Form 990 Tax Year 2014 Filing Checklist
Year-Specific Context
Form 990 for 2014 introduced expanded Schedule A with Parts IV and V for Type III supporting organizations under section 509(a)(3) regulations. Compensation is not considered deferred if paid within two and a half months after the calendar year ends. The Affordable Care Act's employer shared responsibility provisions became effective in 2015 for applicable large employers with 100 or more full-time employees and in 2016 for employers with 50–99 full-time employees.
Filing Requirements
File Form 990 if gross receipts are at least $200,000 or total assets are at least $500,000 at year-end. Section 509(a)(3) supporting organizations must file Form 990 or Form 990-EZ, regardless of gross receipts. Organizations with gross receipts ≤$50,000 may file Form 990-N. Organizations with gross receipts of $50,000 to $199,999 and total assets of under $500,000 may file Form 990-EZ; private foundations file Form 990-PF.
Ten-Step Filing Checklist
Step 1: Verify Filing Requirement and Complete Heading
Confirm gross receipts ≥$200,000 or total assets ≥$500,000 at year-end. Support organizations file regardless of gross receipts. Complete heading Items A-F and H(a)-M with 2014 tax year dates.
Step 2: Gather Schedule A Documentation
The 501(c)(3) and 4947(a)(1) organizations complete Schedule A. Supporting organizations complete new Part IV (11 compliance questions). Type III: non-functionally integrated supporting organizations complete Part V with distribution and attentiveness data. Obtain multi-year public support calculations.
Step 3: Collect Compensation Records
List all current officers, directors, trustees (regardless of compensation); up to 20 key employees (compensation >$150,000); five highest compensated employees (>$100,000); and former officers/key employees (>$100,000 or >$10,000 if a former director or trustee) —report compensation for the calendar year. Compensation paid within 2½ months after the end of the year is not deferred.
Step 4: Complete Parts VIII, IX, and X
Part VIII: Report contributions (line 1h), program revenue (line 2g), investment income (lines 3-4), royalties (line 5), rental income (lines 6a-6b), and other revenue. Total flows to Part I, line 12.
Part IX: Allocate expenses across program services, management/general, and fundraising. If other costs (line 25) exceed 10% of total functional expenses, detail them on Schedule O.
Part X: Report beginning and ending balances for assets and liabilities. Total assets (line 16) must equal total liabilities (line 26) plus net assets (line 27 or 32).
Step 5: Answer Part IV Checklist
Determine required schedules: Schedule A (501(c)(3)/4947(a)(1)); Schedule B (contributions ≥$5,000 from a single contributor); Schedule D (property/investments); Schedule F (international activities above thresholds); Schedule G (fundraising/gaming >$15,000); Schedule H (hospitals); Schedule I (grants >$5,000); Schedule J (former officers/compensation); Schedule L (transactions with interested persons); Schedule M (noncash contributions >$25,000); Schedule R (related organizations). File Form 990-T separately if unrelated business income ≥$1,000.
Step 6: Complete Part V
Report unrelated business activity (line 3a) and Form 990-T filing (line 3b). On line 6c, report ACA employer shared responsibility compliance. For 2014, report preparation for the 2015 mandate (100+ employees). Employers issue Forms 1095-B (for self-insured plans) or 1095-C (for applicable large employers); The Marketplace issues Form 1095-A.
Step 7: Complete Part VI (Governance)
Report voting and independent governing body members. Disclose business/family relationships among officers, directors, trustees, and key employees. Report written policies: conflict of interest (line 12a), whistleblower (line 13), and document retention (line 14). Describe the compensation review process for the CEO/top management (line 15a) and other officers/key employees (line 15b). On line 11, answer 'yes' if the governing body reviewed Form 990 before filing.
Step 8: Complete Part VII (Compensation)
Section A: List current officers, directors, and trustees; up to 20 key employees (compensation >$150,000); the five highest compensated employees (>$100,000); and former officers/employees (>$100,000 or >$10,000 for the former director/trustee). Report compensation for the calendar year and hours worked for the filing organization and related organizations.
Section B: List five highest compensated independent contractors (>$100,000).
Step 9: Complete Schedule L
For 501(c)(3), 501(c)(4), or 501(c)(29) organizations: Report excess benefit transactions (Part I); loans to/from officers, directors, trustees, key employees, or disqualified individuals (Part II); grants to officers, directors, trustees, key employees, substantial contributors, or family (Part III); and business transactions with interested persons if aggregate payments are greater than $100,000 or a single transaction is greater than $10,000 or greater than 1% of total revenue (Part IV).
Step 10: Complete Schedule R
If Part IV lines 33-37 answered yes, list disregarded entities (Part I); related tax-exempt organizations (Part II); partnerships (Part III); related for-profit organizations (Part IV); transactions with related organizations (Part V); and unrelated partnerships conducting >5% of activities (Part VI). Do not report disregarded entity transactions in Part V.
Step 11: Complete Schedule O and Other Schedules
Use Schedule O for narrative explanations requested by Form 990 and schedules (e.g., Part IV: yes answers and Part VI: no answers requiring an explanation). Not all filers require Schedule O—only those providing specifically requested explanations. Complete Part XI (net asset reconciliation) and Part XII (financial statements and reporting).
Step 12: Sign and Assemble
Authorized officer signs under penalty of perjury. The paid preparer provides the PTIN, firm name, and EIN. Assemble Form 990 with required schedules. Schedule B (substantial contributors with TINs) is not publicly disclosed under IRC section 6104(d); all other schedules are public. Omit SSNs on public portions. Refer to the IRS Where to File page for mailing instructions.
Key 2014 Changes
Schedule A added Parts IV and V for supporting organizations. Part IV includes 11 compliance questions for all supporting organizations. Part V requires Type III non-functionally integrated supporting organizations to provide financial verification of distributions and attentiveness, demonstrating their responsiveness to the supported organizations.
Part VII clarified that compensation is not treated as deferred if paid within two and one-half months after calendar year-end. This timing clarification helps organizations properly classify compensation as current year or deferred.
Part XI reconciliation instructions were updated with new instructions for lines 5, 6, and 8, specifying that amounts must match financial statements when applicable. This improves consistency between Form 990 and audited financial statements.
Form Limitations
Form 990 is for organizations exempt under section 501(a) and described in section 501(c), section 527, or section 4947(a)(1). Private foundations file Form 990-PF, not Form 990. Organizations with gross receipts of $50,000 or less may file Form 990-N. Organizations with gross receipts of $50,000 to $199,999 and total assets under $500,000 may file Form 990-EZ.
Section 509(a)(3): Supporting organizations must file Form 990 or Form 990-EZ regardless of gross receipt size, and they cannot file Form 990-N.
Sponsoring organizations of donor-advised funds must file Form 990, not Form 990-EZ.
Organizations filing short-period returns of less than 12 months generally cannot file electronically and must file Form 990 on paper. Form 990 does not permit organizations to claim income tax credits, as it reports tax-exempt organization activity, not taxable income.
Conclusion
Filing Form 990 for tax year 2014 requires accurate revenue and expense reporting, functional expense allocation, comprehensive compensation disclosure for officers, directors, trustees, key employees, and highest compensated employees, completion of required schedules based on specific thresholds, and thorough governance disclosures.
The 2014 form introduced expanded Schedule A requirements for supporting organizations with new Parts IV and V, clarified deferred compensation timing, and updated reconciliation instructions. Organizations must use 2014 instructions and report for the appropriate tax year ending in 2014. Following this checklist ensures accurate and compliant completion of Form 990 for tax year 2014.
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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.
