Part IV. Supporting — 2025 Inst 990 or 990-EZ (Sch A) (PDF)

Complete the sections of Part IV that correspond below with the type of supporting organization indicated on line 12a, 12b, 12c, or 12d of Part I.

Type I: Sections A and B.
Type II: Sections A and C.
Type III functionally integrated: Sections A, D, and E.
Type III non-functionally integrated: Sections A and D, and Part V.

Section A. All Supporting Organizations

Line 1. The organization’s articles of incorporation or trust instrument must designate the publicly supported organization(s) on whose behalf the supporting organization is operated. The articles of a Type I or Type II supporting organization may designate its supported organization(s) either by class or purpose or by name. The articles of a Type III supporting organization must designate the supported organization(s) by name, unless a historic and continuing relationship exists between the organizations.

Check “Yes” only if the organization supports no organization other than those listed by name in its governing instrument. If the organization supports any organization not specifically listed, check “No” and describe in Part VI how the supported organizations are designated. If designated by class or purpose, describe the class or purpose. If the organization and its supported organization(s) have a historic and continuing relationship, explain that relationship. If support of one or more organizations is subject to certain future contingencies, explain those contingencies, and explain what organizations will be supported or benefited if those contingencies occur.

Line 2. If the organization supported any domestic or foreign organization (other than an organization described in section 501(c)(4), (5), or (6)) that didn’t have an IRS determination of status under section 509(a)(1) or (2), check “Yes” and explain in Part VI how the organization determined that the supported organization was described in section 509(a)(1) or (2) and why the supported organization doesn’t have such an IRS determination (for example, because it has applied for but not yet received such a determination, or it isn’t required to obtain recognition of its public charity status because it is a church, a state university, or described in section 4948(b)).

Line 3a. A supporting organization may support an organization described in section 501(c)(4), (5), or (6) if the supported organization satisfies the public support tests applicable to a section 509(a)(2) organization. See Regulations section 1.509(a)-4(k) and the instructions for Part III. If the organization supports a section 501(c)(4), (5), or (6) organization, check “Yes” for line 3a.

Line 3b. If the organization confirmed that the supported organization qualified under section 501(c)(4), (5), or (6) and met the section 509(a)(2) public support test for its most recent tax year, check “Yes” and describe in Part VI how the organization made this determination. For example, the organization may ask its section 501(c)(4), (5), or (6) supported organization to furnish a copy of its

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IRS determination letter and to complete annually a pro forma Schedule A (Form 990), Part III, and keep the letter and support calculation in the supporting organization’s files.

If the supporting organization doesn’t annually confirm that its supported organization satisfies the section 509(a) (2) public support test, it must explain in Part VI how it knows that the supported organization would’ve been described in section 509(a)(2) if it were described in section 501(c)(3) during the tax year.

Line 3c. Support given to a supported section 501(c)(4), (5), or (6) organization must be used solely for charitable purposes. If the supporting organization has put into place measures to ensure that such support is used solely for charitable purposes, check “Yes” and describe those measures in Part VI. If not, check “No” and describe in Part VI how the supporting organization ensured during the tax year that its assets were used solely for charitable purposes.

Line 4a. A supporting organization can’t qualify for Type III status in the tax year if any supported organization wasn’t organized in the United States.

Lines 4b and 4c. A supporting organization must exercise control and discretion over funds granted to an organization that isn’t exempt under section 501(c)(3). See Rev. Rul. 68-489, 1968-2 C.B. 210. Also, a domestic charity must generally exercise control and discretion over funds granted to a foreign organization. See Rev. Rul. 63-252, 1963-2 C.B. 101; and Rev. Rul. 66-79, 1966-1 C.B. 48.

Explain in Part VI how the organization retained such control and discretion despite being controlled or supervised by or in connection with such foreign supported organization(s). Also, explain what controls the organization used to ensure that all support to the foreign supported organization(s) was used exclusively for charitable, educational, etc., purposes described in section 170(c)(2)(B) if the foreign supported organization doesn’t have an IRS determination under sections 501(c) (3) and 509(a)(1) or (2).

Line 5. Supporting organizations may add, substitute, or remove supported organizations only in certain limited situations. See Regulations section 1.509(a)-4(d). Generally, a Type I or Type II supporting organization may add or substitute particular supported organizations within the class or classes designated in its articles, but may not add or substitute supported organizations outside of the designated class(es). A Type III supporting organization, which must specify its supported organizations by name, may only substitute supported organizations if such substitution is conditioned upon the occurrence of an event that is beyond the control of the supporting organization (such as a supported organization’s lapse into private foundation status).

If the organization has added, substituted, or removed any supported organization during the tax year, check “Yes” and provide detail in Part VI, including (i) the names and EINs of the organizations added, substituted, or removed; (ii) the reasons for each addition, substitution, or removal; (iii) the authority under the organization’s organizing document for each addition, substitution, or

removal; and (iv) an explanation of how the action was accomplished (such as by amendment to the organizing document substituting a new supported organization).

