition, qualifications, authority, or duties of the organization’s officers or key employees ;

• The role of the stockholders or membership in governance;

• The distribution of assets upon dissolution;

• The provisions to amend the organizing or enabling document or bylaws;

• The quorum, voting rights, or voting approval requirements of the governing body members or the organization’s stockholders or membership;

• The policies or procedures contained within the organizing documents or bylaws regarding compensation of officers, directors, trustees, or key employees, conflicts of interest, whistleblowers, or document retention and destruction; and

• The composition or procedures contained within the organizing document or bylaws of an audit committee.

Example. Organization X has a written conflicts of interest policy that isn’t contained within the organizing document or bylaws. The policy is changed by board resolution. The policy change doesn’t need to be reported on line 4.

Examples of insignificant changes made to organizing or enabling documents or bylaws that aren’t required to be reported here include changes to the organization’s registered agent with the state and to the required or permitted number or frequency of governing body or member meetings.

Describe significant changes on Schedule O (Form 990), but don’t attach a copy of the amendments or amended document to Form 990 (or recite the entire amended document verbatim), unless such amended documents reflect a change in the organization’s name. See Specific Instructions, Item B, earlier, regarding attachments required in the event of a change in the organization’s name.

Tip: An organization must report significant changes to its organizational documents on Form 990, Part VI, rather than in a letter to EO Determinations. EO Determinations no longer issues letters confirming the tax-exempt status of organizations that report significant changes to their organizational documents, though it will, on request, issue an affirmation letter confirming an organization’s name change. The IRS will no longer require a new exemption application from a domestic section 501(c) organization that undergoes certain changes of form or place of organization described in Rev. Proc. 2018-15, 2018-9 I.R.B. 379.

Line 5. Answer “Yes” if the organization became aware during the organization’s tax year of a significant diversion of its assets, whether or not the diversion occurred during the year. If “Yes,” explain the nature of the diversion, dollar amounts and/or other property involved, corrective actions taken to address the matter, and pertinent circumstances on Schedule O (Form 990), although the person or persons who diverted the assets shouldn’t be identified by name.

A diversion of assets includes any unauthorized conversion or use of the organization’s assets other than for the organization’s authorized purposes, including but not limited to embezzlement

or theft. Report diversions by the organization’s officers, directors, trustees, employees, volunteers, independent contractors, grantees (diverting grant funds), or any other person, even if not associated with the organization other than by the diversion. A diversion of assets doesn’t include an authorized transfer of assets for FMV consideration, such as to a joint venture or for-profit subsidiary in exchange for an interest in the joint venture or subsidiary. For this purpose, a diversion is considered significant 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 (1) 5% of the organization’s gross receipts for its tax year, (2) 5% of the organization’s total assets as of the end of its tax year, or (3) $250,000.

Note: A diversion of assets can in some cases be inurement of the organization’s net earnings. In the case of section 501(c)(3), 501(c)(4), and 501(c)(29) organizations, it can also be an excess benefit transaction taxable under section 4958 and reportable on Schedule L (Form 990).

Line 6. Answer “Yes” if the organization is organized as a stock corporation, a joint-stock company, a partnership, a joint venture, or an LLC. Also answer “Yes” if the 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 to what a person, including a corporation or other legal entity, is called in the governing documents) any person who, pursuant to a provision of the organization’s governing documents or applicable state law, has the right to participate in the organization’s governance or to receive distributions of income or assets from the organization. Members don’t include governing body members. For purposes of Part VI, a membership organization includes members with the following kinds of rights.

1. The members elect the members of the governing body (but not if the persons on the governing body are the organization’s only members) or their delegates.

2. The members approve significant decisions of the governing body.

3. The members can receive a share of the organization’s profits or excess dues or a share of the organization’s net assets upon the organization’s dissolution.

Describe on Schedule O (Form 990) the classes of members or stockholders with the rights described above.

Line 7a. Answer “Yes” on line 7a if at any time during the organization’s tax year there were one or more persons (other than the organization’s governing body itself, acting in such capacity) that had the right to elect or appoint one or more members of the organization’s governing body, whether periodically, or as vacancies arise, or otherwise. If “Yes,” describe on Schedule O (Form 990) the class or classes of such persons and the nature of their rights.

Line 7b. Answer “Yes” on line 7b if at any time during the organization’s tax year any governance decisions of the organization were reserved to (or subject to approval by) members, stockholders, or persons other than the governing body, whether or not any such governance decisions were made during the tax year, such as approval of the governing body’s election or removal of members of the governing body, or approval of the governing body’s decision to dissolve the organization. If “Yes,” describe on Schedule O (Form 990) the class or classes of such persons, the decisions that require their approval, and the nature of their voting rights.

Line 8. Answer “Yes” on lines 8a and 8b if the organization contemporaneously documented by any means permitted by state law every meeting held and written action taken during the

22 2025 Instructions for Form 990

organization’s tax year by its governing body and committees with authority to act on behalf of the governing body (which ordinarily don’t include advisory boards). Documentation permitted by state law can include approved minutes, email, or similar writings that explain the action taken, when it was taken, and who made the decision. For this purpose, contemporaneous means by the later of (1) the next meeting of the governing body or committee (such as approving the minutes of the prior meeting), or (2) 60 days after the date of the meeting or written action. If the answer to either line 8a or 8b is “No,” explain on Schedule O (Form 990) the organization’s practices or policies, if any, regarding documentation of meetings and written actions of its governing body and committees with authority to act on its behalf. If the organization had no committees, answer “No” on line 8b.

Line 9. The IRS needs a current mailing address to contact the organization’s officers, directors, trustees, or key employees . The organization can use its official mailing address stated on the first page of Form 990 as the mailing address for such persons. Otherwise, enter on Schedule O (Form 990) the mailing addresses for such persons who are to be contacted at a different address. Such information will be available to the public.

Section B. Policies

Answer “Yes” to any question in this section that asks whether the organization had a particular policy or practice only if the organization’s governing body (or a committee of the governing body, if the governing body delegated authority to that committee to adopt the policy) adopted the policy by the end of its tax year, and if the policy applied to the organization as a whole. If the policy applied only on a division-wide or department-wide level, answer “No.” The organization may explain the scope of such policy on Schedule O (Form 990).

Line 10a. Answer “Yes” if the organization had during its tax year any local chapters, local branches, local lodges, or other similar local units or affiliates over which the organization had the legal authority to exercise direct or indirect supervision and control (whether or not in a group exemption ) and local units that aren’t separate legal entities under state law over which the organization had such authority. An affiliate or unit is considered “local” for this purpose if it is responsible for a smaller geographical area than the filing organization is responsible for. Thus, a regional organization would be considered local for a national organization.

Example 1. X is a national organization dedicated to the reform of K. X has affiliates in 15 states that conduct activities to carry out the purposes of X at the state level. X has the authority to approve the annual budget of each affiliate. X must answer “Yes” on line 10a.

Example 2. Y is a section 170(b)(1)(A)(iii) hospital located in M City. Y appoints a majority of the board of directors of Z, a section 509(a)(3) supporting organization that invests funds and makes grants for the benefit of Y. Although Y controls Z, Z isn’t a local affiliate of Y that would require Y to answer “Yes” on line 10a.

Line 10b. Written policies and procedures governing the activities of local chapters, branches, and affiliates to ensure their operations are consistent with the organization’s tax-exempt purposes are documents used by the organization and its local units to address the policies, practices, and activities of the local unit. Such policies and procedures can include policies and procedures similar to those described on lines 11–16 of this section, whether separate or included as required provisions in the chapter’s articles of organization or bylaws, a manual provided to chapters, a constitution, or similar documents. If “No,” explain on Schedule O (Form 990) how the organization

ensures that the local unit’s activities are consistent with the organization’s tax-exempt purposes.

Note: The central organization (parent organization) named in a group exemption letter is required to have general supervision or control over its subordinate organizations as a condition of the group exemption.

Line 11a. Answer “Yes” only if a complete copy of the organization’s final Form 990 (including all required schedules), as ultimately filed with the IRS, was provided to each person who was a voting member of the governing body at the time the Form 990 was provided, whether in paper or electronic form, before its filing with the IRS. The organization can answer “Yes” if it emailed all of its governing body members a link to a password-protected website on which the entire Form 990 can be viewed, and noted in the email that the Form 990 is available for review on that site. However, answer “No” if the organization merely informed its governing body members that a copy of the Form 990 is available upon request. Answer “No” if the organization redacted or removed any information from the copy of its final Form 990 that it provided to its governing body members before filing the form. For example, answer “No” if the organization, at the request of a donor, redacted the name and address of that donor from the copy of its Schedule B (Form 990) that it provided to its governing body members. Under those circumstances, the organization may explain on Schedule O (Form 990) why it answered “No” to line 11a.

Line 11b. Describe on Schedule O (Form 990) the process, if any, by which any of the organization’s officers, directors, trustees, board committee members, or management reviewed the prepared Form 990, whether before or after it was filed with the IRS, including specifics about who conducted the review, when they conducted it, and the extent of any such review. If no review was or will be conducted, enter “No review was or will be conducted.”

Example. The return preparer emails a copy of the final version of Form 990 to each Board member before it was filed. However, no Board member undertakes any review of the form either before or after filing. Because such a copy of the final version of the form was provided to each voting member of the organization’s governing body before it was filed, the organization can answer “Yes” even though no review took place. The organization must describe its Form 990 review process (or lack thereof) on Schedule O (Form 990).

Line 12a. Answer “Yes” if, as of the end of the organization’s tax year, the organization had a written conflict of interest policy . A conflict of interest policy defines conflicts 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, manager, or key employee 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.

Example. B is a member of the governing body of X Charity and of Y Charity, both of which are section 501(c)(3) public charities with different charitable purposes. X Charity has taken a public stand in opposition to a specific legislative proposal. At an upcoming board meeting, Y Charity will consider whether to publicly endorse the same specific legislative proposal. While B

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may have a conflict of interest in this decision, the conflict doesn’t involve a material financial interest of B’s merely as a result of Y Charity’s position on the legislation.

Line 12b. Answer “Yes” if the organization’s officers, directors, trustees, and key employees are required to disclose or update annually (or more frequently) information regarding their interests and those of their family members that could give rise to conflicts of interest, such as a list of family members, substantial business or investment holdings, and other transactions or affiliations with businesses and other organizations and those of family members.

Line 12c. If “Yes,” describe on Schedule O (Form 990) the organization’s practices for monitoring proposed or ongoing transactions for conflicts of interest and dealing with potential or actual conflicts, whether discovered before or after the transaction has occurred. The description should include an explanation of which persons are covered under the policy, the level at which determinations of whether a conflict exists are made, and the level at which actual conflicts are reviewed. Also explain any restrictions imposed on persons with a conflict, such as prohibiting them from participating in the governing body ’s deliberations and decisions in the transaction.

Lines 13 and 14. A whistleblower policy encourages staff and volunteers to come forward with credible information on illegal practices or violations of adopted policies of the organization, specifies that the organization will protect the individual from retaliation, and identifies those staff or board members or outside parties to whom such information can be reported. A document retention and destruction policy identifies the record retention responsibilities of staff, volunteers, board members, and outsiders for maintaining and documenting the storage and destruction of the organization’s documents and records.

Certain federal or state laws provide protection against whistleblower retaliation and prohibit destruction of certain documents. For instance, while the federal Sarbanes-Oxley legislation generally doesn’t pertain to tax-exempt organizations, it does impose criminal liability on tax-exempt as well as other organizations for (1) retaliation against whistleblowers that report federal offenses, and (2) destruction of records with the intent to obstruct a federal investigation. See 18 U.S.C. sections 1513(e) and 1519. Also note that an organization is required to keep books and records relevant to its tax exemption and its filings with the IRS. Some states provide additional protection for whistleblowers.

Line 15. Answer “Yes” on line 15a if, during the tax year, the organization (not a related organization or other third party) used a process for determining compensation (reported in Part II or on Schedule J (Form 990), Compensation Information) of the CEO, executive director, or other person who is the top management official, that included all of the following elements.

• Review and approval by a governing body or compensation committee, provided that persons with a conflict of interest regarding the compensation arrangement at issue weren’t involved. For purposes of this question, a member of the governing body or compensation committee has a conflict of interest regarding a compensation arrangement if any of the following circumstances apply.

1. The member (or a family member of the member) is participating in or economically benefitting from the compensation arrangement.

2. The member is in an employment relationship subject to the direction or control of any person participating in or economically benefitting from the compensation arrangement.

3. The member receives compensation or other payments subject to approval by any person participating in or economically benefitting from the compensation arrangement.

4. The member has a material financial interest affected by the compensation arrangement.

5. The member approves a transaction providing economic benefits to any person participating in the compensation arrangement, who in turn has approved or will approve a transaction providing economic benefits to the member. See Regulations section 53.4958-6(c)(1)(iii).

Answer “Yes” on line 15b if the process for determining compensation of one or more officers or key employees other than the top management official included all of the elements listed above.

If the answer was “Yes” on line 15a or 15b, describe the process on Schedule O (Form 990), identify the offices or positions for which the process was used to establish compensation of the persons who served in those offices or positions, and enter the year in which this process was last undertaken for each such person.

If the organization didn’t compensate its CEO, executive director, or top management official during the tax year, answer “No” to line 15a. If the organization didn’t compensate any of its other officers or key employees during the tax year, even if such employees were compensated by a related organization, answer “No” to line 15b.

Line 16. Answer “Yes” on line 16a if, at any time during its tax year, the organization invested in, contributed assets to, or otherwise participated in a joint venture or similar arrangement with one or more taxable persons. For purposes of line 16, a joint venture or similar arrangement (or a “venture or arrangement”) means any joint ownership or contractual arrangement through which there is an agreement to jointly undertake a specific business enterprise, investment, or exempt-purpose activity without regard to (1) whether the organization controls the venture or arrangement; (2) the legal structure of the venture or arrangement; or (3) whether the venture or arrangement is treated as a partnership for federal income tax purposes, or as an association, or corporation for federal income tax purposes. Disregard ventures or arrangements that meet both of the following conditions.

1. 95% or more of the venture’s or arrangement’s income for its tax year ending with or within the organization’s tax year is described in sections 512(b)(1)–(5) (including unrelated debt-financed income).

2. The primary purpose of the organization’s contribution to, or investment or participation in, the venture or arrangement is the production of income or appreciation of property.

Answer “Yes” on line 16b if, as of the end of the organization’s tax year, the organization had both:

1. Followed a written policy or procedure that required the organization to negotiate, in its transactions and arrangements with other members of the venture or arrangement, such terms and safeguards as are adequate to ensure that the organization’s exempt status is protected; and

2. Taken steps to safeguard the organization’s exempt status for the venture or arrangement.

Some examples of safeguards include the following.

• Use of data as to comparable compensation for similarly qualified persons in functionally comparable positions at similarly situated organizations.

• Contemporaneous documentation and recordkeeping for deliberations and decisions regarding the compensation arrangement.

24 2025 Instructions for Form 990

• Control over the venture or arrangement sufficient to ensure that the venture furthers the exempt purpose of the organization.

• Requirements that the venture or arrangement give priority to exempt purposes over maximizing profits for the other participants.

• The venture or arrangement not engage in activities that would jeopardize the organization’s exemption (such as political intervention or substantial lobbying for a section 501(c)(3) organization).

• All contracts entered into with the organization be on terms that are at arm’s length or more favorable to the organization.

Section C. Disclosure

Line 17. List the states with which a copy of this Form 990 is required to be filed, even if the organization hasn’t yet filed Form 990 with that state. Use Schedule O (Form 990) if additional space is necessary.

Tip: Some states require or permit the filing of Form 990 to fulfill state exempt organization or charitable solicitation reporting requirements.

Line 18. Check the box for “Own website” only if the organization posted an exact reproduction (other than for information permitted by law to be withheld from public disclosure, such as the names and addresses of contributors listed on Schedule B (Form 990)) of its Form 990, Form 990-T (for section 501(c)(3) organizations), or application for recognition of exemption (Form 1023, 1023-EZ, 1024, or 1024-A) on its website during its tax year . Check the box for “Another’s website” only if the organization provided to another individual or organization and that other individual or organization posted on its website an exact reproduction (other than for information permitted by law to be withheld from public disclosure, such as the names and addresses of contributors listed on Schedule B (Form 990)) of any such forms during the tax year.

If “Other” is checked, explain on Schedule O (Form 990). Also explain on Schedule O (Form 990) if the organization didn’t make publicly available upon request any of Forms 1023, 1023-EZ, 1024, 1024-A, 990, or 990-T that are subject to public inspection requirements. Exempt organizations must make available for public inspection their Form 1023, 1023-EZ, 1024, or 1024-A application for recognition of exemption. Applications filed before July 15, 1987, need not be made publicly available unless the organization had a copy on July 15, 1987.

Organizations that file Form 990 must make it publicly available for a period of 3 years from the date it is required to be filed (including extensions) or, if later, is actually filed. Organizations aren’t required to make publicly available the names and addresses of contributors (as set forth on Schedule B (Form 990), and on Form 1023, 1023-EZ, 1024, or 1024-A). Section 501(c)(3) organizations that file Form 990-T are also required to make their Forms 990-T publicly available for the corresponding 3-year period for forms filed after August 17, 2006 (unless the form was filed solely to request a refund of telephone excise taxes). See Appendix D for more information on public inspection requirements.

Line 19. Explain on Schedule O (Form 990) whether the organization made its governing documents (for example, articles of incorporation, constitution, bylaws, trust instrument), conflict of interest policy, and financial statements (whether or not audited) available to the general public during the tax year, and, if so, how it made them available to the public (for example, posting on the organization’s website, posting on another website, providing copies on request, inspection at an office of the organization, etc.). If the organization didn’t make any of these documents available to the public, enter “No documents available to the public.”

Federal tax law doesn’t require that such documents be made publicly available unless they were included on a form that is publicly available (such as Form 1023, 1023-EZ, 1024, or 1024-A).

Line 20. Provide the name of the person who possesses the organization’s books and records, and the business address and telephone number of such person (or of the organization if the books and records are kept by such person at a personal residence). If the books and records are kept at more than one location, provide the name, business address, and telephone number of the person responsible for coordinating the maintenance of the books and records. The organization isn’t required to provide the address or telephone number of a personal residence of an individual. If provided, however, such information will be available to the public.

Direct costs are expenses that can be identified specifically with an organization’s activity or project, and can be assigned to an activity or project with a high degree of accuracy. Indirect costs are costs that can’t be identified specifically with an activity or project. For example, a computer bought by a university specifically for a research project is a direct cost. In contrast, the costs of software licensing for programs that run on all the university’s computers are indirect costs.

Colleges, universities, hospitals, and other organizations that incur indirect expenses in various cost centers (such as organizational memberships, books and subscriptions, and regular telecommunications costs) can allocate and report such expenses in the following manner.

1. Report the expenses of all indirect cost centers in column (C), lines 5 through 24.

2. As a separate line item of line 24, enter “Allocation of

[name of indirect cost center] expenses.”

a. If any of the cost center’s expenses are allocated to expenses listed in Part VIII, such as the expenses attributable to fundraising events and activities, enter such expenses as a negative figure in columns (A) and (C).

b. Allocate expenses to column (B) or (D) as positive amounts.

c. Add the amounts in columns (B) and (D) and enter the sum as a negative offsetting amount in column (C). Don’t make any entries in column (A) for these offsetting entries.

Example. An organization reports in column (C) $50,000 of its actual management and general expenses and $100,000 of expenses of an indirect cost center that are allocable in part to other functions. The total of lines 5 through 24 of column (C) would be $150,000 before the indirect cost center allocations were made. Assume that of the $100,000 total expenses of the cost center, $10,000 was allocable to fundraising; $70,000 to various program services; $15,000 to management and general functions; and $5,000 to special events and activities. To report this in Part IX under this optional method:

1. Indicate the cost center, the expenses of which are being allocated, on line 24 as “Allocation of [specify the indirect cost center] expenses”;

2. Enter a decrease of $5,000 on the same line in column (A), “Total expenses,” representing the fundraising event expenses that were already reported in Part VIII, line 8b;

3. Enter $70,000 on the same line in column (B), “Program service expenses”;

4. Enter $10,000 on the same line in column (D), “Fundraising expenses”; and

5. Enter a decrease of $85,000 on the same line in column (C), “Management and general expenses,” to represent the allocations to functional areas other than management and general.

