Form 990-EZ Tax Year 2019: IRS-Accurate Checklist
Why 2019 Form 990-EZ Is Unique
Form 990-EZ for 2019 introduced compliance language regarding Section 4960 excise tax on excess remuneration and clarified that organizations reporting $1,000 or more of unrelated business gross income must file Form 990-T. The 2019 edition incorporated FASB Accounting Standards Update 2016-14, requiring net asset classification as “with donor restrictions” or “without donor restrictions” in Part II (Balance Sheet) rather than “unrestricted,” “temporarily restricted,” and “permanently restricted.”
Organizations filing for the 2019 tax year must distinguish between qualified disaster relief contributions and regular contributions on Part I, Line 1. The form also clarified that donor-advised fund sponsoring organizations must file a Form 990, not Form 990-EZ, regardless of gross receipts or total assets.
Year-Specific Programs for 2019
No stimulus reconciliation or Affordable Care Act provisions directly apply to the 2019 Form 990-EZ. However, tax-exempt organizations with covered employees receiving compensation exceeding $1,000,000 must report Section 4960 excise tax exposure in Part V, line 15. They may need to file Form 4720 (Return of Certain Excise Taxes Under Chapters 41 and 42 of the Internal Revenue Code).
Section 512(b)(13) controlled entity reporting remains mandatory for lines 45a and 45b, consistent with the redesigned 990-EZ framework introduced in 2010. Organizations receiving qualified disaster relief contributions during 2019 may report those amounts separately on line 1 if they maintained contemporaneous records distinguishing disaster contributions from other donations.
Ten-Step Form 990-EZ Checklist for 2019
1. Verify Eligibility Under 2019 Thresholds
Confirm gross receipts are less than $200,000 AND total assets (Part II, column B) are less than $500,000. If both thresholds are met, the organization may file Form 990-EZ. Organizations maintaining donor-advised funds (line 44a), operating hospital facilities (line 44b), or controlled by organizations described in section 512(b)(13) (line 45a) must file Form 990 instead.
Private foundations are required to file Form 990-PF, regardless of their gross receipts or assets. For 2019, 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. Choose Accounting Method and Tax Year
Select the accounting method consistently used throughout the tax year: cash, accrual, or other specified method. Identify the tax year (calendar year or fiscal year beginning and ending in 2019) and record the ending date on the form header (page 1). For calendar-year 2019 filers, the tax year begins January 1, 2019, and ends December 31, 2019; the filing deadline is May 15, 2020, unless an extension is requested via Form 8868 (automatic six-month extension to November 15, 2020).
3. Assemble 2019 Revenue Documentation
Gather documentation for all revenue categories reported in Part I: contributions and grants (line 1), including donor-advised fund contributions (if prohibited) and qualified disaster relief contributions (if distinguishable); program service revenue (line 2); membership dues and assessments (line 3); investment income (line 4); sale of assets other than inventory gain or loss (line 5c); gross amounts from gaming (line 6a), fundraising events (line 6b), and sales of inventory (line 7a); and other revenue (line 8).
For qualified disaster relief contributions, maintain separate records and report totals separately on line 1 if requested. Ensure Forms 1099-MISC, 1099-INT, 1099-DIV, W-2, and donation receipts are available for all revenue categories.
4. Complete Part I Revenue and Expense Sections
Report 2019 revenue on lines 1 through 8: total contributions (line 1), program service revenue (line 2), membership dues (line 3), investment income (line 4), gain or loss from sales of assets (line 5c), gaming gross income less direct expenses (line 6a minus 6c), fundraising event gross income less direct expenses (line 6b minus 6c), and sales of inventory gross income less cost of goods sold (line 7a minus 7b).
Sum lines 1 through 8 to line 9, total revenue. Report expenses on lines 10 through 16: grants and similar amounts (line 10), benefits to members (line 11), salaries and employee benefits (line 12), professional fees (line 13), occupancy, rent, utilities, and maintenance (line 14), printing, postage, and shipping (line 15), and other expenses (line 16). Sum lines 10 through 16 to line 17, total expenses. Subtract line 17 from line 9 to calculate line 18, the excess or deficit for the year. Add line 18 to line 19 (net assets at the beginning of the year) to determine line 21 (net assets at the end of the year).
