F. Use of Form 990-PF To Satisfy State Reporting Requirements

Some states and local government units will accept a copy of Form 990-PF and required attachments instead of all or part of their own financial report forms.

If the organization plans to use Form 990-PF to satisfy state or local filing requirements, such as those from state charitable solicitation acts, note the following.

Determine state filing requirements. Consult the appropriate officials of all states and other jurisdictions in which the organization does business to determine their specific filing requirements. “Doing business” in a jurisdiction may include any of the following.

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

• Conducting programs.

• Having employees within that jurisdiction.

6 Instructions for Form 990-PF (2025)

• Maintaining a checking account or owning or renting property there.

Monetary tests may differ. Some or all of the dollar limitations that apply to Form 990-PF when filed with the IRS may not apply when using Form 990-PF instead of state or local report forms. IRS dollar limitations that may not meet some state requirements are the $5,000 total assets minimum that requires completion of Part II, column (c), and Part XIV; and the $50,000 minimum for listing the highest paid employees and for listing professional fees in Part VII.

Additional information may be required. State and local filing requirements may require attaching to Form 990-PF 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 schedules.

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

• Answers to additional questions and other information. Each jurisdiction may require the additional material to be presented on forms they provide. The additional material doesn't have to be submitted with the Form 990-PF filed with the IRS.

If required information isn't provided to a state, the organization may be asked by the state to provide it or to submit an amended return even if the Form 990-PF is accepted by the IRS as complete.

Amended returns. If the organization submits supplemental information or files an amended Form 990-PF with the IRS, it must also submit a copy of the information or amended return to any state with which it filed a copy of Form 990-PF.

Method of accounting. Many states require that all amounts be reported based on the accrual method of accounting.

Time for filing may differ. The time for filing Form 990-PF with the IRS may differ from the time for filing state reports.