Form 990 Tax Year 2023 Filing Checklist
Overview
Form 990 for tax year 2023 requires tax-exempt organizations, nonexempt charitable trusts, and section 527 political organizations to report financial, governance, and operational information. The 2023 form introduces interactive help icons for electronic filers, clarifies Section 4960 excess compensation reporting, and updates the community benefit standards for hospitals. Organizations must file by the 15th day of the 5th month after the end of their fiscal year and may request an automatic six-month extension by filing Form 8868.
Filing Requirements
Organizations must file Form 990 when they have either gross receipts of $200,000 or more or total assets of $500,000 or more at the end of the year. Organizations with gross receipts typically less than $50,000 may file Form 990-N electronically. Organizations with gross receipts less than $200,000 and total assets less than $500,000 may file Form 990-EZ.
Section 509(a)(3) supporting organizations must file Form 990 or Form 990-EZ, regardless of size. Private foundations must file Form 990-PF. Organizations with $1,000 or more of unrelated business gross income must file Form 990-T in addition to Form 990.
Required Schedules
All organizations must complete Schedule O for supplemental information. Schedule A applies to Section 501(c)(3) organizations claiming public charity status. Supporting organizations must complete Schedule A, Part I, Line 12g, indicating whether each supported organization is named in its governing documents.
Schedule C applies to political campaign or lobbying activities. Schedule D applies to donor-advised funds, conservation easements, art collections, or endowment funds. Schedule E applies to private schools. Schedule F applies to activities outside the United States exceeding specified thresholds.
Schedule G applies when professional fundraising expenses exceed $15,000, or for fundraising events or gaming. Schedule H applies to hospitals with updated community benefit reporting guidance. Schedule I applies when grants or assistance exceeding $5,000 are provided to domestic organizations or individuals.
Schedule J applies when compensation reporting thresholds are met. Schedule L applies to excess benefit transactions, loans to interested persons, or business transactions with disqualified persons. Schedule M applies when noncash contributions exceed $25,000. Schedule N applies to the liquidation or disposal of more than 25 percent of the net assets. Schedule R applies to disregarded entities, related organizations, or unrelated partnerships.
Compensation Reporting
Part VII, Section A, must list all current officers, directors, and trustees, regardless of compensation. List up to 20 key employees with reportable compensation exceeding $150,000 from the organization and related organizations. List the five highest compensated employees with at least $100,000 who are not officers, directors, trustees, or key employees.
Report former officers, directors, trustees, key employees, and the highest compensated employees if they received more than $100,000 in reportable compensation in one of the five prior years, or more than $10,000 for former directors or trustees.
Section 4960 Excess Compensation
Organizations paying covered employees a total remuneration of $1,000,000 or more, including taxable fringe benefits, must complete Schedule O of Form 4720 and pay a 21 percent excise tax on excess amounts. Covered employees include any of the five highest-paid employees for the taxable year or any preceding year beginning after December 31, 2016. Licensed medical professionals receiving remuneration for medical or veterinary services are excluded.
Ten-Step Checklist
Step 1: Verify Filing Requirement
Determine whether your organization meets the $200,000 in gross receipts or the $500,000 in total assets threshold. Calculate gross receipts as total amounts received without subtracting expenses. Confirm whether you are a private foundation requiring Form 990-PF or a supporting organization requiring Form 990, regardless of size.
Step 2: Gather Documentation
Compile audited or reviewed financial statements for 2023. Collect all Forms W-2, 1099-NEC, and 1099-MISC for the year. Gather Forms 1099-R for retirement distributions, Forms 1098-C for vehicle donations exceeding $500, and Forms 8282 for disposed intellectual property or artwork.
Step 3: Complete Core Information
Provide the organization name, employer identification number, address, website, and principal officer information. Describe your mission concisely. Indicate organization type and state of legal domicile. Check appropriate boxes for initial, amended, or final return, or application pending status. Report total employees and volunteers.
Step 4: Prepare Financial Statements
Report all revenue sources in Part VIII, including contributions, program service revenue, investment income, and other revenue. Allocate all expenses in Part IX across program services, management and general, and fundraising categories. Complete Part X balance sheet showing beginning and end-of-year assets, liabilities, and net assets.
Step 5: Complete Part IV Checklist
Answer all 38 questions about organization activities, relationships, and transactions. Each "yes" response requires completion of the corresponding schedule. Review carefully to ensure no required schedules are omitted. Answer questions about disregarded entities, related organizations, and controlled entities under section 512(b)(13).
Step 6: Address Governance Questions
Answer Part VI questions about governing body meetings, conflict-of-interest disclosures, and uniform voting rights. Respond to policy questions regarding code of conduct, conflict-of-interest policy, whistleblower policy, and document retention policy. Document the Form 990 review process. Report voting members and independent voting members of the governing body.
Step 7: Complete Tax Compliance and Compensation
Answer Part V questions about federal employment tax returns and unrelated business income. Complete Schedule J if individuals listed in Part VII meet reporting thresholds. Report base compensation, bonus, and incentive compensation, other reportable compensation, and nontaxable benefits for each listed person.
Step 8: Complete Activity Schedules
Based on the responses in Part IV, complete the required schedules. Section 501(c)(3) organizations complete Schedule A, demonstrating public charity status. Organizations with professional fundraising exceeding $15,000 complete Schedule G. Hospitals complete Schedule H. Organizations with donor-advised funds complete Schedule D. Organizations with foreign activities exceeding thresholds complete Schedule F.
Step 9: Prepare Schedule O
All organizations must complete Schedule O. Provide narrative explanations for program service accomplishments, significant changes in activities, and governance policies. Explain Part VI lines 11b and 19 regarding board review and public disclosure. Explain no responses to governance policy questions. Describe unusual circumstances affecting operations.
Step 10: Sign and File
An authorized officer must sign under penalty of perjury, certifying that the return is accurate, correct, and complete. Provide name, title, and date. Paid preparers must sign and provide their tax identification number, as well as the firm's information. File by the 15th day of the 5th month after the fiscal year-end. Request an automatic six-month extension by filing Form 8868 before the original due date with no explanation required.
Key 2023 Updates
Question-mark icons provide interactive help on the electronic filing platform. Schedule H instructions clarify that accreditation-required activities may qualify as community benefits when addressing health needs. Supporting organizations must indicate whether supported organizations are named in governing documents. Schedule J instructions clarify compensation reporting from related and unrelated organizations.
Compliance Requirements
Organizations that fail to file for three consecutive years face automatic revocation of their tax-exempt status. Incomplete or inaccurate responses subject organizations to IRS inquiry, examination, or penalties. Electronic filings with errors may be rejected, requiring correction and resubmission. All compensation amounts, entity relationships, and program accomplishments must be accurate and supported by documentation.
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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.