5. Complete Part II Balance Sheet
Enter beginning-of-year balances (column A) and end-of-year balances (column B) for 2019: 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). For 2019, apply FASB ASU 2016-14: classify net assets as “with donor restrictions” or “without donor restrictions” rather than “unrestricted,” “temporarily restricted,” and “permanently restricted.”
Line 27, column B (net assets at end of year) must equal Part I, line 21. Ensure the balance sheet reconciles with the audited financial statements if the organization is required to submit audited financial statements.
6. Describe Program Service Accomplishments in Part III
Provide a narrative description of the organization’s mission or most significant activities in the space provided. Describe each major program service accomplishment, including the total expenses for each program if applicable. For tax year 2019, 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 2019 program activities and outcomes.
7. List All Officers, Directors, Trustees, and Key Employees in Part IV
List all current officers, directors, trustees, and key employees as of the end of the 2019 tax year, even if not compensated. Enter -0- if no compensation was paid. For each individual, provide name, title, average hours per week, and reportable compensation from Form W-2 (Box 5) or Form 1099-MISC (Box 7). Include estimated other compensation (employer-paid health insurance, pension contributions, and other fringe benefits), if applicable.
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. Ensure consistency between Part IV compensation and amounts reported on Form 990-EZ Part I, line 12 (salaries and employee benefits).
8. Answer All Part V Other Information Questions
Complete lines 33 through 52 (or applicable subset) for the 2019 tax year. Answer “Yes” or “No” to each question. For organizations that checked the box on line 33 (Section 501 (c) (3) organization), also complete Part VI (Section 501 (c) (3) Organizations Only).
For 2019, critical questions include: line 35a (significant changes to organizing or governing documents); line 36 (liquidation, termination, dissolution, or substantial asset sale); lines 37a and 37b (political expenditures); line 38a (section 4958 excess benefit transactions); line 39 (unrelated business income of $1,000 or more, requiring Form 990-T); line 40b (section 6033(e) notice required); line 40d (donor-advised funds or accounts); line 44a (donor-advised funds); line 44b (hospital facilities); lines 45a and 45b (section 512(b)(13) controlled entities); and line 46 (section 4947(a)(1) nonexempt charitable trust).
9. Prepare and Attach Required Schedules
Add Schedule A (Public Charity Status and Public Support) if the organization checked the box on line 33 (Section 501 (c) (3)). Attach Schedule B (Schedule of Contributors), listing all contributors who gave $5,000 or more during 2019; 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 G (Supplemental Information Regarding Fundraising or Gaming Activities) if line 6a (gaming gross income) exceeds $15,000 OR if the sum of contributions from fundraising events (included in line 1) plus line 6b (gross fundraising income) exceeds $15,000. Attach Schedule L (Transactions With Interested Persons) if any transactions or relationships with interested persons occurred in 2019.
Schedule O (Supplemental Information) is required for all organizations that file Form 990 and for specific organizations that file Form 990-EZ, which must provide narrative information for responses to specific questions requiring supplemental explanation, as outlined in Part V of Form 990-EZ, and governance questions in Part VI. If unrelated business gross income is $1,000 or more, file Form 990-T (Exempt Organization Business Income Tax Return) separately by the same due date as Form 990-EZ.
10. Sign, Date, and Assemble for Filing
An authorized officer must sign and date the return on page 4 under penalties of 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 check the self-employed box if applicable.
For calendar-year 2019 filers, the filing deadline is May 15, 2020. Request an automatic six-month extension to November 15, 2020, using Form 8868. Assemble the return in the following order: Form 990-EZ core (pages 1–4), Schedule A, Schedule B, Schedule G (if applicable), Schedule L (if applicable), Schedule O (if applicable), and any required attachments. Mail the completed return to the IRS address specified in the 2019 Form 990-EZ instructions for your organization’s location.
Form-Specific Limitations
Organizations filing Form 990-EZ are not permitted to maintain donor-advised funds or operate hospital facilities; instead, such organizations must file Form 990. Private foundations must file Form 990-PF, not 990-EZ. 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 not eligible to file Form 990-EZ.
Schedule B is confidential for most 501 (c) (3) organizations but is publicly disclosed for Section 527 political organizations and private foundations. 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. For 2019, Schedule O supplemental information is required for specific Part V and Part VI responses, but is not universally mandatory for all 990-EZ filers unless narrative explanations are required.
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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.