2025 Instructions for Form 990 43

After making these allocations, the column (C), line 25, total functional expenses would be $65,000, consisting of the $50,000 actual management and general expense amount and the $15,000 allocation of the aggregate cost center expenses to management and general.

The above is an example of a one-step allocation that shows how to report the allocation in Part IX. This reporting method would actually be more useful to avoid multiple-step allocations involving two or more cost centers. Without this optional reporting method, the total expenses of the first cost center would be allocated to the other functions and might include an allocation of part of these expenses to another cost center. The expenses of the second cost center would then be allocated to other functions and, perhaps, to other cost centers, and so on. The greater the number of these cost centers that are allocated out, the more difficult it is to preserve the object classification identity of the expenses of each cost center (for example, salaries, interest, supplies, etc.). Using the reporting method described above avoids this problem.

Caution: The intent of the above instructions is only to facilitate reporting indirect expenses by both object classification and function. These instructions don’t authorize the allocation to other functions of expenses that should be reported as management and general expenses.

Organizations should report the amount of grants and other assistance on lines 1 through 3. Report expenses incurred in selecting recipients or monitoring compliance with the terms of a grant or award on lines 5 through 24. See the following instructions.

Note: Organizations can report this information according to ASC 958 but aren’t required to do so. For example, an organization that follows ASC 958 and makes a grant during the tax year to be paid in future years should report the grant’s present value on this year’s Form 990 and report accruals of additional value increments in future years.

Line 1. Enter the amount that the organization, at its own discretion, paid in grants to domestic organizations and domestic governments. United Way and similar federated fundraising organizations should report grants to member or participating agencies on line 1. Organizations must report voluntary grants to state or local affiliates for specific (restricted) purposes or projects on line 1.

If the organization reported on line 1 more than $5,000 of grants or other assistance to any domestic organization or to any domestic government, the organization must complete Parts I and II of Schedule I (Form 990).

Section 501(c)(21) trusts. Use line 1 to report amounts paid by the trust to:

• For insurance exclusively covering liabilities under sections 501(c)(21)(A)(i)(I) and 501(c)(21)(A)(i)(IV). For details, see Regulations section 1.501(c)(21)-1(d).

Line 2. Enter the amount paid by the organization to domestic individuals in the form of scholarships, fellowships, stipends, research grants, and similar payments and distributions.

Also include grants and other assistance paid to third-party providers for the benefit of specified domestic individuals . For example, a grant payment to a hospital to cover the medical expenses of a specific patient must be reported on line 2. By comparison, a grant to the same hospital to provide services to the general public or to unspecified charity patients must be reported on line 1.

If line 2 exceeds $5,000, the organization must complete Parts I and III of Schedule I (Form 990).

Section 501(c)(21) trusts. Use line 2 to report amounts paid by the trust to or for the benefit of miners or their beneficiaries.

Line 3. The organization must enter the total amount of grants and other assistance made to foreign organizations, foreign governments, and foreign individuals, and to domestic organizations or domestic individuals for the purpose of providing grants or other assistance to designated foreign organizations or foreign individuals .

If line 3 exceeds $5,000, the organization may have to complete Part II and/or Part III of Schedule F (Form 990), Statement of Activities Outside the United States. See the Instructions for Schedule F (Form 990) for more information.

Line 4. Enter the payments made by the organization to provide benefits to members (such as payments made by an organization exempt under section 501(c)(8), 501(c)(9), or 501(c)(17) to obtain insurance benefits for members, or patronage dividends paid by section 501(c)(12) organizations to their members). Don’t report on this line the cost of employment-related benefits such as health insurance, life insurance, or disability insurance provided by the organization to its officers, directors, trustees, key employees, and other employees . Report such costs for officers, directors, trustees, and key employees on Part IX, line 5; report such costs for other disqualified persons on Part IX, line 6; and report such costs for other employees on Part IX, lines 8 and 9.

Line 5. Enter the total compensation paid to current officers, directors, trustees, and key employees (as defined under Part VII, earlier) for the organization’s tax year . Compensation includes all forms of income and other benefits earned or received from the filing organization, common paymasters, and payroll/reporting agents in return for services rendered to the filing organization, including compensation reported on Forms W-2 and 1099, pension plan contributions and accruals, and other employee benefits, but doesn’t include non-compensatory expense reimbursements or allowances. Report all compensation amounts relating to such an individual, including those related to services performed in a capacity other than as an officer, director, trustee, or key employee.

Tip: Compensation for Part IX is reported based on the accounting method and tax year used by the organization,

• The Federal Black Lung Disability Trust Fund pursuant to section 3(b)(3) of Public Law 95-227, or

Allocating Indirect Expenses—Example

44 2025 Instructions for Form 990

rather than the definitions and calendar year used to complete Part VII or Schedule J (Form 990) regarding compensation of certain officers, directors, trustees, and other employees .

Note: To the extent the following examples discuss allocation of expenses in columns (B), (C), and (D), they apply only to filers required to complete those columns.

Line 6. Section 501(c)(3), 501(c)(4), and 501(c)(29) organizations must report the total compensation and other distributions provided to disqualified persons and persons described in section 4958(c)(3)(B) to the extent not included on line 5. See Appendix G .

Compensation includes all forms of income and other benefits earned or received from the filing organization, common paymasters, and payroll/reporting agents in return for services rendered to the filing organization, including compensation reported on Forms W-2 and 1099, pension plan contributions and accruals, and other employee benefits, but doesn’t include non-compensatory expense reimbursements or allowances.

Line 7. Enter the total amount of employee salaries, wages, fees, bonuses, severance payments, and similar amounts paid or provided from the filing organization, common paymasters, and payroll/reporting agents in return for services rendered to the filing organization that aren’t reported on line 5 or 6.

Line 8. Enter the employer’s share of contributions to, or accruals under, qualified and nonqualified pension and deferred compensation plans for the year. The organization should include contributions made by the filing organization, common paymasters, and payroll/reporting agents to the filing organization’s sections 401(k) and 403(b) pension plans on behalf of employees . However, it shouldn’t include contributions to qualified pension, profit-sharing, and stock bonus plans under section 401(a) solely for the benefit of current or former officers, directors, trustees, key employees, or disqualified persons, which are reportable on line 5 or 6.

Tip: Complete Form 5500 for the organization’s plan and file it as a separate return. If the organization has more than one pension plan, complete a Form 5500 for each plan. File the form by the last day of the 7th month after the plan year ends.

Line 9. Other employee benefits. Enter contributions by the filing organization, common paymasters, and payroll/reporting agents to the filing organization’s employee benefit programs (such as insurance, health, and welfare programs that aren’t an incidental part of a pension plan included on line 8), and the cost of other employee benefits.

For example, report expenses for employee events such as a picnic or holiday party on line 9. Don’t include contributions on behalf of current or former officers, directors, trustees, key employees, or other persons that were included on line 5 or 6.

Line 10. Payroll taxes. Enter the amount of federal, state, and local payroll taxes for the year but only those taxes that are imposed on the organization as an employer. This includes the employer’s share of social security and Medicare taxes, the federal unemployment tax (FUTA), state unemployment compensation taxes, and other state and local payroll taxes. Don’t include on line 10 taxes withheld from employees’ salaries and paid to various governmental units such as federal, state, and local income taxes and the employees’ shares of social security and Medicare taxes. Such withheld amounts are reported as compensation.

Line 11. Fees for services paid to nonemployees (inde- pendent contractors). Enter on lines 11a through 11g amounts for services provided by independent contractors for management, legal, accounting, lobbying, professional fundraising services, investment management, and other services, respectively. Include amounts whether or not a Form

1099 was issued to the independent contractor . Don’t include on line 11 amounts paid to or earned by employees, officers, directors, trustees, or disqualified persons for these types of services, which must be reported on lines 5 through 7.

If the organization is able to distinguish between fees paid for independent contractor services and expense payments or reimbursements to the contractor(s), report the fees paid for services on line 11 and the expense payments or reimbursements on the applicable lines in Part IX (including line 24 if no other line is applicable). If the organization is unable to distinguish between service fees and expense payments or reimbursements, report all such amounts on line 11.

Line 11a. Management fees. Enter the total fees charged for management services provided by outside firms and individuals.

Line 11b. Legal fees. Enter the total legal fees charged by outside firms and individuals. Don’t include any penalties, fines, settlements, or judgments imposed against the organization as a result of legal proceedings. Report those expenses on line 24. Report any amounts for lobbying services provided by attorneys on line 11d.

Line 11c. Accounting fees. Enter the total accounting and auditing fees charged by outside firms and individuals.

Line 11d. Lobbying fees. Enter amounts for activities intended to influence foreign, national, state, or local legislation, including direct lobbying and grassroots lobbying.

Line 11e. Professional fundraising fees. Enter amounts paid for professional fundraising services, including solicitation campaigns and advice or other consulting services supporting in-house fundraising campaigns. If the organization is able to distinguish between fees paid for professional fundraising services and amounts paid for fundraising expenses such as printing, paper, envelopes, postage, mailing list rental, and equipment rental, then fees paid for professional fundraising services should be reported on line 11e and amounts paid for fundraising expenses should be reported on line 24 as other expenses. If the organization is unable to distinguish between these amounts, it should report all such fees and amounts on line 11e.

Line 11f. Investment management fees. Enter amounts for investment counseling and portfolio management. Monthly account service fees are considered portfolio management expenses and must be reported here. Don’t include transaction costs such as brokerage fees and commissions, which are considered sales expenses and are included on Part VIII, line 7b.

Line 11g. Other fees for services. Enter amounts for other independent contractor services not listed on lines 11a through 11f. For example, amounts paid to an independent contractor for advocacy services that don’t constitute lobbying should be reported here. For health care organizations, payments to health care professionals who are independent contractors are reported on line 11g. Report on line 11g payments to payroll agents, common paymasters, and other third parties for services provided by those third parties to the filing organization. Report on lines 5–10, as appropriate, payments that reimburse third parties for compensation to the organization’s officers, directors, trustees, key employees, or other employees . Report payments to contractors for information technology services on line 14, rather than on line 11g.

If the amount on line 11g exceeds 10% of the amount in column (A) of line 25, the organization must list the type and amount of each line 11g expense on Schedule O (Form 990).

Line 12. Advertising and promotion expenses. Enter amounts paid for advertising. Include amounts for print and electronic media advertising. Also include Internet site link costs,

2025 Instructions for Form 990 45

signage costs, and advertising costs for the organization’s in-house fundraising campaigns. Include fees paid to independent contractors for advertising, except for fees paid to independent contractors for conducting professional fundraising services or campaigns, which are reported on line 11e.

Line 13. Office expenses. Enter amounts for supplies (office, classroom, or other supplies); telephone (cell phones and landlines) and fax; postage (overnight delivery, parcel delivery, trucking, and other delivery expenses) and mailing expenses; shipping materials; equipment rental; bank fees; and other similar costs. Also include printing costs of a general nature. Printing costs that relate to conferences or conventions must be reported on line 19.

Line 14. Information technology. Enter amounts for information technology, including hardware, software, and support services such as maintenance, help desk, and other technical support services. Also include expenses for infrastructure support, such as website design and operations, virus protection and other information security programs and services to keep the organization’s website operational and secured against unauthorized and unwarranted intrusions, and other information technology contractor services. Report payments to information technology employees on lines 5 through 10. Report depreciation/amortization related to information technology on line 22.

Line 15. Royalties. Enter amounts for royalties, license fees, and similar amounts that allow the organization to use intellectual property such as patents and copyrights.

Line 16. Occupancy. Enter amounts for the use of office space or other facilities, including rent; heat, light, power, and other utilities expenses; property insurance; real estate taxes; mortgage interest; and similar occupancy-related expenses. Don’t include on line 16 expenses reported as office expenses (such as telephone expenses) on line 13.

Don’t net any rental income received from leasing or subletting rented space against the amount reported on line 16 for occupancy expenses. If the tenant’s activities are related to the organization’s exempt purpose, report rental income as program service revenue on Part VIII, line 2, and allocable occupancy expenses on line 16. However, if the tenant’s activities aren’t program related, report the rental income on Part VIII, line 6a, and related rental expenses on Part VIII, line 6b.

Don’t include employee salaries or depreciation as occupancy expenses. These expenses are reported on lines 5 through 7 and 22, respectively.

Line 17. Travel. Enter the total travel expenses, including transportation costs (fares, mileage allowances, and automobile expenses), meals and lodging, and per diem payments. Travel costs include the expenses of purchasing, leasing, operating, and repairing any vehicles owned by the organization and used for the organization’s activities. However, if the organization leases vehicles on behalf of its executives or other employees as part of an executive or employee compensation program, the leasing costs are considered employee compensation and are reported on lines 5 through 7.

Line 18. Payments of travel or entertainment expenses for any federal, state, or local public officials. Enter total amounts for travel or entertainment expenses (including reimbursement for such costs) for any federal, state, or local public officials (as determined under section 4946(c)) and their family members (as determined under section 4946(d)). Report amounts for a particular public official only if aggregate expenditures for the year relating to such official (including family members of such official) exceed $1,000 for the year.

For expenditures that aren’t specifically identifiable to a particular individual, the organization can use any reasonable allocation method to estimate the cost of the expenditure to an individual. Amounts not described above can be included in the reported total amount for line 18 or can be reported on line 24. The organization is responsible for keeping records of all travel and entertainment expenses related to a government official whether or not the expenses are reported on line 18 or line 24.

Line 19. Conferences, conventions, and meetings. Enter the total expenses incurred by the organization in conducting meetings related to its activities. Include such expenses as facility rentals, speakers’ fees and expenses, and printed materials. Include the registration fees (but not travel expenses) paid for sending any of the organization’s staff to conferences, conventions, and meetings conducted by other organizations. Travel expenses incurred by officers, directors, and employees attending such conferences, conventions, and meetings must be reported on line 17.

Line 20. Interest. Enter the total interest expense for the year. Don’t include any interest attributable to rental property (reported on Part VIII, line 6b) or any mortgage interest (reported as an occupancy expense on line 16).

Tip: Properly distinguishing between payments to affiliates and grants and allocations is especially important if the organization uses Form 990 for state reporting purposes. If the organization uses Form 990 only for reporting to the IRS, payments to affiliated or national organizations that don’t represent

Line 21. Payments to affiliates. Enter certain types of payments to organizations affiliated with (closely related to) the filing organization.

Payments to affiliated state or national organizations. Dues paid by a local organization to its affiliated state or national (parent) organization are reported on line 21. Report on this line predetermined quota support and dues (excluding membership dues of the type described below) by local agencies to their state or national organizations for unspecified purposes, that is, general use of funds for the national organization’s own program and support services.

Purchases from affiliates. Purchases of goods or services from affiliates aren’t reported on line 21 but are reported as expenses in the usual manner.

Expenses for providing goods or services to affiliates. In addition to payments made directly to affiliated organizations, expenses for providing goods or services to affiliates can be reported on line 21 if:

• The goods or services provided aren’t related to the program services conducted by the organization furnishing them (for example, when a local organization incurs expenses in the production of a solicitation film for the state or national organization); and

• The costs involved aren’t connected with the management and general or fundraising functions of the filing organization. For example, when a local organization gives a copy of its mailing list to the state or national organization, the expense of preparing the copy provided can be reported on line 21, but not the expenses of preparing and maintaining the local organization’s master list.

Voluntary awards or grants to affiliates. Don’t report on line 21 voluntary awards or grants made by the organization to its state or national organizations for specified purposes.

Membership dues paid to other organizations. Report membership dues paid to obtain general membership benefits from other organizations, such as regular services, publications, and other materials, on line 24. This is the case if a charitable organization pays dues to a trade association comprised of otherwise unrelated members.

46 2025 Instructions for Form 990

membership dues reportable as miscellaneous expenses on line 24 can be reported on either line 21 or line 1.

Line 22. Depreciation, depletion, and amortization. If the organization records depreciation, depletion, amortization, or similar expenses, enter the total on line 22. Include any depreciation or amortization of leasehold improvements and intangible assets. An organization isn’t required to use the Modified Accelerated Cost Recovery System (MACRS) to compute depreciation reported on Form 990. For an explanation of acceptable methods for computing depreciation, see Pub. 946, How To Depreciate Property. If an amount is reported on this line, the organization is required to maintain books and records to substantiate any amount reported.

Line 23. Insurance. Enter total insurance expenses other than insurance attributable to rental property (reported on Part VIII, line 6b). Don’t report on this line payments made by organizations exempt under section 501(c)(8), (9), or (17) to obtain insurance benefits for members. Report those expenses on line 4. Don’t report on this line the cost of employment-related benefits such as health insurance, life insurance, or disability insurance provided by the organization to or for its officers, directors, trustees, key employees, and other employees . Report the costs for officers, directors, trustees, and key employees on Part IX, line 5; report the costs for other disqualified persons on Part IX, line 6; and report the costs for other employees on Part IX, line 9. Report the costs for members on Part IX, line 4, not on Part IX, line 23. Don’t report on this line property or occupancy-related insurance. Report those expenses on line 16.

Line 24. Other expenses. Enter the types and amounts of expenses which weren’t reported on lines 1 through 23. Include expenses for medical supplies incurred by health care/medical organizations. Include payments by the organization to professional fundraisers of fundraising expenses such as printing, paper, envelopes, postage, mailing list rental, and equipment rental, if the organization is able to distinguish these expense amounts from fees for professional fundraising services reportable on line 11e. Enter the four largest dollar amounts on lines 24a through 24d and the total of all remaining miscellaneous expenses on line 24e. Don’t include a separate entry for “miscellaneous expenses,” “program expenses,” “other expenses,” or a similar general category on lines 24a–d. If the amount on line 24e exceeds 10% of the amount in column (A) of line 25, the organization must list the type and amount of each line 24e expense on Schedule O (Form 990).

The organization must separately report the amount, if any, of unrelated business income taxes that it paid or accrued during the tax year on line 24.

Line 25. Total functional expenses. Section 501(c)(3) and 501(c)(4) organizations. Add lines 1 through 24e and enter the totals in columns (A), (B), (C), and (D) of line 25.

All other organizations. Add lines 1 through 24e and enter the total in column (A) of line 25.

Line 26. Joint costs. Organizations that included in program service expenses (column (B) of Part IX) any joint costs from a combined educational campaign and fundraising solicitation must disclose how the total joint costs of all such combined activities were allocated in Part IX between education and fundraising. For instance, if the organization spent $100,000 on joint costs and allocated 10% to education, it would report $100,000 in column (A) of line 26; $10,000 in column (B); and $90,000 in column (D). Any costs reported here aren’t to be deducted from the other lines in Part IX on which they are reported. Don’t check the box unless the organization followed Statement of Position 98-2 (SOP 98-2), Accounting for Costs of Activities of Not-for-Profit Organizations and State and Local

Governmental Entities That Include Fundraising (FASB ASC 958-720), in allocating such costs. An organization conducts a combined educational campaign and fundraising solicitation when it solicits contributions (by mail, telephone, broadcast media, or any other means) and includes, with the solicitation, educational material or other information that furthers a bona fide non-fundraising exempt purpose of the organization.

Expenses attributable to providing information regarding the organization itself, its use of past contributions, or its planned use of contributions received are fundraising expenses and must be reported in column (D). Don’t report such expenses as program service expenses in column (B).

Any method of allocating joint costs between columns (B) and (D) must be reasonable under the facts and circumstances of each case. Most states with reporting requirements for charitable organizations and other organizations that solicit contributions either require or allow reporting of joint costs under AICPA SOP 98-2, now codified in FASB ASC 958-720.

The codes listed in this section are a selection from the North American Industry Classification System (NAICS) that should be used in completing Form 990, Part VIII, lines 2 and 11. If you don’t see a code for the activity you are trying

to categorize, select the appropriate code from the NAICS website at 2022 NAICS Census Chart . Select the most specific 6-digit code available that describes the activity producing the income being reported. Note that most codes describe

more than one type of activity. Avoid using codes that describe the organization rather than the income-producing activity.

