What IRS Form 990-PF (2015) Is For

IRS Form 990-PF is the annual information return that all private foundations must file with the IRS. It serves two key purposes:

1. To report financial activities, governance practices, and compliance with private foundation rules.
   
   
2. To calculate and pay the excise tax on net investment income under section 4940.
   
   

Unlike public charities (which only file if they meet certain thresholds), all private foundations and certain section 4947(a)(1) charitable trusts must file Form 990-PF, regardless of their income or asset levels (IRS Instructions for Form 990-PF (2015)).

When You’d Use Form 990-PF for 2015 (Late or Amended Filing)

You may be filing Form 990-PF for 2015 long after the due date (originally May 15, 2016, for calendar-year foundations) in the following situations:

• Late filing: If the IRS sent delinquency notices (e.g., CP-259 or CP-215) or penalty assessments for failure to file.
  
  
• Amended filing: If errors were found in reported revenue, distributions, or excise tax calculations.
  
  
• Compliance correction: To avoid or respond to potential revocation of exempt status (automatic after three consecutive years of non-filing).
  
  
• Refund claim: To request a refund of overpaid section 4940 excise tax—must be filed within 3 years of the original return filing date or 2 years from when taxes were paid, whichever is later.
  
  

Key Rules Specific to 2015

• Excise tax rates: Private foundations paid either 2% or a reduced 1% excise tax on net investment income, depending on whether charitable distribution requirements under section 4940(e) were met.
  
  
• Minimum payout requirement: Foundations were required to distribute about 5% of the average fair market value of investment assets annually for charitable purposes.
  
  
• Electronic filing: Required only for very large filers (250+ returns during the year and assets of $10M+). Most 2015 foundations filed on paper.
  
  
• State reporting: Foundations also had to provide copies of Form 990-PF (and any amendments) to state attorneys general in states where they were incorporated or operated.
  
  

Step-by-Step (High Level)

1. Gather records: Collect 2015 financial statements, investment reports, and IRS transcripts (via Form 4506-T if needed).
   
   
2. Prepare the correct form: Use the 2015 version of Form 990-PF, not the current year’s form.
   
   
3. Calculate excise tax: Report investment income in Part I and compute excise tax in Part VI at the correct 1% or 2% rate.
   
   
4. Check payout requirement: Use Part XI to confirm the foundation met its 5% charitable distribution.
   
   
5. Attach schedules: Include Schedule B (contributors), Part VII-B (self-dealing transactions), and Schedule O (explanations) as needed.
   
   
6. File and pay: Submit electronically if required, or by mail to the IRS Service Center in Ogden, UT, with any excise tax or penalties due.
   
   
7. Maintain records: Keep copies for at least 3 years, and ensure availability for public inspection.
   
   

Common Mistakes and How to Avoid Them

• Incorrect excise tax rate: Apply the 1% rate only if the five-year charitable distribution test is met.
  
  
• Underreporting payout requirement: Errors in valuing investment assets can trigger underdistribution penalties.
  
  
• Failure to report self-dealing: Part VII-B requires disclosure of transactions with disqualified persons; omissions can trigger Form 4720 excise taxes.
  
  
• Missing state notifications: Neglecting to send copies of Form 990-PF (and amendments) to relevant state officials.
  
  
• Unsigned returns: An unsigned Form 990-PF is considered incomplete and not filed.
  
  
• Incomplete public inspection procedures: Foundations must make their return available to the public upon request.
  
  

What Happens After You File

• Processing time: 6–12 months on average for late or amended 2015 returns.
  
  
• IRS notices: You may receive requests for additional documentation or penalty assessments.
  
  
• Penalties: Late filing penalties are $20/day (up to $10,000 or 5% of gross receipts), or $100/day (up to $50,000) for large foundations with gross receipts over $1M.
  
  
• Relief options: You may request reasonable cause abatement of penalties or set up an installment agreement (Form 9465) for excise tax or penalty balances.
  
  
• Appeals: You can dispute penalty assessments through the IRS Appeals Office.
  
  

FAQs

Q: What penalties apply for late filing?
A: $20/day up to $10,000 (or 5% of gross receipts) for smaller foundations; $100/day up to $50,000 for larger ones.

Q: Can I still get 2015 transcripts?
A: Yes, though details may be limited for older years. Use Form 4506-T to request account transcripts.

Q: Is there a refund deadline for excise taxes?
A: Yes, within 3 years of the original filing or 2 years of payment, whichever is later.

Q: Do amended returns go to states too?
A: Yes, send amended Form 990-PF copies to state attorneys general and officials originally entitled to the return.

Q: What if exempt status was revoked?
A: The foundation becomes taxable and must continue filing Form 990-PF until reinstated through Form 1023/1024.

Q: Can I pay penalties in installments?
A: Yes, by filing Form 9465 (Installment Agreement Request). Interest continues to accrue until paid.

Q: How long should records be kept?
A: At least 3 years for IRS examination purposes, and indefinitely for public inspection obligations.

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