Line 6. A supporting organization must engage solely in activities that support or benefit its supported organization(s). In addition to making grants and providing services and facilities directly to its supported organization(s), a supporting organization may also generally make grants or provide services or facilities to (1) individual members of the charitable class benefited by its supported organization(s), or (2) other supporting organizations that also support or benefit its supported organization(s). See Regulations section 1.509(a)-4(e). If the organization made any grants or provided any benefits to any other organization or individual, check “Yes” and provide detail in Part VI.

Lines 7 and 8. Under section 4958(c)(3), any grant, loan, compensation, or other similar payment provided by a supporting organization to a substantial contributor (defined in section 4958(c)(3)(C)), to a family member (defined in section 4958(f)(4)), and to a 35% controlled entity of such persons, is considered a per se excess benefit in its entirety, regardless of the fairness or reasonableness of the payment, and is subject to tax under section 4958(a). The same is true of any loan by a supporting organization to a disqualified person under section 4958 (other than loans to certain exempt organizations). If the organization made any such payment or loan during the tax year, check “Yes” and report the transaction on Schedule L (Form 990), Transactions With Interested Persons, Part I. For more information on excess benefit transactions generally, see the Instructions for Schedule L (Form 990).

Line 9. A supporting organization may not be controlled by disqualified persons, as defined in section 4946. Section 509(a)(1) or (2) organizations, and foundation managers who are disqualified persons only as a result of being foundation managers, aren’t treated as disqualified persons for this purpose. Impermissible control may be direct or indirect. If a disqualified person holds any of the interests described on line 9b or 9c, or derives personal benefit from any such assets, provide detail in Part VI.

Line 10. Under section 4943(f), a Type II supporting organization that accepts a contribution from a person who controls the governing body of a supported organization (or from a family member of such person, or from a 35% controlled entity of such person) is subject to the excess business holdings tax under section 4943. All Type III non-functionally integrated supporting organizations are also generally subject to the tax. For more information about excess business holdings, see the Instructions for Form 4720, Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code.

Line 11. Section 509(f)(2) prohibits Type I and Type III supporting organizations from accepting a gift or contribution from certain persons associated with a supported organization of such supporting organization. Specifically, if a Type I or Type III supporting organization accepts a contribution after August 16, 2006, from a person who controls the governing body of a supported organization (or from a family member of such person, or

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from a 35% controlled entity of such person), then the supporting organization loses its status as a supporting organization. Such supporting organization must file Form 990-PF unless it qualifies as a public charity under section 509(a)(1) or (2).

Section B. Type I Supporting Organizations

Line 1. A Type I supporting organization must be operated, supervised, or controlled by one or more of its supported organizations (the “controlling supported organizations”). This means that the controlling supported organizations must have a substantial degree of direction over the policies, programs, and activities of the supporting organization; and the supporting organization in turn must be responsive to the needs or demands of the controlling supported organizations, and must constitute an integral part of, or maintain a significant involvement in, the operations of the controlling supported organizations. This relationship is most clearly established when one or more supported organizations (through their officers, directors, trustees, or membership) have the unconditional power to remove and replace at least a majority of the supporting organization’s directors or trustees at any time. The relationship is also commonly established when one or more supported organizations have the power to appoint or elect at least a majority of the supporting organization’s directors or trustees at regular intervals. However, there may be other ways to establish this relationship. If the organization relies on other ways to establish the relationship, check “No” and describe in Part VI how the necessary relationship is established.

Line 2. The supporting organization may benefit organizations that don’t participate in the control relationship described on line 1, but only if such activity carries out the purposes of the controlling supported organizations.

Section C. Type II Supporting Organizations

Line 1. A Type II supporting organization must be supervised or controlled in connection with its supported organization(s). This means that there must be common supervision or control by the persons supervising or controlling both the supporting organization and the supported organization(s) to ensure that the supporting organization will be responsive to the needs and requirements of the supported organization(s). This relationship is most clearly established when the same persons serve as all or a majority of the directors or trustees of all of the organizations involved. However, there may be other ways to establish this relationship. If the organization relies on other than overlap of at least a majority of directors or trustees of all organizations involved, check “No” and describe in Part VI how the necessary relationship is established.

Section D. All Type III Supporting Organizations

Line 1. A Type III supporting organization must supply annually a written notice, addressed to a principal officer of each supported organization, which includes the following.

A description of the type and amount of all support, including any amounts counting toward the distribution requirement (as described in Regulations section 1.509(a)-4(i)(6)), the supporting organization provided to the supported organization during the supporting organization’s tax year preceding the tax year in which the notice is provided, including a brief narrative description and sufficient financial detail for the recipient to identify the types and amounts of support being reported.
A copy of the supporting organization’s most recently filed Form 990 (the supporting organization may redact the names and addresses of contributors).
A copy of the supporting organization’s updated governing documents (including articles of organization, bylaws, and any amendments), to the extent not previously provided.