Business Activity Codes

Business Activity Codes

Business Activity Codes

Retail Trade
Code
441100
Automobile dealers
444100
Building material and supplies
dealers
445100
Grocery and convenience
retailers
445200
Specialty food retailers
449100
Furniture and home furnishings
retailers
449210
Electronics and appliance
retailers (including computers)
455000
General merchandise retailers
456110
Pharmacies and drug retailers
456199
All other health and personal
care retailers
458000
Clothing, clothing accessories,
shoe, and jewelry retailers
459110
Sporting goods retailers
459120
Hobby, toy, and game retailers
459130
Sewing, needlework, and piece
goods retailers
459140
Musical instrument and supplies
retailers
459210
Book retailers and news dealers
(including newsstands)
459310
Florists
459410
Office supplies and stationery
retailers
459420
Gift, novelty, and souvenir
retailers
459510
Used merchandise retailers
459900
Other miscellaneous retailers

Business Activity Codes

Business Activity Codes

52 2025 Instructions for Form 990

Business Activity Codes (Continued)

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 in 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.

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) .

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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 .

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 should generally 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.

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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 official

See Top management official . “CEO” stands for chief executive officer.

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; and 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 (Form 990)), gems, and jewelry (other than costume jewelry reportable on line 5 of Schedule M (Form 990)).

Collections of works of art, historical treasures, and other similar assets

Include collections, as described in ASC 958-360-45, of works of art , 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.

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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 she or he 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 the instructions for Part VI, line 15.

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, 2004-1 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 .

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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 capacities 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 an exempt 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.

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Controlling organization under section 512(b) (13)

An exempt organization that controls a controlled entity . Section 512(b)(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. 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)(6).

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 ¹ /2 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), Transactions With Interested Persons, Parts I and II, any person (including an individual, a 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 positions to exercise substantial influence over the affairs of the organization.

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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 the following.

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, and 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), 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), 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 must generally 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 .

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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 territory. A trust is domestic if a court within the United States or a U.S. territory is able to exercise primary supervision over the administration of the trust, and one or more U.S. persons (or persons in territories 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 controls 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.

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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 are generally established by donor-restricted gifts and bequests to provide a source of income in 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, a 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, a 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 .

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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).

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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:

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 (GAAP)

The accounting principles set forth by the Financial Accounting Standards 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 territory of the United States , or a political subdivision of a state or U.S. territory, 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.

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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 (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, 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 on 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 organization)

For purposes of Schedule A (Form 990), Public Charity Status and 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.

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Independent voting member of governing body

A voting member of the governing body , if all four of the following 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), 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) 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; and 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 -3.

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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 the 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 . When a management company is used, the employees may be employed by either the management company or the exempt organization. Whether the management company or the exempt organization is the employer will be determined by the facts and circumstances.

Medical research For purposes of a medical research organization operated in conjunction with a hospital (see Schedule A (Form 990), 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, diagnoses, prevention, treatments, 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.

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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.

• 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.

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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 herself 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.

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.

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).

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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. 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 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.

A “conservation purpose” means:

1. The preservation of land areas for outdoor recreation by, or for 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 a historically important land area or a certified historic structure.

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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 would otherwise 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.

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).

• 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 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), 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).

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).

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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); or (ii) 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 the 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) in box 1 or 5 of Form W-2 (whichever amount is greater); in box 1 of Form 1099-NEC; and/or in box 6 of Form 1099-MISC, 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 in box 2 of Form 1042-S. For persons for whom compensation reporting on Form W-2, 1099-NEC, 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-NEC or 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.

School An organization, the primary function of which is the presentation of formal instruction, and which has a regular faculty, a 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.

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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), 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 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 example, 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 example, 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.

• 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).

• Maintains one or more donor advised funds .

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).

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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 31 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.

Territory 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.

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 in column (B) of Form 990, Part X, line 16.

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 U.S. 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.

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. territory See Territory of the United States .

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Volunteer A person who serves the organization without compensation, for example, 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).

74 2025 Instructions for Form 990

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

2025 Instructions for Form 990 75

Type of organization Internal Revenue Code 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, Chambers of Commerce, 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, Mutual or Cooperative Telephone Companies, etc.

501(c)(12)

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 June 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 Act

501(c)(24)

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

State-Sponsored Organizations Providing Health Coverage for High-Risk Individuals

State-Sponsored Workmen’s Compensation and Insurance and Reinsurance Organizations

501(c)(26)

501(c)(27)

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)

76 2025 Instructions for Form 990

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

To figure whether an organization has to file Form 990-EZ (or Form 990), apply the $50,000 (or $5,000) gross receipts test (below) using the following definition of gross receipts and information in Figuring Gross Receipts below.

Gross receipts are the total amounts the organization received from all sources during its annual tax year (including short years) without subtracting any costs or expenses.

Caution: Don’t use the definition of gross receipts described in Appendix C. Special Gross Receipts Tests for Determining Exempt Status of Section 501(c)(7) and 501(c)(15) Organizations to figure gross receipts for this purpose. Those tests are limited to determining the exempt status of section 501(c)(7) and 501(c)(15) organizations.

Gross receipts when acting as an agent. If a local chapter of a section 501(c)(8) fraternal organization collects insurance premiums for its parent lodge and merely sends those premiums to the parent without asserting any right to use the funds or otherwise deriving any benefit from them, the local chapter doesn’t include the premiums in its gross receipts. The parent lodge reports them instead. The same treatment applies in other situations in which one organization collects funds merely as an agent for another.

Figure gross receipts for Forms 990 and 990-EZ as follows.

Form 990. Gross receipts are the sum of lines 6b(i), 6b(ii), 7b(i), 7b(ii), 8b, 9b, 10b, and 12 (column (A)) of Form 990, Part VIII.

Form 990-EZ. Gross receipts are the sum of lines 5b, 6c, 7b, and 9 of Form 990-EZ, Part I.

Example. Organization M reported $50,000 as total revenue on line 9 of its Form 990-EZ. M added back the costs and expenses it had deducted on lines 5b ($2,000), 6c ($1,500), and 7b ($500) to its total revenue of $50,000 and determined that its gross receipts for the tax year were $54,000.

To determine whether an organization’s gross receipts are normally $50,000 or less, apply the following test. An organization’s gross receipts are considered to be normally $50,000 or less if the organization is:

1. Up to a year old and has received, or donors have pledged to give, $75,000 or less during its first tax year;

2. Between 1 and 3 years old and averaged $60,000 or less in gross receipts during each of its first 2 tax years; or

3. Three years old or more and averaged $50,000 or less in gross receipts for the immediately preceding 3 tax years (including the year for which the return would be filed).

If the organization’s gross receipts are normally $50,000 or less, it must submit Form 990-N, Electronic Notice (e-Postcard) for Tax-Exempt Organizations Not Required to File Form 990 or 990-EZ, if it chooses not to file Form 990 or 990-EZ. In general, organizations excepted from filing Form 990 or 990-EZ because of low gross receipts must submit Form 990-N. See filing exceptions described under General Instructions, Section B, earlier.

To determine whether an organization’s gross receipts are normally $5,000 or less, apply the following test. An organization’s gross receipts are considered to be normally $5,000 or less if the organization is:

1. Up to a year old and has received, or donors have pledged to give, $7,500 or less during its first tax year;

2. Between 1 and 3 years old and averaged $6,000 or less in gross receipts during each of its first 2 tax years; or

3. Three years old or more and averaged $5,000 or less in gross receipts for the immediately preceding 3 tax years (including the year for which the return would be filed).

Section 501(c)(7) organizations (social clubs) and section 501(c)(15) organizations (insurance companies) apply the same gross receipts test as other organizations to determine whether they must file Form 990 or 990-EZ. However, section 501(c)(7) and section 501(c)(15) organizations are also subject to separate gross receipts tests to determine whether they qualify as tax exempt for the tax year. The following tests use a special definition of gross receipts for purposes of determining whether these organizations are exempt for a particular tax year.

Section 501(c)(7). A section 501(c)(7) organization can receive up to 35% of its gross receipts, including investment income, from sources outside its membership and remain tax exempt. Part of the 35% (up to 15% of gross receipts) can be from public use of a social club’s facilities.

Gross receipts, for purposes of determining the tax-exempt status of section 501(c)(7) organizations, are the club’s income from its usual activities and include:

• Charges;

• Admissions;

• Membership fees;

• Dues;

• Assessments; and

2025 Instructions for Form 990 77

• Investment income (dividends, rents, and similar receipts), and normal recurring capital gains on investments.

Gross receipts for this purpose don’t include capital contributions (see Regulations section 1.118-1), initiation fees, or unusual amounts of income (the sale of the clubhouse).

Caution: College fraternities or sororities or other organizations that charge membership initiation fees, but not annual dues, must include initiation fees in their gross receipts.

Section 501(c)(15). If any section 501(c)(15) insurance company (other than life insurance) meets both parts of the following test, then the company can file Form 990 (or Form 990-EZ, if applicable).

1. The company’s gross receipts must be equal to or less than $600,000.

2. The company’s premiums must be more than 50% of its gross receipts.

If the company didn’t meet this test and the company is a mutual insurance company, then it must meet the Alternate test next to qualify to file Form 990 (or Form 990-EZ, if applicable). See Notice 2006-42, 2006-19 I.R.B. 878. Insurance companies that don’t qualify as tax exempt must file Form 1120-PC, U.S. Property and Casualty Insurance Company Income Tax Return, or (if the company isn't entitled to insurance reserves) Form 1120, U.S. Corporation Income Tax Return, as taxable entities for the year.

Alternate test. If any section 501(c) (15) insurance company (other than life insurance) is a mutual insurance company and it didn’t meet the above test, then the company must meet both parts of the following alternate test.

1. The company’s gross receipts must be equal to or less than $150,000.

2. The company’s premiums must be more than 35% of its gross receipts.

If the company doesn’t meet either test, then it must file Form 1120-PC or Form 1120 (if the company isn’t entitled to insurance reserves) instead of Form 990 or 990-EZ.

Caution: The alternate test doesn’t apply if any employee of the mutual insurance company or a member of the employee’s family is an employee of another company that is exempt under section 501(c)(15) (or would be exempt if this provision didn’t apply).

Gross receipts. To determine whether a section 501(c)(15) organization satisfies either of the above tests described in Appendix C, figure gross receipts by adding:

• An inspection of a return, report, notice, or exemption application at an IRS office.

1. Premiums (including deposits and assessments) without reduction for return premiums or premiums paid for reinsurance;

2. Gross investment income of a non-life insurance company (as described in section 834(b)); and

3. Other items that are included in the filer’s gross income under subchapter B, chapter 1, subtitle A, of the Code.

This definition doesn’t, however, include contributions to capital. For more information, see Notice 2006-42.

Premiums. Premiums consist of all amounts received as a result of entering into an insurance contract. They are reported on Form 990, Part VIII, line 2, or on Form 990-EZ, Part I, line 2.

Anti-abuse rule. The anti-abuse rule, found in section 501(c)(15)(C), explains how gross receipts (including premiums) from all members of a controlled group are aggregated in figuring the above tests.

Some members of the public rely on Form 990, or 990-EZ, as the primary or sole source of information about a particular organization. How the public perceives an organization in those cases may be determined by the information presented on its returns.

An organization’s completed Form 990 or 990-EZ is available for public inspection as required by section 6104. Schedule B (Form 990), Schedule of Contributors, is open for public inspection for section 527 organizations filing Form 990 or 990-EZ. For other organizations that file Form 990 or 990-EZ, the names and addresses of contributors listed on Schedule B aren’t required to be made available for public inspection. All other information reported on Schedule B, including the amount of contributions, the description of noncash contributions, and any other information, is required to be made available for public inspection unless it clearly identifies the contributor. Form 990-T filed after August 17, 2006, by a section 501(c)(3) organization to report any unrelated business income is also available for public inspection and disclosure.

Use Form 4506-A, Request for a Copy of Exempt or Political Organization IRS Form, to request:

• A copy of an exempt or political organization’s return, report, notice, or exemption application; or

Complete information is available on the IRS website at IRS.gov/Charities- Non-Profits/Copies-of-EO-Returns- Available .

The IRS can’t disclose portions of an exemption application relating to any trade secrets, etc. Additionally, the IRS generally can’t disclose the names and addresses of contributors. See the Instructions for Schedule B (Form 990) for more information about the disclosure of that schedule.

Notice 2008-49, 2008-20 I.R.B. 979, provides interim guidance regarding the requirement that section 501(c)(3) organizations and the IRS make Form 990-T available for public inspection.

Form 990 or 990-EZ can only be requested for section 527 organizations for tax years beginning after June 30, 2000.

A return, report, notice, or exemption application can be inspected at an IRS office free of charge. Copies of these items can also be obtained through the organization as discussed in the following section.

Public inspection and distribution of certain returns of unrelated business income. Section 501(c)(3) organizations that are required to file Form 990-T after August 17, 2006, must make Form 990-T available for public inspection under section 6104(d)(1)(A)(ii).

Public inspection and distribution of returns and reports for a political or- ganization. Section 527 political organizations required to file Form 990 or 990-EZ must, in general, make their Forms 8871, 8872, 990, or 990-EZ available for public inspection in the same manner as annual information returns of section 501(c) organizations are made available. See Public inspection and distribution of applications for tax exemption and annual information returns of tax-exempt organizations, later. Generally, Form 8871 and Form 8872 are available for inspection and printing at IRS.gov/Charities-and-Nonprofits .

Public inspection and distribution of applications for tax exemption and annual information returns of tax-ex- empt organizations. Under Regulations sections 301.6104(d)-1 through -3, a tax-exempt organization must:

• Make its application for recognition of exemption and its annual information returns available for public inspection without charge at its principal, regional, and district offices during regular business hours;

78 2025 Instructions for Form 990

• Make each annual information return available for a period of 3 years beginning on the date the return is required to be filed (determined with regard to any extension of time for filing) or is actually filed, whichever is later; and

• Provide a copy without charge (for Form 990-T, this requirement applies only to Forms 990-T filed after August 17, 2006), other than a reasonable fee for reproduction and actual postage costs, of all or any part of any application or return required to be made available for public inspection to any individual who makes a request for a copy in person or in writing (except as provided in Regulations sections 301.6104(d)-2 and -3).

Tax-exempt organization is any organization that is described in section 501(c) or (d) and is exempt from taxation under section 501(a). The term “tax-exempt organization” also includes any section 4947(a)(1) nonexempt charitable trust or nonexempt private foundation that is subject to the reporting requirements of section 6033.

statements, attachments, and supporting documents, except for the name and address of any contributor to the organization. See the Instructions for Schedule B (Form 990). However, statements, attachments, and supporting documents filed with Form 990-T that don’t relate to the imposition of unrelated business income tax aren’t required to be made available for public inspection and copying. See Notice 2008-49.

Annual returns more than 3 years old. An annual information return doesn’t include any return after the expiration of 3 years from the date the return is required to be filed (including any extension of time that has been granted for filing the return) or is actually filed, whichever is later.

a request for inspection (normally not more than 2 weeks) and at a reasonable time of day;

• Can mail, within 2 weeks of receiving the request, a copy of its application for tax exemption and annual information returns to the requester instead of allowing an inspection; and

• Can charge the requester for copying and actual postage costs only if the requester consents to the charge.

An organization that has a permanent office, but has no office hours, or very limited hours during certain times of the year, must make its documents available during those periods when office hours are limited, or not available, as though it were an organization without a permanent office.

Time and place for providing copies in response to requests made in person. A tax-exempt organization must:

• Provide copies of required documents under section 6104(d) in response to a request made in person at its principal, regional, and district offices during regular business hours; and

Application for tax exemption includes:

• Any prescribed application form (Form 1023, 1023-EZ, 1024, or 1024-A),

• All documents and statements the IRS requires an applicant to file with the form,

If an organization files an amended return, however, the amended return must be made available for a period of 3 years beginning on the date it is filed with the IRS.

Local or subordinate organizations. For rules relating to annual information returns of local or subordinate organizations, see Regulations section 301.6104(d)-1(f)(2). Regional or district offices. A regional or district office is any office of a tax-exempt organization, other than its principal office, that has paid employees, whether part-time or full-time, whose aggregate number of paid hours a week is normally at least 120.

• Provide copies to a requester on the day the request is made, except for unusual circumstances (explained next).

• Any statement or other supporting document submitted in support of the application, and

• Any letter or other document issued by the IRS concerning the application.

A site isn’t considered a regional or district office, however, if:

Unusual circumstances. In the case of an in-person request, where unusual circumstances exist so that fulfilling the request on the same business day causes an unreasonable burden to the tax-exempt organization, the organization must provide the copies no later than the next business day following the day that the unusual circumstances cease to exist, or the 5th business day after the date of the request, whichever occurs first.

Application for tax exemption doesn’t include:

• Any application for tax exemption filed before July 15, 1987, unless the organization filing the application had a copy of the application on July 15, 1987;

• In the case of a tax-exempt organization other than a private foundation, the name and address of any contributor to the organization; or

• The only services provided at the site further exempt purposes (daycare, health care, scientific or medical research); and

• The site doesn’t serve as an office for management staff, other than managers who are involved solely in managing the exempt function activities at the site.

• Any material that isn’t available for public inspection under section 6104.

Unusual circumstances include:

• Requests received that exceed the organization’s daily capacity to make copies;

Caution: If there is no prescribed application form, see Regulations section 301.6104(d)-1(b)(3)(ii). Annual information return includes:

• An exact copy of the Form 990 or 990-EZ filed by a tax-exempt organization as required by section 6033,

• Any amended return the organization files with the IRS after the date the original return is filed (both the original and amended return are subject to the public inspection requirements), or

• An exact copy of Form 990-T if one is filed by a section 501(c)(3) organization.

The copy must include all information furnished to the IRS on Form 990, 990-EZ, or 990-T as well as all

Permissible conditions on public inspection. A tax-exempt organization:

• Can have an employee present in the room during an inspection;

• Must allow the individual conducting the inspection to take notes freely during the inspection; and

• Must allow the individual to photocopy the document at no charge, if the individual provides photocopying equipment at the place of inspection.

• Must permit public inspection within a reasonable amount of time after receiving

• Requests received shortly before the end of regular business hours that require an extensive amount of copying; or

• Requests received on a day when the organization’s managerial staff capable of fulfilling the request is conducting special duties (student registration or attending an off-site meeting or convention), rather than its regular administrative duties.

Organizations that don’t maintain permanent offices. A tax-exempt organization with no permanent office:

• Must make its application for tax exemption and its annual information returns available for inspection at a reasonable location of its choice;

Agents for providing copies. For rules relating to use of agents to provide copies, see Regulations sections 301.6104(d)-1(d)(1)(iii) and -1(d)(2)(ii) (C).

Request for copies in writing. A tax-exempt organization must honor a written request for a copy of documents

2025 Instructions for Form 990 79

(or the requested part) required under section 6104(d) if the request:

1. Is addressed to (and delivered by mail, electronic mail, fax, or a private

delivery service, as defined in section 7502(f)) a principal, regional, or district office of the organization; and

2. Sets forth the address to which the copy of the documents should be sent.

Request for a copy of parts of a document. A tax-exempt organization must fulfill a request for a copy of the organization’s entire application for tax exemption or annual information return or any specific part or schedule of its application or return. A request for a copy of less than the entire application or less than the entire return must specifically identify the requested part or schedule.

Fees for copies. A tax-exempt organization can charge a reasonable fee for providing copies. Before the organization provides the documents, it can require that the individual requesting copies of the documents pay the fee. If the organization has provided an individual making a request with notice of the fee, and the individual doesn’t pay the fee within 30 days, or if the individual pays the fee by check and the check doesn’t clear upon deposit, the organization can disregard the request.

Form of payment. a. Request made in person. If a tax-exempt organization charges a fee for copying, it must accept payment by cash and money order for requests made in person. The organization can accept other forms of payment, such as credit cards and personal checks.

b. Request made in writing. If a tax-exempt organization charges a fee for copying and postage, it must accept payment by certified check, money order, and either personal check or credit card for requests made in writing. The organization can accept other forms of payment.

Avoidance of unexpected fees. Where a tax-exempt organization doesn’t require prepayment and a requester doesn’t enclose payment with a request, an organization must receive consent from a requester before providing copies

for which the fee charged for copying and postage exceeds $20.

