Form 990-EZ Tax Year 2020 Checklist
2020 Form 990-EZ: Why This Year Matters
For 2020, Form 990-EZ filers transitioned to a new compliance landscape with updated Form 1099-NEC reporting requirements for nonemployee compensation, replacing the prior Form 1099-MISC Box 7 approach. Electronic filing became mandatory for Form 990 beginning July 31, 2020. However, Form 990-EZ remained eligible for voluntary e-filing through calendar year 2021, creating timing implications for organizations managing accounting period changes within the 2020 tax year window.
Organizations filing for fiscal years ending in calendar year 2020 must respond to inquiries about indoor tanning services (Part V, line 44c) and indicate whether the organization received payments for indoor tanning services, even if the answer is no. If the organization claimed exempt status but had not yet received IRS recognition by the filing deadline, the “Application pending” box must be checked in Item B of the form heading; such organizations file according to section 6033 requirements, assuming tax-exempt status.
2020 Year-Specific Programs Applicable to Form 990-EZ
No stimulus reconciliation or Affordable Care Act provisions directly apply to the 2020 Form 990-EZ. However, organizations with gross income from unrelated business activities of $1,000 or more must file Form 990-T separately, reporting unrelated business taxable income. Section 512(b)(13) controlled entity reporting remains mandatory for Part V, line 45a and line 45b, consistent with the redesigned 990-EZ framework introduced in 2010.
For 2020, organizations must also comply with new Form 1099-NEC reporting rules, effective for the 2020 tax year, which require nonemployee compensation to be reported on Form 1099-NEC rather than Form 1099-MISC, Box 7. This change affects compensation reporting for independent contractors and key employees listed in Part IV and Part VI of Form 990-EZ.
Ten-Step Form 990-EZ Compliance Checklist: 2020 Tax Year
1. Verify Eligibility
Confirm gross receipts are less than $200,000, AND total assets (Part II, column B, line 25) are less than $500,000 at the end of the tax year. Organizations that maintain donor-advised funds, operate hospital facilities, or are described in section 512(b)(13) must instead file Form 990, regardless of revenue or assets.
Private foundations must file Form 990-PF, not Form 990-EZ. For 2020, organizations choosing the Form 990-N e-Postcard must have gross receipts of $50,000 or less. Those exceeding $50,000 but under $200,000 may file Form 990-EZ if their assets are under $500,000.
2. Confirm Accounting Period and Filing Date
Enter exact dates in Item A (heading): the fiscal year began in 2020 and ended in 2021 for fiscal year filers, or the calendar year January 1, 2020, through December 31, 2020, for calendar year filers. Due date: 15th day of the 5th month after the fiscal year end. For calendar-year 2020 filers, the filing deadline is May 15, 2021.
If filing a short year that began in 2020 and ended before December 31, 2020, either the 2019 or 2020 Form 990-EZ may be used. If the short year starts in 2021 and ends before December 31, 2021, use the 2020 form. Request an automatic six-month extension to November 15, 2021, using Form 8868.
3. Gather and Reconcile Revenue Documentation
Collect Forms 1098-T, 1099-MISC, 1099-NEC (for nonemployee compensation, effective 2020), W-2s, and donation receipts. Line 1 (contributions) must not include “unusual grants”; prepare a supporting list (see Schedule A if applicable). Ensure Forms 1099-INT, 1099-DIV, and capital gains/losses records are available for investment income (line 4) and sale of assets (line 5c).
Line 9 total (sum of lines 1, 2, 3, 4, 5c, 6d, and 7b) must equal the organization’s total revenue for the tax year. For qualified disaster relief contributions, maintain separate records and report totals separately on line 1 if requested.
4. Identify Unrelated Business Income Reporting
If gross income from unrelated business activities is $1,000 or more (Part V, line 35a), answer “Yes” and file Form 990-T (Exempt Organization Business Income Tax Return) separately by the same due date as Form 990-EZ. Indicate the amount on Part V, line 35a. If unrelated business taxable income exists, report the total on Form 990-EZ line 7b from Form 990-T, Part I, line 11. For 2020, ensure all unrelated business activities are appropriately documented and allocated between exempt and nonexempt functions.
5. Complete Financial Statements (Parts I and II)
Part I (Revenue, Expenses, Changes in Net Assets): Report 2020 revenue on lines 1 through 8 and expenses on lines 10 through 17. Lines 10 through 17 total expenses; line 18 excess or deficit. Line 21 net assets at the end of the year must equal Part II, line 27 (total assets minus total liabilities).
Part II Balance Sheets: Report beginning-of-year balances (column A) and end-of-year balances (column B) for 2020: cash, savings, and investments (line 22), land and buildings (line 23), other assets (line 24), total assets (line 25), total liabilities (line 26), and net assets or fund balances (line 27). Reconciliation: Part I, line 21 must equal Part II, line 27. Ensure the balance sheet reconciles with the audited financial statements if the organization is required to submit audited financial statements.
6. Document Program Service Accomplishments (Part III)
Describe three most significant program service accomplishments in the space provided. Provide a narrative description of the organization’s mission or most significant activities. Report total program service expenses from Part I, line 14. If substantial new activities occurred in 2020, detailed descriptions are required in Schedule O, Part V, line 33.