See Regulations section 1.509(a)-4(i)(2). The notice must be submitted by the last day of the fifth month of the supporting organization’s tax year being reported (May 31 for calendar-year filers). An organization that doesn’t timely submit the required information in the required manner doesn’t qualify as a Type III supporting organization for the tax year in which it fails to timely submit.

State whether during the tax year being reported the organization provided a timely notice with the required information in the required manner.

Lines 2 and 3. A Type III supporting organization must be responsive to the needs or demands of each of its supported organizations. An organization meets this responsiveness test with regard to each supported organization if:

The supported organization has an adequate relationship with the supporting organization because:

a. The supported organization regularly appoints or elects (whether or not during the tax year) at least one officer, director, or trustee of the supporting organization; b. At least one member of the governing body of the supported organization also serves as an officer, director, or trustee of the supporting organization; or c. The officers, directors, or trustees of the supporting organization and of the supported organization maintain a close and continuous working relationship; and

Because of this relationship, the supported organization has a significant voice in the supporting organization’s investment policies, timing of grants, manner of making grants, selection of grant recipients, and other use of income or assets (the “significant voice” test).

In the case of a supporting organization that supported a supported organization before November 20, 1970, additional facts and circumstances such as a historic and continuing relationship between the organizations may also be taken into account in considering the responsiveness test.

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If the organization has an adequate relationship with at least one supported organization only by means of a “close and continuous working relationship” or a “historic and continuing relationship,” then in Part V explain the relationship and how it has been maintained. Also, all Type III supporting organizations that claim to meet the significant voice test must describe in Part VI the voice or role of the supported organization(s) in directing the supporting organization’s use of its income or assets.

Section E. Type III Functionally Integrated Supporting Organizations

Line 1. A Type III supporting organization must constitute an integral part of one or more of its supported organizations by maintaining significant involvement in its operations and providing support on which the supported organization is dependent. To satisfy this requirement as a Type III functionally integrated supporting organization, an organization may (a) pass an activities test (see the instructions for line 2, later), (b) be the parent of its supported organizations (see the instructions for line 3, later), or (c) support governmental supported organizations (see Support of governmental supported organizations, later). If the organization can’t satisfy any of these tests, it may still qualify as a Type III non-functionally integrated supporting organization. See Part V, later.

Support of governmental supported organizations. A Type III supporting organization meets the integral part test for a functionally integrated supporting organization if it (1) only supports one or more governmental organizations (as discussed in the instructions for Section D under Lines 2 and 3, earlier), and (2) a substantial part of the supporting organization’s activities directly further the exempt purposes of at least one governmental supported organization; and (3) if the supporting organization supports more than one governmental supported organization, all of the governmental supported organizations either (1) operate within the same city, county, or metropolitan area; or (2) work in close coordination or collaboration together to conduct a service, program, or activity that the supporting organization supports.

Line 2. Activities Test. To meet the activities test of a Type III functionally integrated supporting organization, substantially all of the supporting organization’s activities must (1) directly further the exempt purposes of one or more supported organization, and (2) be activities that such supported organization(s) would normally be engaged in but for the supporting organization’s involvement.

Direct furtherance. Substantially all of the supporting organization’s activities must be “direct furtherance” activities. Direct furtherance activities are conducted by the supporting organization itself, rather than by a supported organization. Holding title to exempt-use assets and managing them are direct furtherance activities. Fundraising, investing and managing non-exempt-use assets, grant-making to organizations, and grant-making to individuals (unless it meets the requirements of Regulations section 1.509(a)-4(i)(4)(ii)(D)) aren’t direct furtherance activities.

But for. In addition, the direct furtherance activities must be activities in which, but for the supporting organization’s involvement, the supported organization would normally be involved.

Examples include holding and managing facilities used by a church for its religious purposes, operating a food pantry for a group of churches that normally would operate food pantries themselves, and maintaining local parks for a community foundation that would otherwise maintain those parks. See Regulations section 1.509(a)-4(i)(4)(v) for more detailed examples.

Line 3. Parent of Supported Organizations. To qualify as the parent of each of its supported organizations, (1) the supporting organization and its supported organizations must be part of an integrated system (for example, a hospital system); (2) the supporting organization must direct the overall policies, programs, and activities of the supported organizations (for example, coordinating the activities of the supported organizations and engaging in overall planning, policy development, budgeting, and resource allocation); and (3) the supporting organization’s governing body, members of the governing body, or officers (acting in their official capacities) must appoint or elect, directly or indirectly, a majority of the officers, directors, or trustees of each supported organization and have the power to remove and replace such directors, officers, or trustees, or otherwise have an ongoing power to appoint or elect such directors, officers, or trustees with reasonable frequency.