Documents to be provided by regional and district offices. Except as otherwise provided, a regional or district office of a tax-exempt organization must satisfy the same rules as the principal office for allowing public inspection and providing copies of its application for tax exemption and annual information returns.

A regional or district office isn’t required, however, to make its annual information return available for inspection or to provide copies until 30 days after the date the return is required to be filed (including any extension of time that is granted for filing the return) or is actually filed, whichever is later.

Applications for tax exemption. Except as otherwise provided, a tax-exempt organization that didn’t file its own application for tax exemption (because it is a local or subordinate organization covered by a group exemption letter) must, upon request, make available for public inspection, or provide copies of, the application submitted to the IRS by the central or parent organization to obtain the group exemption letter and those documents which were submitted by the central or parent organization to include the local or subordinate organization in the group exemption letter.

However, if the central or parent organization submits to the IRS a list or directory of local or subordinate organizations covered by the group

exemption letter, the local or subordinate organization is required to provide only the application for the group exemption ruling and the pages of the list or directory that specifically refer to it. The local or subordinate organization must permit public inspection, or comply with a request for copies made in person, within a reasonable amount of time (normally not more than 2 weeks) after receiving a request made in person for public inspection or copies and at a reasonable time of day. See Regulations section 301.6104(d)-1(f) for further information. Annual information returns. A local or subordinate organization that doesn’t file its own annual information return (because it is affiliated with a central or parent organization that files a group return) must, upon request, make available for public inspection, or provide copies of, the group returns filed by the central or parent organization.

However, if the group return includes separate statements for each local or subordinate organization included in the group return, the local or subordinate organization receiving the request can omit any statements relating only to other organizations included in the group return.

The local or subordinate organization must permit public inspection, or comply with a request for copies made in person, within a reasonable amount of time (normally not more than 2 weeks) after receiving a request made in person for public inspection or copies and at a reasonable time of day.

When a requester seeks inspection, the local or subordinate organization can:

• Mail a copy of the applicable documents to the requester within the

80 2025 Instructions for Form 990

relevant facts and circumstances such as:

A tax-exempt organization can disregard any request for copies of all or part of any document beyond the first two received within any 30-day period or the first four received within any 1-year period from the same individual or the same address, whether or not the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) has determined that the organization is subject to a harassment campaign.

A tax-exempt organization can apply for a determination that it is the subject of a harassment campaign and that compliance with requests that are part of the campaign wouldn’t be in the public interest by submitting a signed application to the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes). See Rev. Proc. 2025-1, 2025-1 I.R.B. 1, or as updated annually.

In addition, the organization can suspend compliance with any request it reasonably believes to be part of the harassment campaign until it receives a response to its application for a harassment campaign determination. However, if the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) determines that the organization didn’t have a reasonable basis for requesting a determination that it was subject to a harassment campaign or reasonable belief that a request was part of the campaign, the officer, director, trustee, employee, or other responsible individual of the organization remains liable for any penalties for not providing the copies in a timely fashion. See Regulations section 301.6104(d)-3.

Except where otherwise instructed, where a line calls for a dollar amount or numerical data, the central organization

same time period instead of allowing an inspection; and

• Charge the requester for copying and actual postage costs, if the requester consents to the charge.

If the local or subordinate organization receives a written request for a copy of its annual information return, it must fulfill the request by providing a copy of the group return in the time and manner specified under Request for copies in writing, earlier.

The requester has the option of requesting from the central or parent organization, at its principal office, inspection or copies of group returns filed by the central or parent organization. The central or parent organization must fulfill the requests in the time and manner specified under Special Rules Relating to Public Inspection and Special Rules Relating to Copies, earlier.

Failure to comply. Any person who doesn’t comply with the public inspection requirements will be assessed a penalty of $25 for each day that inspection wasn’t permitted, up to a maximum of $13,000 for each return. The penalties for failure to comply with the public inspection requirements for applications are the same as those for annual returns, except that the $13,000 limitation doesn’t apply (sections 6652(c)(1)(C) and (D)). Any person who willfully fails to comply with the public inspection requirements for annual returns or exemption applications will be subject to an additional penalty of $5,000 (section 6685).

Making Applications and Returns Widely Available A tax-exempt organization isn’t required to comply with a request for a copy of its application for tax exemption or an annual information return if the organization has made the requested document widely available (see below).

An organization that makes its application for tax exemption and/or its annual information return widely available must also make the document available for public inspection, as required under Regulations section 301.6104(d)-1(a).

A tax-exempt organization makes its application for tax exemption and/or an annual information return widely available if the organization complies with the Internet posting requirements and the notice requirements given below.

Internet posting. A tax-exempt organization can make its application for tax exemption and/or an annual information return widely available by posting the document on a web page that the tax-exempt organization establishes and maintains, or by having the document posted, as part of a database of similar documents of other tax-exempt

organizations, on a web page established and maintained by another entity. The document will be considered widely available only if:

• The web page through which it is available clearly informs readers that the document is available and provides instructions for downloading it;

• The document is posted in a format that, when accessed, downloaded, viewed, and printed in hard copy, exactly reproduces the image of the application for tax exemption or annual information return as it was originally filed with the IRS, except for any information permitted by statute to be withheld from public disclosure; and

• Any individual with access to the Internet can access, download, view, and print the document without special computer hardware or software required for that format (other than software that is readily available to members of the public without payment of any fee) and without payment of a fee to the tax-exempt organization or to another entity maintaining the web page.

Reliability and accuracy. In order for the document to be widely available through an Internet posting, the entity maintaining the web page must have procedures for ensuring the reliability and accuracy of the document that it posts on the page and must take reasonable precautions to prevent alteration, destruction, or accidental loss of the document when posted on its page. In the event that a posted document is altered, destroyed, or lost, the entity must correct or replace the document.

Notice requirement. If a tax-exempt organization has made its application for tax exemption and/or an annual information return widely available, it must notify any individual requesting a copy where the documents are available (including the address on the Internet, if applicable). If the request is made in person, the organization must provide the notice to the individual immediately. If the request is made in writing, the notice must be provided within 7 days of receiving the request.

• A sudden increase in requests,

• An extraordinary number of requests by form letters or similarly worded correspondence,

• Hostile requests,

• Evidence showing bad faith or deterrence of the organization’s exempt purpose,

• Prior provision of the requested documents to the purported harassing group, and

• A demonstration that the organization routinely provides copies of its documents upon request.

Tax-Exempt Organization Subject to Harassment Campaign Under section 6104(d)(4), if the Office of Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment Taxes) determines that the organization is being harassed, a tax-exempt organization isn’t required to comply with any request for copies that it reasonably believes is part of a harassment campaign.

Whether a group of requests is a harassment campaign depends on the

2025 Instructions for Form 990 81

maintained by the central organization that subordinates are required to adopt.

13. Part VI, line 5. Significant diversion of assets. In determining whether a diversion of a subordinate’s assets meets the 5%/$250,000 reporting threshold, consider only the total assets and gross receipts of that subordinate, not of the parent or other subordinates.

14. Part VI, line 20. Person who possesses books and records. Identify the person who possesses the information furnished by the subordinate organizations used in compiling the group return.

15. Part VII. Compensation of officers, directors, trustees, key employees, and highest compensated employees. File a single consolidated Form 990, Part VII, showing the officers, directors, trustees, and key employees of each subordinate included in the group return, and a single consolidated Schedule J (Form 990), Part II, for all officers, directors, trustees, and key employees above the compensation thresholds. Report the five highest compensated employees and independent contractors above $100,000 for the whole group of subordinates, not for each subordinate. If one or more officers, directors, trustees, key employees, or highest compensated employees received compensation from more than one organization in the group, the person’s compensation from the several organizations must be reported in column (D).

16. Part VII. Compensation from related organizations. Report compensation from an organization that is included in the group ruling but that isn’t among the subordinates included in the group return as compensation from a related organization in column (E), even if the related organization isn’t required to be reported on Schedule R (Form 990), Related Organizations and Unrelated Partnerships.

17. Part XII, lines 2a–2b. Compiled, reviewed, or audited financial statements. Answer “Yes” only if all the subordinates in the group had their financial statements compiled, reviewed, or audited individually (rather than on a consolidated basis).

18. Schedule A (Form 990), Part I. Reason for public charity status. If the subordinates don’t all have the same public charity status, then check the public charity status box for the largest number of subordinates in the group, and explain on Schedule A (Form 990), Public Charity Status and Public Support, Part IV. However, if any section 509(a)(3) organizations are among the subordinates in the group return, also answer lines 12e through 12g.

filing the group return must aggregate the data from all the subordinate organizations included in the group return and report the aggregate number. For example, in answering Form 990, Part I, line 6, the total number of volunteers for all of the subordinate organizations would be reported.

For purposes of Form 990, Part III, summarize the mission and activities of all of the subordinate organizations as if all of the subordinate organizations were one entity.

In general, if a line requires a “Yes” or “No” answer and the answer isn’t the same for all subordinate organizations to which the line applies, then check “Yes” and explain the answer in the schedule’s supplemental information section (if applicable) or on Schedule O (Form 990). For the following lines, however, check “No” if the answer is “No” for any of the subordinates to which the line applies, and explain on Schedule O (Form 990).

• Form 990, Part V, lines 1c, 2b, 3b, 5c, 6b, 7b, 7g, and 7h.

• Form 990, Part VI, lines 8a, 8b, 10b, 12b, and 12c.

• Schedule C (Form 990), Political Campaign and Lobbying Activities, Part I-B, lines 3 and 4a.

• Schedule C (Form 990), Part I-C, line 4.

• Schedule C (Form 990), Part II-A, line 1j.

• Schedule C (Form 990), Part II-B, line 2d.

• Schedule C (Form 990), Part III-A, lines 1–3.

• Schedule D (Form 990), Supplemental Financial Statements, Part I, lines 5 and

• Schedule D (Form 990), Part II, lines 5 and 8.

• Schedule E (Form 990), Schools, lines 1–4d and 7.

• Schedule F (Form 990), Statement of Activities Outside the United States, Part I, line 1.

• Schedule G (Form 990), Supplemental Information Regarding Fundraising or Gaming Activities, Part III, line 9a.

• Schedule I (Form 990), Grants and Other Assistance to Organizations, Governments, and Individuals in the United States, Part I, line 1.

• Schedule J (Form 990), Compensation Information, Part I, lines 1b and 2.

• Schedule M (Form 990), Noncash Contributions, Part I, line 31.

• Schedule N (Form 990), Liquidation, Termination, Dissolution, or Significant Disposition of Assets, Part I, lines 3, 4a– b, 5, and 6a–c.

The following is a list of other special instructions for group returns.

1. Item B. Final return/terminated. If the central organization is terminating

its group exemption and filing its final group return, don’t check the “Final return/terminated” box. Refer to Rev. Proc. 80-27, 1980-1 C.B. 677, as modified, for procedures for terminating the group exemption.

2. Item C. Name. Enter the name of the group exemption. Note that the group exemption may have a different name than the central organization’s name.

3. Item D. EIN. Use the special EIN (separate from the central organization’s EIN) that is issued solely for the purposes of the group return. The central organization must have received a group exemption letter before it can file a group ruling.

4. Items E, F, and J. Enter information for the central organization only.

5. Item H. Group returns. If the organization answers “Yes” to item H(a) but “No” to item H(b) (not all subordinate organizations are included in the group return), then attach a list (not on Schedule O (Form 990)) showing the name, address, and EIN of each subordinate organization included in the group return. Additionally, attach a list (not on Schedule O (Form 990)) showing the name, address, and EIN of each subordinate organization not included in the group return. See Regulations section 1.6033-2(d)(2)(ii).

6. Item K. Form of organization. Check “Other” if the group has more than one form of organization.

7. Item L. Year of formation. Leave blank for group return.

8. Item M. State of legal domicile. Leave blank for group return.

9. Part IV, lines 14b–19, 21–22, and 29, dollar thresholds. Apply the dollar thresholds for the aggregate data for the group as a whole, not subordinate by subordinate.

10. Part IV, line 20. Hospitals. Answer “Yes” if any affiliate included within the group return operated a hospital facility.

11. Part VI, line 2. Relationships among officers, directors, trustees, and key employees. Describe on Schedule O (Form 990) only relationships between officers, directors, trustees, and key employees of the same subordinate organization, not relationships between officers, directors, trustees, and key employees of one subordinate and officers, directors, trustees, and key employees of another subordinate.

12. Part VI, line 4. Significant changes to organizational documents. Report only changes to standardized organizational documents

82 2025 Instructions for Form 990

branch or division of its parent organization for federal tax purposes (but see the Tip next for the treatment of disregarded entities as separate entities for employment tax purposes). Therefore, financial and other information applicable to a disregarded entity must be reported as the parent organization’s information, except on Form 990, Part VI, lines 10a and 10b, and on Schedule R (Form 990), in which disregarded entities must be separately reported.

An organization must report on its Form 990, including Parts VIII through X, all of the revenues, expenses, assets, liabilities, and net assets or funds of a disregarded entity of which it is the sole member. The disregarded entity is deemed to have the same accounting period as its parent for federal tax purposes. The organization must also report the activities of a disregarded entity in the appropriate parts (including schedules) of the Form 990. For example, support of a disregarded entity must be taken into account by the filing organization for purposes of the public support tests set forth on Schedule A (Form 990). Similarly, political campaign activity or lobbying activity conducted by a disregarded entity of which the organization is the sole member must be reported on Schedule C (Form 990).

Tip: A disregarded entity is treated as a separate entity for purposes of employment tax and certain excise taxes. For wages paid after January 1, 2009, a disregarded entity is required to use its name and EIN for reporting and payment of employment taxes.

Caution: A single-member LLC is treated generally as a disregarded entity of its sole member/owner unless it elects to be treated as a separate association. It may elect to be treated separately by filing Form 8832, Entity Classification Election, or by claiming tax-exempt status in its own right (by filing a Form 1023, 1023-EZ, 1024, or 1024-A, application for recognition of tax-exempt status, or a Form 990, 990-EZ, 990-N, or 990-T, using its own name and EIN). Once the IRS determines a single-member LLC to be exempt, it is no longer eligible to be treated as a disregarded entity until the determination of exemption is revoked and the LLC subsequently files a Form 8832 electing disregarded entity status. Similarly, a single-member LLC that claims exemption but hasn’t been determined to be exempt isn’t eligible to be treated as disregarded until the claim is withdrawn or rejected and the LLC files a Form 8832 electing disregarded entity status. See Regulations section 301.7701-3(c)(1)(v)(A).

19. Schedule A (Form 990), Parts II and III. Support statements. Report aggregate data for all subordinates with the public charity status corresponding to Part II or III.

20. Schedule A (Form 990), Parts IV through VI. In addition to Part I in paragraph 18 above, if any section 509(a) (3) organizations are among the subordinates in the group return, also complete the relevant sections of Parts IV and V. If an answer in Part IV requires more information with respect to any section 509(a)(3) organizations, then answer with respect to those organizations and provide that additional information in Part VI. For instance, if the group includes 50 section 509(a)(3) organizations, and one of them doesn’t list all of its supported organizations by name in its governing documents, then answer “No” on Part IV, Section A, line 1, and explain in Part VI. If the group includes more than one Type III non-functionally-integrated supporting organization, then provide aggregate data in Part V.

21. Schedule B (Form 990). Contributors. Report a consolidated Schedule B (Form 990) for all subordinates included in the group return. Apply the dollar and percentage thresholds (including the greater of $5,000 or 2% threshold for section 501(c) (3) organizations described in sections 509(a)(1) and 170(b)(1)(A)(vi)) subordinate by subordinate, not on a group basis.

22. Schedule C (Form 990), Part II-A. Lobbying expenditures and affiliated groups. Complete Part II-A, column (b), for the group as a whole. In column (a), except on lines 1g and 1h, include the amounts that apply to all electing members of the group if they are included in the group return. If the group return includes organizations that belong to more than one affiliated group, enter in column (b) the totals for all the groups.

23. Schedule D (Form 990), Part X. Other liabilities. The filing organization can summarize that portion, if any, of the FIN 48 (ASC 740) footnote that applies to the liability of multiple organizations including the organization (for example, as a member of a group with consolidated financial statements), to describe the filing organization’s share of the liability.

24. Schedule H (Form 990). Hospitals. Complete one Schedule H for all of the hospitals operated by subordinates in the group, and report aggregate data from all the hospitals. In Part V, Section A, list each of the organization’s hospital facilities separately. List in Section A the name and EIN of the subordinate hospital

organization that operates the hospital facility. Complete separate Sections B and C for each of the hospital facilities or facility reporting groups listed in Section A.

25. Schedule J (Form 990). Compensation from related organizations. See the Part VII instructions, earlier, in this Appendix.

26. Schedule L (Form 990). Transactions with interested persons. On Schedule L (Form 990), Part IV, report only transactions between a subordinate organization and its interested persons—not transactions between a subordinate organization and the interested persons of other subordinates. In determining whether a transaction between the subordinate and its interested persons meets the financial reporting thresholds of Schedule L, Part IV, consider only the payments between the subordinate and its interested persons, not payments between interested persons and the parent or other subordinates.

27. Schedule N (Form 990). Liquidation or significant disposition of assets. Explain on Schedule N (Form 990), Part III, which of the subordinates have undergone a liquidation, termination, dissolution, or significant disposition of assets during the tax year.

28. Schedule R (Form 990). Related organizations. See the Instructions for Schedule R (Form 990) to determine when related organizations of a member of a group exemption must be included on Schedule R (Form 990). In general, central organizations and subordinate organizations of a group exemption aren’t required to be listed as related organizations on Schedule R (Form 990), Part II; and all other related organizations of the central organization or of a subordinate organization are required to be listed on Schedule R (Form 990) in the applicable part. Even if a related organization isn’t required to be listed in Part II of Schedule R (Form 990), the organization must report its transactions with the related organization in Part V, as described in the instructions for that Part.

Disregarded Entities A disregarded entity, as described in Regulations sections 301.7701-1 through -3, is generally treated as a

2025 Instructions for Form 990 83

continues to operate. Transfers to (or by) a filing organization by (or to) its disregarded entity aren’t to be reported in Part II, but transfers by or contractions of a disregarded entity are to be taken into account to determine whether a reportable event (based on 25% of the filing organization’s net assets, including those of its disregarded entities) has occurred.

16. Schedule R (Form 990), Part V, line 2. Transactions with related organizations. Specified payments to a disregarded entity by a controlled entity of the filing organization, and transfers by a disregarded entity to an exempt noncharitable entity, are to be reported on Schedule R (Form 990), Part V, line 2.

If the organization participates as a partner or member of a joint venture, partnership, LLC, or other entity treated as a partnership for federal tax purposes (referred to here as a “joint venture”), as described in Regulations sections 301.7701-1 through -3, then the organization in general must report the activities of the joint venture as its own activities, and report the joint venture’s revenue, expenses, and assets, to the extent of the organization’s proportionate interest in the joint venture. For example, a proportionate share of the political campaign activity or lobbying activity conducted by a joint venture of which the organization is a member must be reported on Schedule C (Form 990). If the joint venture is a member of a second joint venture, which is a member of a third joint venture, etc., the activities similarly pass through all joint ventures to the organization, according to the organization’s proportionate share in each of the joint ventures.

The following is a list of special instructions for the form and schedules regarding the reporting of a joint venture of which the organization is a member.

1. Part I, line 2. Disposition of 25% of assets. See the instructions for Schedule N in this Appendix, later.

2. Part I, lines 7a–7b. Unrelated business income. Include the organization’s distributive share (whether or not distributed) of income or loss of the joint venture that is unrelated business income in determining the organization’s gross and net unrelated business income.

3. Part IV, lines 3–5. Political campaign and lobbying activities. See

The following is a list of special instructions for the form and schedules regarding the reporting of a disregarded entity of which the organization is the sole member. These items are described to illustrate special applications of the rule described above that a disregarded entity’s activities and items must be reported on the organization’s Form 990 and applicable schedules.

1. Part I, line 5. Number of employees. See the instructions for Part V, lines 1 and 2, below.

2. Part I, line 6. Number of volunteers. The total number of volunteers to be reported can, but isn’t required to, include volunteers of any disregarded entity.