For tax year 2020, ensure descriptions are accurate, precise, and demonstrate how the organization fulfilled its exempt purpose during the tax year. Do not use boilerplate or generic descriptions that apply to any organization; the IRS instructions specify that this section must reflect actual 2020 program activities and outcomes.
7. List Officers, Directors, Trustees, Key Employees (Part IV)
List each person serving in these roles at any time during the 2020 tax year, regardless of compensation. Include names, titles, average hours per week, reportable compensation (Forms W-2/1099-MISC/1099-NEC), health benefits, and estimated other compensation. The title column is required; addresses are not required. For 2020, ensure all nonemployee compensation reported on Form 1099-NEC (effective 2020) is included in Part IV compensation totals.
Key employees are defined as any person who had reportable compensation of more than $150,000 from the organization and any related organizations and who meets specific responsibilities. Enter -0- if no compensation was paid. Ensure consistency between Part IV compensation and amounts reported on Form 990-EZ Part I, line 12 (salaries and employee benefits).
8. Complete Part V (Other Information) and Governance Questions
Answer all Yes/No questions, including significant activities (line 33), unrelated business income (line 35a through c), changes to governing documents (line 34), political expenditures (line 37), loans to insiders (line 38a through b), excess benefit transactions (line 40b), donor-advised funds (line 44a), indoor tanning service payments (line 44c), and controlled entities (line 45a and 45b).
For any “Yes” answers that require explanation, please attach Schedule O with the details. For 2020, critical questions include: line 33 (significant changes to organizing or governing documents); line 34 (unrelated business income of $1,000 or more, requiring Form 990-T); line 37 (political expenditures); line 38a (section 4958 excess benefit transactions); line 40b (section 6033(e) notice required); line 44a (donor-advised funds); line 44c (indoor tanning service payments); and lines 45a and 45b (section 512(b)(13) controlled entities).
9. Complete Part VI (501(c)(3) Organizations Only)
If the organization is a section 501(c)(3), answer questions 47 through 49b and complete compensation tables (lines 50 through 51) for the five highest-paid employees and independent contractors earning over $100,000 (excluding officers, directors, trustees, and key employees already listed in Part IV).
Attach completed Schedule A (Public Charity Status and Public Support) confirming public charity status. Answer line 52, confirming Schedule A's completion. For 2020, ensure all compensation reported on lines 50 and 51 includes amounts from Form 1099-NEC (nonemployee compensation) rather than Form 1099-MISC Box 7.
10. Prepare and Sign Return; Attach Required Schedules
Ensure that all parts are completed, calculations are verified, and explanations are entered in Schedule O where required. An authorized officer is required to sign and date the return on page 4, subject to penalties for perjury. Print or type the signer’s name, title, date, and telephone number. If a paid preparer completed the form, they must sign, date, provide preparer-use-only information (PTIN, firm name, firm EIN, and firm address), and verify the self-employed box if applicable.
Attach Schedule A (Form 990 or 990-EZ) if the organization is a 501(c)(3). Attach Schedule B (Schedule of Contributors) if contributors gave $5,000 or more; Schedule B is filed with the IRS but is not publicly disclosed for most 501(c) organizations (except section 527 political organizations and private foundations). Attach Schedule O if any Part V or Part VI question was answered “Yes” and an explanation was provided. Attach any other schedules indicated by Part V answers (for example, Schedule C, D, E, F, G, L, N as applicable). Do not mail Form 8453 or Form 8868 unless an extension is requested.
See IRS publication “Where to File” for the 2020 Form 990-EZ paper filing address. For calendar-year 2020 filers, the filing deadline is May 15, 2021. Assemble the return in the following order: Form 990-EZ core (pages 1 through 4), Schedule A, Schedule B, Schedule G (if applicable), Schedule L (if applicable), Schedule O (if applicable), and any required attachments.
Form 990-EZ Specific Limitations (2020)
Organizations cannot file Form 990-EZ if they maintain donor-advised funds, operate hospital facilities, are recognized as section 501(c)(29) nonprofit health insurance issuers, or are controlling organizations under section 512(b)(13); these entities must file a complete Form 990 regardless of gross receipts or asset thresholds. Private foundations cannot use Form 990-EZ; instead, they should use Form 990-AD. Organizations with gross receipts of $200,000 or more, or total assets of $500,000 or more, must file Form 990 instead.
Foreign organizations and domestic organizations outside the United States or its possessions are generally required to file a form in addition to Form 990-EZ. Organizations reporting unrelated business gross income of $1,000 or more must file Form 990-T separately and cannot report such income solely on Form 990-EZ.
2020 Line and Schedule Updates for Form 990-EZ
Beginning with the 2020 tax year, nonemployee compensation reported on Form 1099-NEC (replacing 1099-MISC box 7) must be included in Part IV compensation totals and in determining officer and key employee threshold calculations. Part V, lines 44 and 45 on Form 990-EZ address donor-advised funds and controlled entities, not Section 4960 or Section 4968 excise taxes.
These excise tax questions do not appear on Form 990-EZ; they are specific to Form 990. For 2020, questions regarding indoor tanning service payments remain on Part V, lines 44c and 44d, requiring organizations to answer whether they received payments for indoor tanning services and whether Form 720 was filed, if applicable.
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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions and consult a qualified professional for guidance.