3. Part III. Program service accomplishments. Consider activities and accomplishments of all disregarded entities when answering this part.

4. Part IV, line 12. Audited financial statements. The organization shouldn’t answer “Yes” to this question merely because it received audited financial statements of one or more disregarded entities, if the audited financial statements of the organization weren’t audited.

5. Part IV, lines 31–32. Liquidation or significant disposition of assets. See the instructions for Schedule N (Form 990) in this Appendix, later.

6. Part IV, lines 35–36. Transactions with related organizations. See the instructions for Schedule R (Form 990) in this Appendix, later.

7. Part V, lines 1–2. Forms 1096 and W-3. The total number of information returns and employees to be reported, and compliance with backup withholding rules, includes all backup withholding, information returns, and employees of any disregarded entity, whether or not the disregarded entity has a separate EIN for employment tax and information reporting purposes.

8. Part V, line 7. Organizations that can receive deductible contributions. For purposes of Form 990 reporting, lines 7a through 7h are to be answered by taking into account any contributions made to a disregarded entity.

9. Part VI, lines 1a–9. Members of the governing body, officers, directors, trustees, and employees of a disregarded entity won’t be treated as governing body members, officers, directors, or trustees of the filing organization, but a person can be a key employee or highest compensated employee of the filing organization by virtue of compensation paid by the disregarded entity, or the person’s responsibilities and authority over operations of the

disregarded entity when compared to the filing organization as a whole. See Disregarded entities under Part VII, Section A, earlier.

10. Part VI, Section B, lines 10a– 16b. Policies. The organization should check “Yes” or “No” based on the filing organization’s policies, but for each “Yes” response, they must report on Schedule O (Form 990) whether the policy applies to all of the organization’s disregarded entities (if any).

11. Part VII, line 1a. Definitions of key employee and highest compensated employee. An officer, director, trustee, and employee of a disregarded entity can constitute a key employee or highest compensated employee of the filing organization by virtue of compensation paid by the disregarded entity, or the person’s responsibilities and authority over operations of the disregarded entity when compared to the filing organization as a whole. See the instructions for Form 990, Part VII, Section A.

12. Part XII, lines 2a–2b. Financial statements. If the organization included financial information from its disregarded entity or entities in its financial statements, but didn’t consolidate any other entity’s information in its financial statements, it should check the box for “Separate basis” but not the box for “Consolidated basis” or “Both consolidated and separate basis.”

13. Part XII, line 3. Uniform Guidance, 2 CFR Part 200, Subpart F. The organization must check “Yes” if a disregarded entity was required to undergo an audit or audits.

Note: The Single Audit Act of 1984 and OMB Circular A-133 are superseded by Uniform Guidance, 2 CFR Part 200, Subpart F, and now requires states, local governments, and nonprofit organizations that spend $750,000 (previously $500,000) or more of federal awards in a year to obtain an annual audit.

14. Schedule L (Form 990). Transactions with interested persons. Reportable transactions include transactions involving interested persons who have such status because of their relationship with a disregarded entity (such as an employee of the disregarded entity who qualifies as a key employee of the organization as a whole). A transaction between an interested person and a disregarded entity of the organization is reportable on Schedule L.

15. Schedule N (Form 990). Liquidation or significant disposition of assets. The organization shouldn’t prepare Part I to report a termination, liquidation, or dissolution of a disregarded entity if the filing organization

84 2025 Instructions for Form 990

The intermediate sanction regulations are important to the exempt organization community as a whole, and for ensuring compliance in this area. The rules provide a roadmap by which an organization can steer clear of situations that may give rise to inurement.

Under section 4958, any disqualified person who benefits from an excess benefit transaction with an applicable tax-exempt organization is liable for a 25% tax on the excess benefit. The disqualified person is also liable for a 200% tax on the excess benefit if the excess benefit isn’t corrected by a certain date. Also, organization managers who participate in an excess benefit transaction knowingly, willfully, and without reasonable cause are liable for a 10% tax on the excess benefit, not to exceed $20,000 for all participating managers on each transaction.

These rules only apply to certain applicable section 501(c)(3), 501(c)(4), and 501(c)(29) organizations. An applicable tax-exempt organization is a section 501(c)(3), 501(c)(4), or 501(c) (29) organization that is tax exempt under section 501(a), or was an organization at any time during a 5-year period ending on the day of the excess benefit transaction .

An organization isn’t treated as a section 501(c)(3), 501(c)(4), or 501(c) (29) organization for any period covered by a final determination that the organization wasn’t tax exempt under section 501(a), so long as the determination wasn’t based on private inurement or one or more excess benefit transactions.

Most section 501(c)(3), 501(c)(4), or 501(c)(29) organization employees and independent contractors won’t be affected by these rules. Only the few influential persons within these organizations are covered by these rules

the instructions for Schedule C in this Appendix, later.

4. Part IV, line 7. Conservation easements. See the instructions for Schedule D in this Appendix, later.

5. Part IV, lines 14–16. Activities outside the United States. See the instructions for Schedule F in this Appendix, later.

6. Part IV, lines 17–19. Fundraising and gaming. See the instructions for Schedule G in this Appendix, later.

7. Part IV, line 20. Hospitals. See the instructions for Schedule H in this Appendix, later.

8. Part IV, lines 21–22. Grants in the United States. See the instructions for Schedule I in this Appendix, later.

9. Part IV, lines 26–28. Loans, grants, and business transactions involving interested persons. See the instructions for Schedule L in this Appendix, later.

10. Part IV, line 32. Disposition of 25% of assets. See the instructions for Schedule N in this Appendix, later.

11. Part IV, lines 34–37. Related organizations and unrelated partnerships. See the instructions for Schedule R in this Appendix, later.

12. Part V, line 3a. Unrelated business income. Include the organization’s distributive share (whether or not distributed) of income or loss of the joint venture that is unrelated business income in determining the organization’s gross unrelated business income.

13. Part VI. Governance, management, and disclosure. Don’t take into account a joint venture for purposes of Part VI (except for lines 16a and 16b).

14. Part VII. Compensation. See the instructions for Schedule J in this Appendix, later.

15. Parts VIII, IX, and X. Financial statements. Report in accordance with the organization’s books and records.

16. Part XII. Financial statements and reporting. Disregard a joint venture.

17. Schedule C (Form 990). Political campaign and lobbying activities. Report the organization’s share of political campaign or lobbying activities conducted by a joint venture.

18. Schedule D (Form 990), Part II. Conservation easements. Include conservation easements held by a joint venture formed for the purpose of holding the easements.

19. Schedule F (Form 990). Activities outside the United States. Include activities of a joint venture, including grants to organizations or individuals outside the United States.

20. Schedule G (Form 990). Fundraising and gaming. Include activities of a joint venture and the organization’s share of revenues and expenses. On Part III, line 12, check “Yes” if the joint venture was formed to administer charitable gaming.

21. Schedule H (Form 990). Hospitals. Report activities, expenses, and revenue of hospital facilities and other programs operated by any joint venture, to the extent of the organization’s proportionate interest in the joint venture. See the instructions for Schedule H, Part IV, to determine how to report an organization’s interest in joint ventures and management companies.

22. Schedule I (Form 990). Grants in the United States. Include grants from a joint venture to organizations, governments, or individuals in the United States.

23. Schedule J (Form 990). Compensation. If an officer, director, trustee, or employee of the organization receives compensation from a joint venture, the compensation isn’t treated as paid pro rata by the organization. The compensation may need to be reported, however, as compensation from a related organization if the joint venture is a related organization.

24. Schedule K (Form 990), Part III, line 1. Private business use. Report certain joint ventures that owned property financed by tax-exempt bonds .

25. Schedule L (Form 990), Parts II–IV. Loans, grants, and business transactions involving interested persons. Report loans, grants, and business transactions between the organization and a joint venture, if the joint venture is an interested person for purposes of Schedule L, and if the transaction meets the applicable reporting thresholds described in the Schedule L instructions. Also report certain joint ventures with interested persons as provided in the Schedule L, Part IV, instructions as business transactions themselves.

26. Schedule N (Form 990), Part II. Disposition of 25% of assets. In determining whether the organization made a disposition of more than 25% of its assets, take into account its share of dispositions by a joint venture.

27. Schedule R (Form 990). Related organizations. Report relationships with certain joint ventures in Parts III and VI, and certain transactions with joint ventures in Part V.

An applicable tax-exempt organization doesn’t include:

• A private foundation, as defined in section 509(a);

• A governmental entity that is exempt from (or not subject to) taxation without regard to section 501(a) or relieved from filing an annual return under Regulations section 1.6033-2(g)(6); and

• Certain foreign organizations .

2025 Instructions for Form 990 85

when they receive benefits, such as compensation, fringe benefits, or contract payments. The IRS calls this class of covered individuals disqualified persons .

A disqualified person, regarding any transaction, is any person 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. 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. This would include, for example, voting members of the governing body, and persons holding the power of the following.

organization as a whole or a discrete segment of the organization that represents a substantial portion of the activities, assets, income, or expenses of the organization, as compared to the organization as a whole.

What about persons who staff affili- ated organizations? In the case of multiple affiliated organizations, the determination of whether a person has substantial influence is made separately for each applicable tax-exempt organization. A person may be a disqualified person for more than one organization in the same transaction.

An excess benefit transaction is generally a transaction in which an economic benefit is provided by an applicable tax-exempt organization, directly or indirectly, to or for the use of any disqualified person, and the value of the economic benefit provided by the applicable tax-exempt organization exceeds the value of the consideration (including the performance of services) received for providing the benefit, but see the special rules below for donor advised funds and supporting organizations . An excess benefit transaction can also occur when a disqualified person embezzles from the exempt organization.

To determine whether an excess benefit transaction has occurred, all consideration and benefits exchanged between a disqualified person and the applicable tax-exempt organization, and all entities it controls, are taken into account.

For purposes of determining the value of economic benefits, the value of property, including the right to use property, is the FMV . FMV is 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.

Highly Compensated Employee
Benefits—Limitation Amounts

• 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.

• Presidents, CEOs, or chief operating officers.

• Treasurers and chief financial officers. A disqualified person also includes certain family members of a disqualified person, and 35% controlled entities of a disqualified person.

The following persons are considered disqualified persons for the following organizations, along with certain family members and 35% controlled entities associated with them.

• For a transaction involving a donor advised fund, a donor or donor advisor of that donor advised fund.

• For a donor advised fund sponsoring organization, an investment advisor of the sponsoring organization .

• For a supported organization of a section 509(a)(3) supporting organization, the disqualified persons of the section 509(a)(3) supporting organization .

See the instructions for Form 4720, Schedule I, for more information regarding these disqualified persons.

Who isn’t a disqualified person? The rules also clarify which persons aren’t considered to be in a position to exercise substantial influence over the affairs of an organization. They include:

• An employee who receives benefits that total less than the highly compensated amount (see below) and who doesn’t hold the executive or voting powers just mentioned, isn’t a family member of a disqualified person, and isn’t a substantial contributor;

• Tax-exempt organizations described in section 501(c)(3); and

Who else can be considered a dis- qualified person? Other persons not described above can also be considered disqualified persons, depending on all the relevant facts and circumstances.

Facts and circumstances tending to show substantial influence.

• The person founded the organization.

• The person is a substantial contributor to the organization under the section 507(d)(2)(A) definition, only taking into account contributions to the organization for the past 5 years.

• The person’s compensation is primarily based on revenues derived from the activities of the organization that the person controls.

• The person has or shares authority to control or determine a substantial portion of the organization’s capital expenditures, operating budget, or compensation for employees.

• The person manages a discrete segment or activity of the organization that represents a substantial portion of the activities, assets, income, or expenses of the organization, as compared to the organization as a whole.

• The person owns a controlling interest (measured by either vote or value) in a corporation, partnership, or trust that is a disqualified person.

• The person is a nonstock organization controlled directly or indirectly by one or more disqualified persons.

Facts and circumstances tending to show no substantial influence.

• The person is an independent contractor whose sole relationship to the organization is providing professional advice (without having decision-making authority) for transactions from which the independent contractor won’t economically benefit.

• The person has taken a vow of poverty.

• Any preferential treatment the person receives based on the size of the person’s donation is also offered to others making comparable widely solicited donations.

Donor advised funds. For a donor advised fund, an excess benefit transaction includes a grant, a loan, compensation, or similar payment from the fund to a:

• Section 501(c)(4) organizations for transactions engaged in with other section 501(c)(4) organizations.

• The direct supervisor of the person isn’t a disqualified person.

• The person doesn’t participate in any management decisions affecting the

For these transactions, the excess benefit is defined as the amount of the

86 2025 Instructions for Form 990

• All other compensatory benefits, whether or not included in gross income for income tax purposes.

Exception. To the extent the economic benefit is excluded from the disqualified person’s gross income for income tax purposes, the applicable tax-exempt organization isn’t required to indicate its intent to provide an economic benefit as compensation for services, for example, employer-provided health benefits and contributions to qualified plans under section 401(a).

What benefits are disregarded? The following economic benefits are disregarded for purposes of section 4958.

• Nontaxable fringe benefits. An economic benefit that is excluded from income under section 132.

• Benefits to volunteers. An economic benefit provided to a volunteer for the organization if the benefit is provided to the general public in exchange for a membership fee or contribution of $75 or less per year.

• Benefits to members or donors. An economic benefit provided to a member of an organization due to the payment of a membership fee, or to a donor as a result of a deductible contribution, if a significant number of nondisqualified

grant, loan, compensation, or similar payment. For additional information, see the Instructions for Form 4720.

Supporting organizations. For any supporting organization defined in section 509(a)(3), an excess benefit transaction includes grants, loans, compensation, or similar payment provided by the supporting organization to a:

• Taxable and nontaxable fringe benefits, except fringe benefits described in section 132.

• Foregone interest on loans.

• 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. 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)).

A substantial contributor is any person who contributed or bequeathed an aggregate of more than $5,000 to the organization, if that amount is more than 2% of the total contributions and bequests received by the organization before the end of the tax year of the organization in which the contribution or bequest is received by the organization from the person. A substantial contributor includes the grantor of a trust.

The excess benefit for substantial contributors and parties related to those contributors includes the amount of the grant, loan, compensation, or similar payment. For additional information, see the Instructions for Form 4720.

When does an excess benefit transac- tion usually occur? For federal income tax purposes, an excess benefit transaction occurs on the date the disqualified person receives the economic benefit from the organization. However, when a single contractual arrangement provides for a series of compensation payments or other payments to a disqualified person during the disqualified person’s tax year, any excess benefit transaction for these payments occurs on the last day of the disqualified person’s tax year.

In the case of the transfer of property subject to a substantial risk of forfeiture, or in the case of rights to future compensation or property, the transaction occurs on the date the property, or the rights to future compensation or property, isn’t subject to a substantial risk of forfeiture. Where the disqualified person elects to include an amount in gross income in the tax year of transfer under section 83(b), the excess benefit transaction occurs on the date the disqualified person receives the

economic benefit for federal income tax purposes.

Section 4958 applies only to post-September 1995 transactions. Section 4958 applies the general rules to excess benefit transactions occurring on or after September 14, 1995. Section 4958 doesn’t apply to any transaction occurring pursuant to a written contract that was binding on September 13, 1995, and at all times thereafter before the transaction occurs. The special rules relevant to transactions with donor advised funds and supporting organizations apply to transactions occurring after August 17, 2006, except that taxes on certain transactions between supporting organizations and their substantial contributors apply to transactions occurring on or after July 25, 2006.

Reasonable compensation is the valuation standard that is used to determine if there is an excess benefit in the exchange of a disqualified person’s services for compensation . Reasonable compensation is the value that would ordinarily be paid for like services by like enterprises under like circumstances. This is the section 162 standard that will apply in determining the reasonableness of compensation. The fact that a bonus or revenue-sharing arrangement is subject to a cap is a relevant factor in determining the reasonableness of compensation.

For determining the reasonableness of compensation, all items of compensation provided by an applicable tax-exempt organization in exchange for the performance of services are taken into account in determining the value of compensation (except for certain economic benefits that are disregarded, as discussed in What benefits are disregarded? in this Appendix, later). Items of compensation include the following.

Written intent required to treat bene- fits as compensation. An economic benefit isn’t treated as consideration for the performance of services unless the organization providing the benefit clearly indicates its intent to treat the benefit as compensation when the benefit is paid.

An applicable tax-exempt organization (or entity that it controls) is treated as clearly indicating its intent to provide an economic benefit as compensation for services only if the organization provides written substantiation that is contemporaneous with the transfer of the economic benefits under consideration. Ways to provide contemporaneous written substantiation of its intent to provide an economic benefit as compensation include the following.

• The organization produces a signed written employment contract.

• The organization reports the benefit as compensation on an original Form W-2, Form 1099, or Form 990, or on an amended form filed before the start of an IRS examination.

• The disqualified person reports the benefit as income on the person’s original Form 1040 or 1040-SR or on an amended form filed before the start of an IRS examination.

• All forms of cash and noncash compensation, including salary, fees, bonuses, severance payments, and deferred and noncash compensation.

• The payment of liability insurance premiums for, or the payment or reimbursement by the organization of, taxes or certain expenses under section 4958, unless excludable from income as a de minimis fringe benefit under section 132(a)(4). (A similar rule applies in the private foundation area.) Inclusion in compensation for purposes of determining reasonableness under section 4958 doesn’t control inclusion in income for income tax purposes.

2025 Instructions for Form 990 87

persons make similar payments or contributions and are offered a similar economic benefit.

• Benefits to a charitable beneficiary. An economic benefit provided to a person solely as a member of a charitable class that the applicable tax-exempt organization intends to benefit as part of the accomplishment of its exempt purpose.

• Benefits to a governmental unit. A transfer of an economic benefit to or for the use of a governmental unit, as defined in section 170(c)(1), if exclusively for public purposes.

Is there an exception for initial con- tracts? Section 4958 doesn’t apply to any fixed payment made to a person pursuant to an initial contract . This is a very important exception because it would potentially apply, for example, to all initial contracts with new, previously unrelated officers and contractors.

An initial contract is 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.

A fixed payment is an amount of cash or other property specified in the contract, or determined by a fixed formula that is specified in the contract, which is to be paid or transferred in exchange for the provision of specified services or property.

A fixed formula can, in general, incorporate an amount that depends upon future specified events or contingencies, as long as no one has discretion when calculating the amount of a payment or deciding whether to make a payment (such as a bonus).

Treatment as new contract. A binding written contract, providing that it can be terminated or canceled by the applicable tax-exempt organization without the other party’s consent (except as a result of substantial nonperformance) and without substantial penalty, is treated as a new contract, as of the earliest date that any termination or cancellation would be effective. Also, a contract in which there is a material change, which includes an extension or renewal of the contract (except for an extension or renewal resulting from the exercise of an option by the disqualified person), or a more than incidental change to the amount payable under the contract, is treated as a new contract as of the effective date of the material change. Treatment as a new contract can cause the contract to fall outside the initial contract exception, and it would thus be tested under the FMV standards of section 4958.

Payments under a compensation arrangement are presumed to be reasonable and the transfer of property (or right to use property) is presumed to be at FMV if the following three conditions are met.

1. The transaction is approved by an authorized body of the organization (or an entity it controls), which is composed of individuals who don’t have a conflict of interest concerning the transaction.

2. Before making its determination, the authorized body obtained and relied upon appropriate data as to comparability. There is a special safe harbor for small organizations. If the organization has gross receipts of less than $1 million, appropriate comparability data include data on compensation paid by three comparable organizations in the same or similar communities for similar services.

3. The authorized body adequately documents the basis for its determination concurrently with making that determination. The documentation should include:

a. The terms of the approved transaction and the date approved;

b. The members of the authorized body who were present during debate on the transaction that was approved and those who voted on it;

c. The comparability data obtained and relied upon by the authorized body and how the data was obtained;

d. Any actions by a member of the authorized body having a conflict of interest; and

e. Documentation of the basis for the determination before the later of the next meeting of the authorized body or 60 days after the final actions of the authorized body are taken, and approval of records as reasonable, accurate, and complete within a reasonable time thereafter.

Special rebuttable presumption rule for nonfixed payments. As a general rule, in the case of a nonfixed payment, no rebuttable presumption arises until the exact amount of the payment is determined, or a fixed formula for calculating the payment is specified, and the three requirements creating the presumption have been satisfied. However, if the authorized body approves an employment contract with a disqualified person that includes a nonfixed payment (for example, discretionary bonus) with a specified cap on the amount, the authorized body can establish a rebuttable presumption as to

the nonfixed payment when the employment contract is entered into by, in effect, assuming that the maximum amount payable under the contract will be paid, and satisfying the requirements giving rise to the rebuttable presumption for that maximum amount.

An IRS challenge to the presumption of reasonableness. The IRS can refute the presumption of reasonableness only if it develops sufficient contrary evidence to rebut the probative value of the comparability data relied upon by the authorized body. This provision gives taxpayers added protection if they faithfully find and use contemporaneous persuasive comparability data when they provide the benefits.

Organizations that don’t establish a presumption of reasonableness. An organization can still comply with section 4958 even if it didn’t establish a presumption of reasonableness. In some cases, an organization may find it impossible or impracticable to fully implement each step of the rebuttable presumption process. In those cases, the organization should try to implement as many steps as possible, in whole or in part, in order to substantiate the reasonableness of benefits as timely and as well as possible. If an organization doesn’t satisfy the requirements of the rebuttable presumption of reasonableness, a facts and circumstances approach will be followed, using established rules for determining reasonableness of compensation and benefit deductions in a manner similar to the established procedures for section 162 business expenses.

A disqualified person corrects an excess benefit transaction by undoing the excess benefit to the extent possible, and by taking any additional measures necessary to place the organization in a financial position not worse than that in which it would be if the disqualified person were dealing under the highest fiduciary standards. The organization isn’t required to rescind the underlying agreement; however, the parties may need to modify an ongoing contract for future payments.

A disqualified person corrects an excess benefit by making a payment in cash or cash equivalents equal to the correction amount to the applicable tax-exempt organization. The correction amount equals the excess benefit plus the interest on the excess benefit; the interest rate can be no lower than the applicable federal rate. There is an anti-abuse rule to prevent the disqualified person from effectively transferring property other than cash or cash equivalents.

Exception. For a correction of an excess benefit transaction described under Donor advised funds, earlier, no amount repaid in a manner prescribed by the IRS can be held in a donor advised fund.

Property. With the agreement of the applicable tax-exempt organization, a disqualified person can make a payment by returning the specific property previously transferred in the excess benefit transaction. The return of the property is considered a payment of cash (or cash equivalent) equal to the lesser of:

• The FMV of the property on the date the property is returned to the organization, or

• The FMV of the property on the date the excess benefit transaction occurred.

Insufficient payment. If the payment resulting from the return of the property is less than the correction amount, the disqualified person must make an additional cash payment to the organization equal to the difference.

Excess payment. If the payment resulting from the return of the property exceeds the correction amount described above, the organization can make a cash payment to the disqualified person equal to that difference.

The regulations make it clear that the IRS will apply the procedures of section 7611 when initiating and conducting any

inquiry or examination into whether an excess benefit transaction has occurred between a church and a disqualified person .

Proposed intermediate sanction regulations were issued in 1998. The proposed regulations had special provisions covering “any transaction in which the amount of any economic benefit provided to or for the use of a disqualified person is determined in whole or in part by the revenues of one or more activities of the organization”— so-called revenue-sharing transactions. Rather than setting forth additional rules on revenue-sharing transactions, the final regulations reserve this section. Consequently, until the IRS issues new regulations for this reserved section on revenue-sharing transactions, these transactions will be evaluated under the general rules (for example, the FMV standards) that apply to all contractual arrangements between applicable tax-exempt organizations and their disqualified persons.

Section 4958 doesn’t affect the substantive standards for tax exemption under section 501(c)(3), 501(c)(4), or 501(c)(29), including the requirements that the organization be organized and operated exclusively for exempt purposes, and that no part of its net earnings inure to the benefit of any private shareholder or individual. The legislative history indicates that in most instances, the imposition of this intermediate sanction will be in lieu of revocation. The IRS has indicated that the following factors will be considered (among other facts and circumstances) in determining whether to revoke an applicable tax-exempt organization’s exemption status where an excess benefit transaction has occurred.

• The size and scope of the organization’s regular and ongoing activities that further exempt purposes before and after the excess benefit transaction or transactions occurred.

• The size and scope of the excess benefit transaction or transactions (collectively, if more than one) in relation to the size and scope of the organization’s regular and ongoing activities that further exempt purposes.

• Whether the organization has been involved in multiple excess benefit transactions with one or more persons.

2025 Instructions for Form 990 89

• Whether the organization has implemented safeguards that are reasonably calculated to prevent excess benefit transactions.

• Whether the excess benefit transaction has been corrected, or the organization has made good-faith efforts to seek correction from the disqualified person(s) who benefited from the excess benefit transaction.

How To Get Tax Help

the policy year or plan year to which the fee applies.

Form 926. Return by a U.S. Transferor of Property to a Foreign Corporation.

Form 940. Employer’s Annual Federal Unemployment (FUTA) Tax Return.

Form 941. Employer’s QUARTERLY Federal Tax Return. Used to report social security, Medicare, and income taxes withheld by an employer and social security and Medicare taxes paid by an employer.

Form 943. Employer’s Annual Federal Tax Return for Agricultural Employees.

Form 990-T. Exempt Organization Business Income Tax Return. Filed separately for organizations subject to UBTI that have total gross income from all of their unrelated trades or businesses of $1,000 or more for the tax year. The Form 990-T is also filed to pay the section 6033(e)(2) proxy tax. For Form 990, see Part V, line 3, and its instructions; for Form 990-EZ, see Part V, line 35, and its instructions.

Form 1023. Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code.

Form 1023-EZ. Streamlined Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code.

Form 1024. Application for Recognition of Exemption Under Section 501(a).

Form 1024-A. Application for Recognition of Exemption Under Section 501(c)(4) of the Internal Revenue Code.

Form 1040. U.S. Individual Income Tax Return.

Form 1040-SR. U.S. Tax Return for Seniors.

Form 1041. U.S. Income Tax Return for Estates and Trusts. Required of section 4947(a)(1) nonexempt charitable trusts that also file Form 990 or 990-EZ. However, if the trust doesn’t have any taxable income under subtitle A of the Code, it can file Form 990 or 990-EZ and doesn’t have to file Form 1041 to meet its section 6012 filing requirement. If this condition is met, complete Form 990 or 990-EZ and don’t file Form 1041.

Form 1096. Annual Summary and Transmittal of U.S. Information Returns.

Form 1098 series. Information returns to report mortgage interest, student loan interest, qualified tuition and related expenses received, and a contribution of a qualified vehicle that has a claimed value of more than $500.

Form 1099 series. Information returns to report acquisitions or abandonments of

Getting answers to your tax ques- tions. On IRS.gov, you can get up-to-date information on current events and changes in tax law.

• IRS.gov/Help : A variety of tools to help you get answers to some of the most common tax questions.

• IRS.gov/ITA : The Interactive Tax Assistant, a tool that will ask you questions and, based on your input, provide answers on a number of tax topics.

• IRS.gov/Forms : Find forms, instructions, and publications. You will find details on the most recent tax changes and interactive links to help you find answers to your questions.

• The Online EIN Application ( IRS.gov/ EIN ) helps you get an employer

identification number (EIN) at no cost.

• You may also be able to access tax law information in your e-filing software.

Getting tax forms and publications. Go to IRS.gov/Forms to view, download, or print all of the forms, instructions, and publications you may need. Or you can go to IRS.gov/OrderForms to place an order.

Getting tax publications and instruc- tions in eBook format. Download and view most popular tax publications and instructions (including the Instructions for Form 1040) on mobile devices as eBooks at IRS.gov/eBooks .

IRS eBooks have been tested using Apple’s iBooks for iPad. Our eBooks haven’t been tested on other dedicated eBook readers, and eBook functionality may not operate as intended.

Phone. If you have questions and/or need help completing Form 990 or 990-EZ, call 877-829-5500. This toll-free telephone service is available Monday through Friday.

Other Forms That May Be Required

Schedule A (Form 990). Public Charity Status and Public Support.

Schedule B (Form 990). Schedule of Contributors.

Schedule C (Form 990). Political Campaign and Lobbying Activities.

Schedule D (Form 990). Supplemental Financial Statements.

Schedule E (Form 990). Schools.

Schedule F (Form 990). Statement of Activities Outside the United States.

Schedule G (Form 990). Supplemental Information Regarding Fundraising or Gaming Activities.

Schedule H (Form 990). Hospitals.

Schedule I (Form 990). Grants and Other Assistance to Organizations, Governments, and Individuals in the United States.

Schedule J (Form 990). Compensation Information.

Schedule K (Form 990). Supplemental Information on Tax-Exempt Bonds.

Schedule L (Form 990). Transactions With Interested Persons.

Schedule M (Form 990). Noncash Contributions.

Schedule N (Form 990). Liquidation, Termination, Dissolution, or Significant Disposition of Assets.

Schedule O (Form 990). Supplemental Information to Form 990 or 990-EZ.

Schedule R (Form 990). Related Organizations and Unrelated Partnerships.

Forms W-2 and W-3. Wage and Tax Statement; and Transmittal of Wage and Tax Statements.

Form W-9. Request for Taxpayer Identification Number and Certification.

Form 720. Quarterly Federal Excise Tax Return.

Caution: The Patient-Centered Outcomes Research fee is imposed on issuers of specified health insurance policies (section 4375) and plan sponsors of applicable self-insured health plans (section 4376) for policy and plan years ending on or after October 1, 2012. See Form 720 and section 4376 for more information.

In addition to various federal excise taxes that are paid with the filing of Form 720, the Patient-Centered Outcomes Research fee that is imposed on issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans is payable annually and reported on the Form 720 that is filed for the second quarter of each year, which is due no later than July 31 of the calendar year immediately following the last day of

90 2025 Instructions for Form 990

Form 8871. Political Organization Notice of Section 527 Status.

Form 8872. Political Organization Report of Contributions and Expenditures.

Form 8886. Reportable Transaction Disclosure Statement.

Form 8886-T. Disclosure by Tax-Exempt Entity Regarding Prohibited Tax Shelter Transaction.

Form 8899. Notice of Income From Donated Intellectual Property. Used to report net income from qualified intellectual property to the IRS and the donor.

Form 8940. Request for Miscellaneous Determination.

Form 8976. Notice of Intent to Operate Under Section 501(c)(4).

Form SS-4. Application for Employer Identification Number.

FinCEN Form 114. Report of Foreign Bank and Financial Accounts.

Helpful Publications

Pub. 15. (Circular E), Employer’s Tax Guide.

Caution: Trust fund recovery penalty. If certain excise, income, social security, and Medicare taxes that must be collected or withheld aren’t collected or withheld, or these taxes aren’t paid to the IRS, the trust fund recovery penalty can apply. The trust fund recovery penalty can be imposed on all persons (including volunteers) who the IRS determines were responsible for collecting, accounting for, and paying over these taxes, and who acted willfully in not doing so.

This penalty doesn’t apply to volunteer unpaid members of any board of trustees or directors of a tax-exempt organization, if these members are solely serving in an honorary capacity, don’t participate in the day-to-day or financial activities of the organization, and don’t have actual knowledge of the failure to collect, account for, and pay over these taxes. However, the preceding sentence doesn’t apply if it results in no person being liable for the penalty.

The penalty is equal to the unpaid trust fund tax. See Pub. 15 (Circular E) for more details, including the definition of responsible persons.

Pub. 15-A. Employer’s Supplemental Tax Guide.

Pub. 463. Travel, Gift, and Car Expenses.

Pub. 525. Taxable and Nontaxable Income.

secured property; proceeds from broker and barter exchange transactions; cancellation of debt; dividends and distributions; certain government and state qualified tuition program payments; taxable distributions from cooperatives; interest payments; payments of long-term care and accelerated death benefits; miscellaneous income payments; distributions from an HSA, Archer MSA, or Medicare Advantage MSA; original issue discount; distributions from pensions, annuities, retirement or profit-sharing plans, IRAs, insurance contracts, etc.; and proceeds from real estate transactions. Also, use certain of these returns to report amounts that were received as a nominee on behalf of another person.

Form 1120-POL. U.S. Income Tax Return for Certain Political Organizations.

Form 1128. Application To Adopt, Change, or Retain a Tax Year.

Form 2848. Power of Attorney and Declaration of Representative.

Form 3115. Application for Change in Accounting Method.

Form 3520. Annual Return To Report Transactions With Foreign Trusts and Receipt of Certain Foreign Gifts.

Form 4506. Request for Copy of Tax Return.

Form 4506-A. Request for a Copy of Exempt or Political Organization IRS Form.

Form 4562. Depreciation and Amortization.

Form 4720. Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code.

Form 5471. Information Return of U.S. Persons With Respect to Certain Foreign Corporations.

Form 5500. Annual Return/Report of Employee Benefit Plan. Employers who maintain pension, profit-sharing, or other funded deferred compensation plans are generally required to file Form 5500. This requirement applies whether or not the plan is qualified under the Internal Revenue Code and whether or not a deduction is claimed for the current tax year.

Form 5578. Annual Certification of Racial Nondiscrimination for a Private School Exempt From Federal Income Tax.

Form 5768. Election/Revocation of Election by an Eligible Section 501(c)(3) Organization To Make Expenditures To Influence Legislation.

Form 7004. Application for Automatic Extension of Time To File Certain

Business Income Tax, Information, and Other Returns.

Form 8038 series. Tax-exempt bonds.

Form 8274. Certification by Churches and Qualified Church-Controlled Organizations Electing Exemption From Employer Social Security and Medicare Taxes.

Form 8282. Donee Information Return. Required of the donee of charitable deduction property who sells, exchanges, or otherwise disposes of donated property within 3 years after receiving it. The form is also required of any successor donee who disposes of the charitable deduction property within 3 years after the date that the donor gave the property to the original donee. It doesn’t matter who gave the property to the successor donee. It may have been the original donee or another successor donee.

Form 8283. Noncash Charitable Contributions.

Form 8300. Report of Cash Payments Over $10,000 Received in a Trade or Business. Used to report cash amounts in excess of $10,000 that were received in a single transaction (or in two or more related transactions) in the course of a trade or business (as defined in section 162). However, if the organization receives a charitable cash contribution in excess of $10,000, it isn’t subject to the reporting requirement because the funds weren’t received in the course of a trade or business.

Form 8328. Carryforward Election of Unused Private Activity Bond Volume Cap.

Form 8718. User Fee for Exempt Organization Determination Letter Request.

Form 8821. Tax Information Authorization.

Form 8822-B. Change of Address or Responsible Party—Business. Used to notify the IRS of a change in mailing address that occurs after the return is filed.

Form 8868. Application for Extension of Time To File an Exempt Organization Return or Excise Taxes Related to Employee Benefit Plans.

Form 8870. Information Return for Transfers Associated With Certain Personal Benefit Contracts. Used to identify those personal benefit contracts for which funds were transferred to the organization, directly or indirectly, as well as the transferors for, and beneficiaries of, those contracts.

2025 Instructions for Form 990 91

Pub. 526. Charitable Contributions.

Pub. 538. Accounting Periods and Methods.

Pub. 557. Tax-Exempt Status for Your Organization.

Pub. 561. Determining the Value of Donated Property.

Pub. 598. Tax on Unrelated Business Income of Exempt Organizations.

Pub. 892. How to Appeal an IRS Determination on Tax-Exempt Status.

Pub. 946. How To Depreciate Property.

Pub. 1771. Charitable Contributions—Substantiation and Disclosure Requirements.

Pub. 1828. Tax Guide for Churches and Religious Organizations.

Pub. 3079. Tax-Exempt Organizations and Gaming.

Pub. 3386. Tax Guide for Veterans’ Organizations.

Pub. 3833. Disaster Relief, Providing Assistance Through Charitable Organizations.

Pub. 4220. Applying for 501(c)(3) Tax-Exempt Status.

Pub. 4221-PC. Compliance Guide for 501(c)(3) Public Charities.

Pub. 4221-PF. Compliance Guide for 501(c)(3) Private Foundations.

Pub. 4302. A Charity’s Guide to Vehicle Donation.

Pub. 4303. A Donor’s Guide to Vehicle Donation.

Pub. 4386. Compliance Checks.

Pub. 4573. Group Exemptions.

Some states and local governmental units will accept a copy of Form 990 or 990-EZ in place of all or part of their own financial report forms. The substitution applies primarily to section 501(c)(3) organizations, but some other types of section 501(c) organizations are also affected. If the organization uses Form 990 or 990-EZ to satisfy state or local filing requirements, such as those under state charitable solicitation acts, note the following discussions.

Determine state filing requirement. The organization can consult the appropriate officials of all states and other jurisdictions in which it does business to determine their specific filing

requirements. Doing business in a jurisdiction can include:

Each jurisdiction can require the additional material to be presented on forms they provide. The additional information shouldn’t be submitted with the Form 990 or 990-EZ filed with the IRS, unless included on Schedule O (Form 990).

Even if the Form 990 or 990-EZ that the organization files with the IRS is accepted by the IRS as complete, a copy of the same return filed with a state won’t fully satisfy that state’s filing requirement if (1) required information isn’t provided, including any of the additional information discussed in this Appendix; or (2) the state determines that the form wasn’t completed by following the applicable Form 990 or 990-EZ instructions or supplemental state instructions. In that case, the state may ask the organization to provide the missing information or to submit an amended return.

Use of audit guides may be required. To ensure that all organizations report similar transactions uniformly, many states require that contributions, gifts, grants, similar amounts, and functional expenses be reported according to the AICPA Audit and Accounting Guide,

• Soliciting contributions or grants by mail or otherwise from individuals, businesses, or other charitable organizations;

• Conducting programs;

• Having employees within that jurisdiction;

• Maintaining a checking account; or

• Owning or renting property there.

Monetary tests can differ. Some or all of the dollar limitations applicable to Form 990 or 990-EZ when filed with the IRS may not apply when using Form 990 or 990-EZ in place of state or local report forms. Examples of the IRS dollar limitations that don’t meet some state requirements are the normally $50,000 gross receipts minimum that creates an obligation to file with the IRS and the $100,000 minimum for listing independent contractors on Form 990, Part VII, Section B.

Additional information may be re- quired. State or local filing requirements can require the organization to attach to Form 990 or 990-EZ one or more of the following.

• Additional financial statements, such as a complete analysis of functional expenses or a statement of changes in net assets.

• Notes to financial statements.

• Additional financial statements.

• A report on the financial statements by an independent accountant.

• Answers to additional questions and other information.

Not-for-Profit Entities (2018), supplemented, as applicable, by the Standards of Accounting and Financial Reporting for Voluntary Health and Welfare Organizations issued jointly by the National Health Council, Inc., the National Assembly of Voluntary Health and Social Welfare Organizations, and the United Way of America (1998).

Donated services and facilities. Even though donated services and facilities may be reported as items of revenue and expense in certain circumstances, many states and the IRS don’t permit the inclusion of those amounts in Parts VIII and IX of Form 990, Part I of Form 990-EZ, or (except for donations by a governmental unit) Schedule A (Form 990). The optional reporting of donated services and facilities is discussed in the instructions for Part III of Form 990.

Amended returns. If the organization submits supplemental information or files an amended Form 990 or 990-EZ with the IRS, it must also send a copy of the information or amended return to any state with which it filed a copy of Form 990 or 990-EZ originally to meet that state’s filing requirement. If a state requires the organization to file an amended Form 990 or 990-EZ to correct conflicts with the Form 990 or 990-EZ instructions, the organization must also file an amended return with the IRS.

Method of accounting. Most states require that all amounts be reported based on the accrual method of accounting. See also General Instructions, Section D, earlier.

Time for filing can differ. The deadline for filing Form 990 or 990-EZ with the IRS differs from the time for filing reports with some states.

Public inspection. The Form 990 or 990-EZ information made available for public inspection by the IRS can differ from that made available by the states.

This Appendix discusses certain federal tax rules that apply to exempt organizations and donors for contributions. See also Pub. 526, Charitable Contributions; and Pub. 1771, Charitable Contributions—Substantiation and Disclosure Requirements.

Schedule B (Form 990). Many organizations that file Form 990, 990-EZ, or 990-PF must file Schedule B to report on tax-deductible and non-tax-deductible contributions. See Schedule B and its instructions to determine whether Schedule B must be filed, and for the public inspection rules applicable to that form.

92 2025 Instructions for Form 990

Solicitation of nondeductible contri- bution. See the instructions for Form 990, Part V, lines 6a and 6b, for rules on public notice of nondeductibility when soliciting nondeductible contributions.

Keeping fundraising records for tax-deductible contributions. A section 501(c) organization that is eligible to receive tax-deductible contributions under section 170(c) must keep sample copies of its fundraising materials, such as:

• Dues statements,

• Fundraising solicitations,

• Tickets,

• Receipts, or

• Other evidence of payments received in connection with fundraising activities.

IF... THEN...

the organization advertises its fundraising events

the organization uses radio, television, or Internet to solicit contributions

the organization uses outside fundraisers

it must keep samples of the advertising copy.

it must keep samples of scripts, transcripts, printouts of emails and web pages, or other evidence of solicitations in the media.

it must keep samples of the fundraising materials used by the outside fundraisers.

For each fundraising event, the organization must keep records to show the portion of any payment received from patrons that isn’t deductible, that is, the retail value of the goods or services received by the patrons. See Disclosure statement for quid pro quo contributions, later.

the Form 8283 and return it so the donor can get a charitable contribution deduction. The organization should keep a copy for its records. See Form 8283 for more details.

Qualified intellectual property. An organization described in section 170(c) (except a private foundation) that receives or accrues net income from a qualified intellectual property contribution must file Form 8899, Notice of Income From Donated Intellectual Property. See Form 990, Part V, line 7g. The organization must file Form 8899 for any tax year that includes any part of the 10-year period beginning on the date of contribution but not for any tax years in which the legal life of the qualified intellectual property has expired or the property failed to produce net income.

A donee organization reports all income from donated qualified intellectual property as income other than contributions (for example, royalty income from a patent). A donee isn’t required to report as contributions on Form 990 (including statements) any of the additional deductions claimed by donors under section 170(m)(1). See Pub. 526.

Motor vehicles, boats, and airplanes. Special rules apply to charitable contributions of motor vehicles, boats, or airplanes with a claimed value of more than $500. See Form 990, Part V, line 7h; section 170(f)(12); Pub. 4302, A Charity’s Guide to Vehicle Donation; and the Instructions for Form 1098-C, Contributions of Motor Vehicles, Boats, and Airplanes.

charitable contribution. See section 170(f)(8) and Regulations section 1.170A-13(f). A charitable organization that receives a payment made as a contribution is treated as the donee organization for this purpose even if the organization (according to the donor’s instructions or otherwise) distributes the amount received to one or more charities.

The organization’s acknowledgment must:

1. Be written;

2. Be contemporaneous;

3. State the amount of any cash it received;

4. State: a. Whether the organization gave the donor any intangible religious benefits (no valuation needed), and

b. Whether the organization gave the donor any goods or services in return for the donor’s contribution (a quid pro quo contribution); and

5. Describe goods or services the organization:

a. Received (no valuation needed), and

b. Gave (good-faith estimate of value needed).

If the organization accepts a contribution in the name of one of its activities or programs, then indicate the organization’s name in the acknowledgment as well as the program’s name. For example: “Thank you for your contribution of $300 to (organization’s name) made in the name of our Special Relief Fund program. No goods or services were provided in exchange for your contribution.”

Similarly, if a domestic organization owns and controls a domestic disregarded entity, and the disregarded entity receives a contribution, then indicate the organization’s name in the acknowledgment as well as the relationship with the disregarded entity. For example: “Thank you for your contribution of $300 to (organization’s name) made in the name of (name of disregarded entity), which is treated as a disregarded entity of (organization’s name) for federal tax purposes. No goods or services were provided in exchange for your contribution.” See Notice 2012-52, 2012-35 I.R.B. 317. Exception. The written acknowledgment need not include a good-faith estimate of value for goods or services given to the donor if they are:

1. Goods or services with insubstantial value,

2. Certain membership benefits,

3. Goods or services described in (1) or (2) given to the employees of a donor

Noncash contributions. Form 990 schedules. An organization may be required to file Schedule M to report certain noncash (property) contributions; see the instructions for Schedule M on who must file. Also, an organization that files Schedule B must report certain information on noncash contributions.

Dispositions of donated property. If an organization receives a charitable contribution of property and within 3 years sells, exchanges, or otherwise disposes of the property, the organization may need to file Form 8282, Donee Information Return. See Form 990, Part V, lines 7c and 7d.

Donated property over $5,000. If the organization received from a donor a partially completed Form 8283, Noncash Charitable Contributions, the donee organization should generally complete

Substantiation and disclosure requirements for charitable contributions.

Recordkeeping for cash, check, or other monetary charitable gifts. To deduct a contribution of a cash, check, or other monetary gift (regardless of the amount), a donor must maintain a bank record or a written communication from the donee organization showing the donee’s name, date, and amount of the contribution. See section 170(f)(17) and Regulations section 1.170A-15 for more information. In the case of a text message contribution, the donor’s phone bill meets the section 170(f)(17) recordkeeping requirement of a reliable written record if it shows the name of the donee organization and the date and amount of contribution.

Acknowledgment to substantiate charitable contributions. A donee organization should be aware that a donor of a charitable contribution of $250 or more (including a contribution of unreimbursed expenses) can’t take an income tax deduction unless the donor obtains the organization’s acknowledgment to substantiate the

2025 Instructions for Form 990 93

organization or the partners of a donor partnership, or

4. Intangible religious benefits.

These exceptions are defined below.

Disclosure statement for quid pro quo contributions. If the organization receives a quid pro quo contribution of more than $75, the organization must provide a disclosure statement to the donor. See section 6115.

The organization’s disclosure statement must:

1. Be written;

2. Estimate in good-faith the value of the organization’s goods or services given in return for the donor’s contribution;

3. Describe, but need not value, certain goods or services given to the donor’s employees or partners; and

4. Inform the donor that a charitable contribution deduction is limited as follows.

purchase a ticket for $15. For a $60 membership fee, however, members are offered free admission to any of the performances. H makes a payment of $350 and accepts this membership benefit. Because of the limited number of performances, the membership privilege can’t be exercised frequently. Therefore, G’s acknowledgment must describe the free admission benefit and estimate its value in good-faith.

Certain goods or services provided to donor’s employees or partners. Certain goods or services provided to employees of donor organizations or partners of donor partnerships may be disregarded for substantiation and disclosure purposes. Nevertheless, the donee organization’s disclosure statement must describe the goods or services. A good-faith estimate of value isn’t needed.

Example. Museum J offers a basic membership benefits package for $40. It includes free admission and a 10% gift shop discount. Corporation K makes a $50,000 payment to J and, in return, J offers K’s employees free admission, a T-shirt with J’s logo that costs J $4.50, and a 25% gift shop discount. Because the free admission is a privilege that can be exercised frequently and is offered in both benefit packages, and the value of the T-shirts is insubstantial, Museum J’s disclosure statement need not value or mention the free admission benefit or the T-shirts. However, because the 25% gift shop discount to K’s employees differs from the 10% discount offered in the basic membership benefits package, J’s disclosure statement must describe the 25% discount but need not estimate its value.

Donor’s contribution

Less The organization’s money, goods, and services given in return

Equals Donor’s deductible charitable contribution.

Exceptions. No disclosure statement is required if the organization gave only:

1. Goods or services with insubstantial value,

2. Certain membership benefits,

3. Goods or services described in (1) or (2) given to the employees of a donor organization or the partners of a donor partnership, or

4. Intangible religious benefits.

These exceptions are defined below. See also Regulations sections 1.170A-1, 1.170A-13, and 1.6115-1.

Certain goods or services disregar- ded for substantiation and disclosure purposes.

There is no prescribed format for the organization’s written acknowledgment of a donation. Letters, postcards, or computer-generated forms may be acceptable. The acknowledgment must, however, provide sufficient information to substantiate the amount of the deductible contribution. The organization may either:

Definitions

Substantiation. It is the responsibility of the donor:

Goods or services with insubstantial value. Generally, under section 170, the deductible amount of a contribution is determined by taking into account the FMV, not the cost to the charity, of any benefits that the donor received in return. However, the cost to the charity may be used in determining whether the benefits are insubstantial. See Cost basis next.

Cost basis. If a taxpayer makes a payment of $68.00 or more to a charity and receives only token items in return, the items have insubstantial value if they:

• To value a donation, and

• To obtain an organization’s written acknowledgment substantiating the donation.

• Provide separate statements for each contribution of $250 or more, or

• Furnish periodic statements substantiating contributions of $250 or more.

• Bear the charity’s name or logo, and

• Have an aggregate cost to the charity of $13.60 or less (low-cost article amount of section 513(h)(2)).

FMV basis. If a taxpayer makes a payment to a charitable organization in a fundraising campaign and receives benefits with an FMV of not more than 2% of the amount of the payment, or $136, whichever is less, the benefits received have insubstantial value in determining the taxpayer’s contribution.

Caution: The dollar amounts given above are applicable to tax year 2025 under Rev. Proc. 2024-40, 2024-45 I.R.B. 1100, section 2.34. They are adjusted annually for inflation.

When a donee organization provides a donor only with goods or services having insubstantial value under Rev. Proc. 2024-40 (and any successor documents), the contemporaneous written acknowledgment may indicate that no goods or services were provided in exchange for the donor’s payment.

Certain membership benefits. Other goods or services that are disregarded for substantiation and disclosure purposes are annual membership benefits offered to a taxpayer in exchange for a payment of $75 or less per year that consist of:

1. Any rights or privileges that the taxpayer can exercise frequently during the membership period such as:

a. Free or discounted admission to the organization’s facilities or events, or

b. Free or discounted parking; or 2. Admission to events that are: a. Open only to members, and b. Within the low-cost article limitation, per person.

Example 1. E offers a basic membership benefits package for $75. The package gives members the right to buy tickets in advance, free parking, and a gift shop discount of 10%. E’s $150 preferred membership benefits package also includes a $20 poster. Both the basic and preferred membership packages are for a 12-month period and include about 50 productions. E offers F, a patron of the arts, the preferred membership benefits in return for a payment of $150 or more. F accepts the preferred membership benefits package for $300. E’s written acknowledgment satisfies the substantiation requirement if it describes the poster, gives a good-faith estimate of its FMV ($20), and disregards the remaining membership benefits.

Example 2. In Example 1, if F received only the basic membership package for its $300 payment, E’s acknowledgment need state only that no goods or services were provided.

Example 3. G Theater Group performs four plays. Each play is performed twice. Nonmembers can

Separate contributions of less than $250 aren’t subject to the requirements of section 170(f)(8), whether or not the sum of the contributions made by a taxpayer

94 2025 Instructions for Form 990

to a donee organization during a tax year equals $250 or more.

won’t be aggregated for purposes of the $75 threshold.

Contemporaneous. A written acknowledgment is contemporaneous if the donor obtains it on or before the earlier of:

• The date the donor files the original return for the tax year in which the contribution was made, or

• The due date (including extensions) for filing the donor’s original return for that year.

Good-faith estimate. An organization may use any reasonable method in making a good-faith estimate of the value of goods or services provided by that organization in consideration for a taxpayer’s payment to that organization. A good-faith estimate of the value of goods or services that aren’t generally available in a commercial transaction may be determined by reference to the FMV of similar or comparable goods or services. Goods or services may be similar or comparable even though they don’t have the unique qualities of the goods or services that are being valued.

Substantiation of payroll contributions. An organization may substantiate an employee’s contribution by deduction from its payroll by:

• A pay stub, Form W-2, or other document showing a contribution to a donee organization, together with

• A pledge card or other document from the donee organization that shows its name. For contributions of $250 or more, the document must state that the donee organization provides no goods or services for any payroll contributions. The amount withheld from each payment of wages to a taxpayer is treated as a separate contribution.

Substantiation of matched payments. If a taxpayer’s payment to a donee organization is matched by another payor, and the taxpayer receives goods or services in consideration for its payment and some or all of the matching payment, those goods or services will be treated as provided in consideration for the taxpayer’s payment and not in consideration for the matching payment.

Disclosure statement. An organization must provide a written disclosure statement to donors who make a quid pro quo contribution in excess of $75 (section 6115). This requirement is separate from the written substantiation acknowledgment a donor needs for deductibility purposes. While, in certain circumstances, an organization may be able to meet both requirements with the same written document, an organization must be careful to satisfy the section 6115 written disclosure statement requirement in a timely manner because of the penalties involved.

Goods or services. Goods or services include:

• Cash,

• Property,

• Services,

• Benefits, and

• Privileges. In consideration for. A donee organization provides goods or services in consideration for a taxpayer’s payment if, at the time the taxpayer makes the payment to the donee organization, the taxpayer receives, or expects to receive, goods or services in exchange for that payment.

Goods or services a donee organization provides in consideration for a payment by a taxpayer include goods or services provided in a year other than the year in which the donor makes the payment to the donee organization.

Penalties. A charity that knowingly provides a false substantiation acknowledgment to a donor may be subject to the penalties under section 6701 and/or section 7206(2) for aiding and abetting an understatement of tax liability.

For tax years beginning before January 1, 2021, section 501(c)(21) black lung trusts that could not use Form 990-N, e-Postcard (see Who Must File, earlier), used Form 990-BL to meet the reporting requirements of section 6033. A section 501(c)(21) black lung trust, trustee, or disqualified person liable for section 4951 or 4952 excise taxes also used Form 990-BL to report and pay those taxes.

For tax years beginning after December 31, 2020, section 501(c)(21) trusts will use Form 990 instead of Form 990-BL to meet section 6033 reporting requirements. A section 501(c)(21) black lung trust, trustee, or disqualified person liable for section 4951 or 4952 excise taxes will use Form 6069 to report and pay sections 4951 and 4952 excise taxes.

In general, a section 501(c)(21) trust will complete Form 990 in the same manner as any other organization required to file Form 990, including (without limitation) schedules or forms identified upon completion of Part IV, Checklist of Required Schedules; or Part V, Statements Regarding Other IRS Filings and Tax Compliance.

The following chart is intended to help section 501(c)(21) black lung trusts identify some of the key lines on Form 990 that correspond with certain lines of Form 990-BL, especially a heading block item and in Part I.

Intangible religious benefits. Intangible religious benefits are provided only by organizations organized exclusively for religious purposes. Examples include:

• Admission to a religious ceremony; and

• De minimis tangible benefits, such as wine provided in connection with a religious ceremony.

Quid pro quo contribution. A quid pro quo contribution is a payment that is made both as a contribution and as a payment for goods or services provided by the donee organization.

Example. A donor gives a charity $100 in consideration for a concert ticket valued at $40 (a quid pro quo contribution). In this example, $60 would be deductible. Because the donor’s payment exceeds $75, the organization must furnish a disclosure statement even though the taxpayer’s deductible amount doesn’t exceed $75. Separate payments of $75 or less made at different times of the year for separate fundraising events

Charities that fail to provide the required disclosure statement for a quid pro quo contribution of more than $75 will incur a penalty of $10 per contribution, not to exceed $5,000 per fundraising event or mailing. The charity may avoid the penalty if it can show that the failure was due to reasonable cause (section 6714).

2025 Instructions for Form 990 95

Section 501(c)(21) Black Lung

Trusts

96 2025 Instructions for Form 990

Index

$10,000–per-item exception 27 $10,000–per-related organization

exception 27 35% controlled entity 17, 53

A

Section 501(c)(21) Black Lung Trusts 95 Applicable tax-exempt

Appendix I, Use of Form 990 or

990-EZ To Satisfy State Reporting Requirements 92 Appendix J, Contributions 92 Appendix K, Reporting Information for

CEO 21 CEO, executive director, or top

management official 55 Certified historic structure 55 Change of address 91 Changes in net assets 92 Charitable risk pools 2 Child care organizations 2 Children 2 Church 3, 55 Church-affiliated organization 4 Closely held stock 55 Club 17 Code(s) 3 Collectibles 55 Collections of works of art, historical

Accountable plan 20, 53 Accountant 50 Accounting :

organization 53, 85 Application for recognition of

Fees 45 Period 5 Accounting fees 45 Accounting period 5, 8 Accounts payable 49 Accounts receivable 48 Accrual 6 Activities 11 Activities conducted outside the

exemption 90 Application pending 9 Art 12, 53 Articles of incorporation 21 ASC 2016–14 53 ASC 740 53 ASC 958 12, 53 Assessments 38 Asset(s) :

Net 49 Total 49 Assistance to individuals 44 Attachments 8 Attorney 10 Audit 54, 84 Audit committee 20, 54 Audit guides 92 Audited financial statements 12, 54 Automatic revocation 7

treasures, and other similar assets 55 College 78 Committee 4 Compensation 13, 25, 36, 55, 82

Current officers 44 Disqualified persons 26, 45 Former officers 25 Other persons 26 Reasonable 87 Reportable 27 Table 32 Compilation (compiled financial

United States 53 Activities outside the United

States 53 Address :

Change in 9 Website 10 Address Change 8 Administrative 19 Advance ruling period 4 Advertising 45 Affiliate/affiliates 46, 84

Expenses 46 Payments 46 Purchases 46 State or national organizations 46 Affiliated organizations 86 Allocations :

B

Exception 31 Benefits :

Backup withholding 15 Balance sheet 47 Bank account 15 Bank or financial institution trustee

statements) 12, 55 Completing the heading 8 Conflict of interest policy 56 Conflicts of interest policy 22, 23 Conservation easement 12, 56 Consolidated financial statement 12,

83 Contemporaneous 87 Contracts 88 Contributing employer 63, 71 Contributions 12, 37, 39, 56

Disclosure statement 16 Donation of services 38 Donor advised funds 86 Government 38 Government grants 38 Membership dues 11, 38 Noncash 39 Nondeductible 16 Quid pro quo 16 Contributor 2 Contributors, Schedule of 39 Control 14, 57 Controlled entity 14, 57 Controlling organization :

Grants, and 11 Alternate test 78 Amended Return 9

Description of amendment 6 Name change amendment 6 Annual information return 79 Anti-abuse rule 78 Appendix :

Disregarded 31 Employee 45 Members 44, 87 Membership 40 Bingo 42, 54 Board designated endowment

Appendix A, Exempt Organizations

Reference Chart 76 Appendix B, How to Determine

Whether an Organization’s Gross Receipts Are Normally $50,000 (or $5,000) or Less 77 Appendix C, Special Gross Receipts

(quasi) 12 Board-designated endowment 54 Bond issue 40, 54 Bonds, tax-exempt 49 Bonus 88 Book value 48 Books of account 6 Business activities 39 Business Activity Codes 52 Business code 40 Business relationship 21, 54

Tests for Determining Exempt Status of Section 501(c)(7) and 501(c)(15) Organizations 77 Appendix D, Public Inspection of

Returns 78 Appendix E, Group Returns—

Section 512(b)(13) 3 Controlling organization under

Reporting Information on Behalf of the Group 81 Appendix F, Disregarded Entities and

C

Calendar year 5 Capital contributions 17 Capital gains 40 Capital stock accounts 49 Capital surplus 50 Cash 47 Cash contributions 54 Cash receipts and disbursements 6 Central organization 7, 55

section 512(b)(13) 58 Cooperative service organizations 2 Copies 7 Core form 58 Corporation 10 Credit counseling services 58 Current year 58

Joint Ventures—Inclusion of Activities and Items 83 Appendix G, Section 4958 Excess

Benefit Transactions 85 Appendix H, Forms and Publications

to File or Use 90

2025 Instructions for Form 990 97

Government agencies 39 Initiation 78 Legal 45 Membership 77 Registration 39 Figuring gross receipts 77 FIN 48 83 FIN 48 (ASC 740) 62 Final return 6, 8 Financial account 15 Financial statements 62 Fiscal year 5, 62 Five highest compensated

D

De minimis fringe benefit 87 Debt management plan services 58 Defeasance escrow 40, 58 Deferred charges 48 Deferred compensation 58 Deferred revenue 49 Defined benefit plan 31

EIN 60 Email subscription 2 Employee 61 Employee benefit plan 4 Employee benefits 45 Employee(s) 26 Employees, key 26 Employer identification number (EIN) :

Disregarded entities 84 Section 501(c)(9) organizations 9 Endowment fund 12, 61 Endowment funds 12 EO Determinations 11 Equipment 48 Escrow or custodial account 49, 61 Estates 37 Estimate, reasonable 10 Excess benefit transaction 61, 85-87

Accounts 15 Organization 4 Foreign government 62 Foreign individual 62 Foreign organization 62 Form 8976, Notice of Intent to

Nonqualified 31 Qualified 31 Defined contribution plan :

Qualified 31 Dependent care assistance 32 Depreciation 47 Determination letter 3 Direct expenses 41 Director 13, 58 Director or trustee 26, 58 Disclosure 15

Conflict of interest 23 Disqualified person(s) 21 Excess business holdings 16 Statement 16 Disclosure of excess business

employees 26 Fixed payment 88 FMV 14, 18, 19, 22, 37, 38, 40-42, 47,

50, 59 , 72, 86, 88 , 89, 94-96 Foreign 15

Recognition of Exemption Under Section 501(c)(3) 90 Form 1024-A, Application for

Recognition of Exemption under Section 501(c)(4) of the Internal Revenue Code 90 Form 1024, Application for

Recognition of Exemption Under Section 501(a) 90 Form 1040-SR, U.S.Income Tax

holdings 16 Disqualified person 58 Disqualified persons 85 Disregarded benefits 31, 32 Disregarded entities 8, 28, 83 Disregarded entity or entities 59 Dissolution 84 Distributions 45 Dividends 39 Document retention and destruction

Churches 89 Correction 89 Donor advised funds 89 Excess payment 89 Excise tax 88 Insufficient payment 89 Revenue sharing transactions 89 Revocation of exemption 89 Section 4958 85 Excess business holdings 16 Excise taxes 88 Executive director 24 Exempt bond 61 Exempt function 39 Exempt organizations, types of 76 Exempt purposes 11, 22, 42 Expenses 40

Allocating indirect 43 Direct 41 Functional 42 Fundraising 41 Indirect expenses 43 Management and general 43 Occupancy 46 Political 12 Postage 46 Printing 46 Program service 42, 47 Shipping 46 Supplies 46 Telephone 46 Extension of time to file 6

Operate Under Section 501(c) (4) 91 Forms :

FinCEN Form 114 91 Form 1023-EZ, Streamlined

Application for Recognition of Exemption Under Section 501(c)(3) of the Internal Revenue Code. 90 Form 1023, Application for

policy 24 Domestic government 59 Domestic individual 59 Domestic organization 60 Donations 38

Income 4 Form 1096, Annual Summary and

Transmittal of U.S. Information Returns 90 Form 1098 series 90 Form 1120–POL, U.S. Income Tax

Return for Certain Political Organizations 91 Form 1128, Application To Adopt,

Change or Retain a Tax Year 91 Form 2848, Power of Attorney and

Of services 38 Of use of materials, equipment or

Return for Seniors 90 Form 1040, U.S. Individual Income Tax

facilities 38 Of vehicles 16 Donor advised fund 60 Donor advised fund(s) :

Return 90 Form 1041, U.S. Income Tax Return

Disqualified person 86 Donor advisor 16 Exceptions 89 Excess benefit transaction 86 Grants 86 Sponsoring organization 3 Donor advisor 60 Donor contributions :

Acknowledgment 16 Donor-Imposed Restriction 60 Donor-Restricted Endowment

Family member 86 Family member, family

for Estates and Trusts 90 Form 1065, U.S. Return of Partnership

F

Facility/facilities 11 Facts and circumstances 81 Fair market value (FMV) 62 Family :

fund 60 Dues 38

Declaration of Representative 91 Form 3115, Application for Change in

Accounting Method 91 Form 3520, Annual Return To Report

Transactions with Foreign Trusts and Receipt of Certain Foreign Gifts 91 Form 4506–A, Request for a Copy of

Exempt or Political Organization IRS Form 91 Form 4506, Request for Copy of Tax

Club 32 Membership 40, 46 Paid to affiliates 46

E

e-Postcard (see also Form 990-N) 77 Economic benefit 86

Disregarded 87 Nontaxable fringe benefits 87

relationship 62 FASB ASC 958 37, 49 Federal unemployment tax (FUTA) 90 Federated fundraising agencies 38 Federated fundraising

Accounting 45 Copies 80 Fundraising 45

organizations 44 Fees 45

Return 91

98 2025 Instructions for Form 990

Form 4562, Depreciation and

Government :

Agency 39 Contracts 39 Contributions 38 Fees 39 Grants 38, 43 Official 46 Organization 4 Government official 63 Governmental issuer 40, 63 Governmental unit 49, 63 Governmental Unit 63 Grants 11, 37, 44

Amortization 91 Form 4720, Return of Certain Excise

Form 8940, Request for Miscellaneous

Taxes Under Chapters 41 and 42 of the Internal Revenue Code 91 Form 5471, Information Return of U.S.

Determination, Request for Miscellaneous Determination, under Section 507, 509(a), 4940, 4942, 4945, and 6033 of the Internal Revenue Code 91 Form 926, Return by a U.S. Transferor

of Property to a Foreign Corporation 90 Form 940, Employer’s Annual Federal

Persons With Respect to Certain Foreign Corporations 91 Form 5500, Annual Return/Report of

Employee Benefit Plan 91 Form 5578, Annual Certification of

Racial Nondiscrimination for a Private School Exempt From Federal income Tax. 91 Form 5768, Election/Revocation of

Unemployment (FUTA) Tax Return 90 Form 941, Employer’s Quarterly

Election by an Eligible Section 501(c)(3) Organization To Make Expenditures To Influence Legislation 91 Form 7004, Application for Automatic

Extension of Time to File Certain Business Income Tax, Information, and Other Returns 91 Form 720, Quarterly Federal Excise

Federal Tax Return 90 Form 943, Employer’s Annual Tax

Return for Agricultural Employees 90 Form 990-PF, Return of Private

Foundation or Section 4947(a)(1) Trust Treated as Private Foundation 4 Form 990-T, Exempt Organization

Business Income Tax Return 90 Form 990–EZ, Short Form Return of

Allocations, and 11 Contributions 11 Government contributors 38 Payable 49 Receivable 47 Grants and other assistance 63 Grants and other assistance outside

Tax Return 90 Form 8038 series, Tax Exempt

the United States 13 Gross proceeds 64 Gross receipts 64, 77

$5,000 77 $50,000 77 Gross rents 40 Gross revenue 14 Gross sales price 40 Group exemption 64, 80

Bonds 91 Form 8274, Certification by Churches

and Qualified Church-Controlled Organizations Electing Exemption from Employer Social Security and Medicare Taxes 91 Form 8282, Donee Information

Organization Exempt From Income Tax 10 Form 990–N, Electronic Notice

(e-Postcard) for Tax-Exempt Organizations Not Required To File Form 990 or 990–EZ 2 Form SS-4, Application for Employer

Identification Number 91 Form W-2, Wage and Tax

$50,000 or less 77 Acting as agent 77 Figuring 77 Gross receipts test :

Return 91 Form 8283, Noncash Charitable

Central/parent organization 80 Group return 64, 82

Contributions 91 Form 8300, Report of Cash Payments

Statement 90 Forms and publications 15 Foundations 27 Fringe benefits 87

De minimis 87 Nontaxable 87 Functional expenses 42

Over $10,000 Received in a Trade or Business 91 Form 8328, Carryfoward Election of

Unused Private Activity Bond Volume Cap 91 Form 8718, User Fee for Exempt

H

84 Historical treasure 12, 64 Hospital 83 Hospital (or cooperative hospital

Organization Determination Letter Request 91 Form 8821, Tax Information

Authorization 91 Form 8822-B, Change of Address or

Responsible Party—Business 91 Form 8868, Application for Extension

Allocating indirect 43 Fundraising 43 Management and general 43 Program service 42 Fund Balances 49, 50 Fundraising 38, 62

Heading 8 Health benefits 31 Helpful hints 2 Highest compensated employee 64,

service organization) 64 Hospital organization 64 Hospital/hospital facility 64 Hours per week 29 Household goods 64

of Time To File an Exempt Organization Return or Excise Taxes Related to Employee Benefit Plans 6, 91 Form 8870, Information Return for

contributions 7 Fundraising activities 62 Fundraising events 41, 63 Funds 49

Activities 13 Events 38 Expenses 43 Fees 45 Records for tax deductible

I

Transfers Associated With Certain Personal Benefit Contracts 91 Form 8871, Political Organization

G

Income :

Notice of Section 527 Status 91 Form 8872, Political Organization

Exempt function 11 Investment 40 Rental 39 Unrelated business 15 Incomplete return 6 Independent contractor 37, 64 Independent voting member of

Report of Contributions and Expenditures 91 Form 8886–T, Disclosure by

Tax-Exempt Entity Regarding Prohibited Tax Shelter Transaction 91 Form 8886, Reportable Transaction

Disclosure Statement 91 Form 8899, Notice of Income From

GAAP 63 Gaming 42, 63 GEN (Group exemption number) 9 Generally accepted accounting

principles 11 Generally accepted accounting

Donated Intellectual Property 91

principles/GAAP 63 Gifts 37, 39 Goods 41

Goods or services 41 Goods sold, cost of 42 Governance 85 Governing body 63, 84 Governing documents 22

governing body 20, 65 Indoor tanning services 18 Information return 79 Information technology 45, 46 Initial contract 65, 88 Instant bingo 42, 65 Institutional trustee 26, 65 Insurance 47

2025 Instructions for Form 990 99

Insurance contract 78 Integrated auxiliary 3 Intellectual property 16 Interest 40, 46

Miscellaneous 6

Expenses 47 Mission 4 Mission society 4 Money market funds 47 Mutual or cooperative electric

Conflicts of interest 22 Document retention and

Pledges receivable 47 Policies :

destruction 24 Joint venture 24 Nondiscrimination 91 Whistleblower 24 Political :

Mortgage 46 Tax-exempt 18 Interest income 39, 40

Notes and loans receivable 40 Securities 40 Interested persons 84 Inventory 42 Investment 40

companies 17

N

Expenses 83 Political campaign activities 68 Political organization 4

Public inspection 78 Section 527 3 State or local 3 Political subdivision 68 Postage cost 79 Power of attorney 91 Premiums 78 Prepaid expenses 48 Principal officer 68 Printing 46 Private business use 68, 85 Private foundation 68, 85 Privileged relationship 21 Proceeds 40, 68 Professional fundraising services 45,

Committee 20 Dividend 40 Income 78 Interest 40 Management 21 Program-related 40 Rents 40 Savings and temporary cash 47 Investments 48

Net assets 49 Net Assets with donor restrictions 67 Net Assets without Donor

Restrictions 67 Noncash contribution 39 Noncash contributions 67 Nonexempt charitable trust 67 Nonfixed payments 88 Nonprofit health insurance issuer 3 Nonqualified deferred

compensation 67 Nonqualified defined benefit plan 31 Nonqualified defined contribution

J

Joint costs 47 Joint venture 65, 84

K

Key employee 26, 66

L

plan 31, 34 Nontaxable fringe benefit 87 Notes receivable 48 Number of employees 84 Nursing homes 39

Expense 46 Officer 26, 67 Offices 79 “On behalf of” issuer 67 Ordinary course of business 21 Organization manager 67, 89 Organization(s) 4, 89

O

Occupancy 46

68 Program service 11 Program service accomplishments,

statement of 11 Program service expenses 42 Program service revenue 39

Government agency 39 Insurance premiums 39 Interest income 40 Medicaid 39 Medicare 39 Membership fees 40 Program-related investments 39 Rental income 39 Section 501(c)(9) organization 39 Unrelated trade or business

Land 48 Late filing 6 Legal fees 45 Legislation 66 Liabilities, total 49 Liquidation 83 List of states 6 Loans :

Receivable 48 Lobbying 66

Activity/Activities 12 Expenses 83 Grassroots 45 In-house expenditures 45 Joint ventures 84 Lobbying activities 66 Lobbying expenditures 83 Local governmental unit 49 Lotteries 41

Affiliated 86 Form of 10 Not required to file 3 Organizational documents 82 Organizations :

Foreign countries, in 4 Other assets 48 Other compensation 27 Ownership 14

activities 39 Program-related investment 39, 68 Prohibited tax shelter

P

transactions 15, 16 Proxy tax 12 PTIN 10 Pub. 3079, Tax-Exempt Organizations

and Gaming 63 Public charity 68, 82 Public Inspection 78 Public interest law firm 11 Public support 90 Publications 15

M

Maintaining offices, employees, or

Paid preparer 10 Paid-in capital 50 Paperwork Reduction Act Notice 50 Partnership 84 Payables 49 Payments :

agents 66 Management 84 Management and general

expenses 43 Management company 21, 66 Medicaid 39 Medical research 66, 79 Medicare 90 Meetings 46 Member of the governing body 20, 66 Membership 46

Cash 91 Compensation 87 Nonfixed 88 Severance 45 To affiliates 46 Payroll taxes 45 Penalties 6, 16

Failure to file 6 Perjury 7 Pension plan contributions 45 Personal benefit contracts 16 Phone help 2 Photographs of Missing Children 2

Substantiation and Disclosure Requirements 38, 41, 92 Pub. 1779, Independent Contractor or

Compliance Checks 92 Group Exemptions 92 Pub. 15–A, Employer’s Supplemental

Tax Guide (Fringe Benefits) 91 Pub. 15, (Circular E) Employer’s Tax

Guide 91 Pub. 1771, Charitable Contributions–

and Religious Organizations 92

Assessments 38 Benefits 40 Dues 38, 46 Merger, articles of 8

Employee 37 Pub. 1828, Tax Guide for Churches

100 2025 Instructions for Form 990

Pub. 3079, Tax-Exempt Organizations

Relationship 40 Reasonable compensation 70 Reasonable effort 70 Reasonableness, rebuttable

relationships 19 Section 501(c)(4) :

Applicable organization 85 Section 501(c)(5) :

Disclosure of transactions and

and Gaming 92 Pub. 3386, Tax Guide for Veterans

Organizations 92 Pub. 3833, Disaster Relief, Providing

presumption of 88 Receivable 14

Assistance Through Charitable Organizations 92 Pub. 4220, Applying for 501(c)(3)

Lobbying expenses 12 Membership dues 40 Section 501(c)(6) :

Lobbying expenses 12 Membership dues 40 Section 501(c)(7) 17, 84 Section 501(c)(9) 9 Section 6033(e) 12 Securities 48 Security/securities 71 Security/Securities 41 Sequencing list to complete the form

Tax-Exempt Status 92 Pub. 4221–PC, Compliance Guide for

501(c)(3) Public Charities 92 Pub. 4221–PF, Compliance Guide for

501(c)(3) Private Foundations 92 Pub. 4302, A Charity’s Guide to

Vehicle Donation 92 Pub. 4303, A Donor’s Guide to Vehicle

Account 47 Grants 47 Pledges 47 Reconciliation 6 Reconciliation of net assets 50 Recordkeeping 7 Refunding escrow 14, 70 Refunding issue 70 Reimbursement :

Donation 92 Pub. 463, Travel, Gift, and Car

Expenses 38, 91 Pub. 525, Taxable and Nontaxable

Income 91 Pub. 526, Charitable Contributions 92 Pub. 538, Accounting Periods and

Methods 92 Pub. 557, Tax-Exempt Status for Your

Of expenses 20 Of taxes 87 Related organization 20, 25, 71 Religious order 20, 71 Rent/rental 40

Expense 40 Income 39 Reportable compensation 13, 71 Reporting information from third

and schedules 4 Severance payments 45 Shipping 46 Short accounting period 5, 72 Short period 72 Short year and final returns 31 Short year and final returns. 32 Signature 10 Signature block 10 Significant disposition of assets 84 Significant disposition of net

Organization 92 Pub. 561, Determining the Value of

Donated Property 92 Pub. 598, Tax on Unrelated Business

parties 8 Requirements for a properly

Income of Exempt Organizations 92 Pub. 892, How to Appeal an IRS

Decision on Tax Exempt Status 92 Pub. 946, How To Depreciate

Property 92 Pub. 947, Practice Before the IRS and

completed Form 990 7 Research 43 Retained earnings 50 Returns and allowances 42 Revenue 42, 49

Deferred 49 Gross 14 Program service 39 Special events 41 Sweepstakes, raffles, and lotteries 41 Revenue-sharing transactions 89 Review of financial statement 71 Review of financial statements 12 Revocation of exemption 89 Rounding off to whole dollars 7 Royalties 40

contributions 16 SOP 98-2 47 Special events 41 Specific instructions for Form 990 8 Sponsoring organization 3, 72 State :

assets 72 Social club 17 Social security :

Tax 45 Solicitations of nondeductible

Filing requirement 92 Reporting requirements 6 State of legal domicile 10, 72 Statement(s) 92

Power of Attorney 10 Publicly traded securities 48, 69 Pull tabs 69 Pull-tabs 42 Purchases from affiliates 46 Purpose of Form 1

Q

Qualified 501(c)(3) bond 69 Qualified conservation

contribution 69 Qualified defined benefit plan 31 Qualified defined contribution

plan 31 Qualified intellectual property 16 Qualified state or local political

S

Of inventory 39 Sarbanes-Oxley 24 Savings 47 Savings accounts 47 Schedule of contributors 12 Scholarships 12 School 71 Section 4947(a)(1) trusts 11, 18 Section 4958 85, 88, 89 Section 4958, excise taxes :

Salaries 45 Sales 42

Activities outside of United States 13 Audited financial 82 Functional expenses 42 Position 98–2 47 Program service accomplishments 11 Revenue 37 Subordinate organization 72, 80 Substantial contributor 61, 86 Substantial influence 86 Supported organization 72, 86 Supporting organization 73, 87 Sweepstakes 41

T

organization 3, 70 Quasi-endowment 70 Quid pro quo contribution :

Disclosure statement 16

R

Racial nondiscrimination 91 Raffles 41 Reasonable :

Amount 79 Belief 81 Burden 79 Cause 6 Compensation 20 Effort 20, 21, 31 Estimate 10 Fee 79 Knowledge 86

Disqualified persons 85 Organization managers 89 Section 4968 18, 19 Section 501(c)(12) 17 Section 501(c)(15) 3, 77 Section 501(c)(21) :

black lung trusts 3 black-lung trust 95 trust 13, 39, 40, 44, 47, 49 Section 501(c)(3) 2

Tax shelter transaction 15 Tax year 26, 73 Tax-exempt bond 73 TE/GE EO Determinations 78 Telephone number 9 Term endowment 73 Terminated 8 Territory of the United States :

Applicable organization 85

Territory 73 Territory organization :

U.S. Territory 4

2025 Instructions for Form 990 101

Text message contribution 93 Top financial official 26, 73 Top management official 26, 73 Total assets 48, 73 Total liabilities 49 Transfers 14

Uncollectible pledges 37 Uniform Guidance, 2 CFR Part 200,

Institutional Funds Act (UPMIFA) 49 Unincorporated association 8 United States 10, 73 University/universities 12 Unrelated business 15, 73

Voluntary employees’ beneficiary

association 9 Volunteer 10, 74 Volunteer exception 31 Voting member of the governing

body 74 Voting member of the governing

Subpart F 50, 84 Uniform Prudent Management of

Personal benefit contracts 16 To controlled entities 14 Travel expense 46 Trust 8 Trust fund recovery penalty :

Income 37 Income tax 79 Revenue 40 Unrelated business gross income 73 Unrelated business income 43, 73 Unrelated organization 13, 73 Unrelated trade or business 73

body/board 20

W

Wages 45 Website address 10 Whistleblower policy 24 Widely available 81 Withholding :

Backup 15 Works of art 12, 74

Y

Year of formation 10, 74

Penalties 91 Trustee 73 Trustee(s) 10, 13, 19, 26

Institutional 26 Tuition assistance 32

U

U.S. territory 4, 38, 60, 63, 73 U.S. Territory :

Territory organization 3 U.S. Treasury bills 47

Activities 39 Gross income 85

V

Vehicle donations 93

102 2025 Instructions for Form 990