Form 990 2016: IRS-Accurate Tax-Year-Specific Checklist
Year-Specific Context
Form 990 for 2016 required organizations to report on calendar year 2016 or any tax year beginning in 2016 and ending in 2017. No stimulus reconciliation, energy credits, or TCJA rules applied to the 2016 form. ACA shared responsibility payment reporting was in effect through 2018, but applied only to certain health coverage entities, not general Form 990 filers. The 2016 form introduced no major line-item redesigns compared to 2015; Schedule B (donor disclosure) reporting requirements remained consistent with those of prior years for 2016 filings.
Year-Specific Compliance Items
Organizations with unrelated business gross income of $1,000 or more in tax year 2016 were required to file Form 990-T in addition to Form 990 or 990-EZ. For organizations operating hospital facilities, Section 501 (c) (3) requirements under the Patient Protection and Affordable Care Act mandated compliance to retain tax-exempt status; the 2016 form required completion of Schedule H for such facilities.
Ten-Step Checklist for Form 990, Tax Year 2016
Step 1: Determine Filing Requirement and Correct Form
Confirm organization gross receipts for 2016: if gross receipts were $200,000 or more OR total assets at the end of 2016 were $500,000 or more, file Form 990 (not 990-EZ or 990-N). If gross receipts were typically $50,000 or less and the organization chose not to file a full return, file Form 990-N, the e-postcard, instead. If gross receipts were $100,000 or more but less than $200,000 and total assets were less than $500,000, the organization could choose between Form 990-EZ and Form 990.
Step 2: Gather Officer, Director, and Compensation Documentation
Obtain W-2 forms, Form 1099-MISC, and Form 1099-NEC records for all officers, directors, trustees, key employees (persons with reportable compensation exceeding $150,000 from organization and related entities), and the five highest compensated employees (reportable compensation exceeding $100,000 from organization and related entities not otherwise listed). Document names, titles, time devoted to position, and reportable compensation from all sources for each person listed in Part VII, Section A.
Step 3: Verify and Document Unrelated Business Income
Calculate total unrelated business gross income from Part VIII, column (c), line 12 for 2016. If unrelated business gross income was $1,000 or more, prepare to file Form 990-T (Exempt Organization Business Income Tax Return) and report net unrelated business taxable income on Form 990, Part I, line 7b. Do not include unrelated business income on the organization’s exempt-purpose revenue lines.
Step 4: Assemble Revenue and Expense Documentation
Gather all source documents for contributions and grants (Part VIII, line 1h), program service revenue (Part VIII, line 2g), investment income (Part VIII, lines 3, 4, and 7d), and other revenue (Part VIII, lines 5, 6d, 8c, 9c, 10c, and 11e). Compile functional expense allocation by category: grants and similar amounts paid (Part IX, column (A), lines 1–3), salaries and compensation (Part IX, column (A), lines 5–10), professional fees including fundraising (Part IX, column (A), line 11e), and occupancy and depreciation (Part IX, column (A), lines 16 and 22).
Step 5: Determine Required Schedules Based on 2016 Activities
Complete the checklist in Part IV of Form 990 (lines 1–38) to identify all applicable schedules. Key thresholds for 2016: if the organization reported more than $5,000 in grants to domestic organizations or domestic governments, complete Schedule I, Parts I and II. Suppose professional fundraising expenses exceeded $15,000 (Part IX, column (A), lines six and 11e).
Complete Schedule G, Part I if the fundraising event gross income and contributions exceeded $15,000 (Part VIII, lines 1c and 8a); complete Schedule G, Part II. Suppose gaming activities' gross income exceeded $15,000 (Part VIII, line 9a); complete Schedule G, Part III. All Form 990 filers must complete Schedule O (Supplemental Information).
Step 6: Report Grants and Assistance on Schedule I (If Required)
If the organization reported more than $5,000 of grants or other assistance to any domestic organization or domestic government (Part IX, column (A), line 1), attach Schedule I, Parts I and II. Provide the recipient organization name, EIN, IRC section (if applicable), amount of cash grant, noncash assistance amount and description, and purpose of grant for each grant exceeding $5,000.
Step 7: Report Donor Information on Schedule B (If Applicable)
For organizations filing Form 990 for tax year 2016, if contributions totaled $5,000 or more from any one contributor during 2016, complete Schedule B (Form 990), Parts I and II, with contributor name, address, total contributions, and type of contribution (person, payroll, noncash).
For ALL organizations filing Form 990 in 2016, include contributor names and addresses on Schedule B; the regulatory change permitting specific 501(c)(4) and 501(c)(6) organizations to omit names and addresses on Schedule B was not effective until May 28, 2020, and does not apply to 2016 tax year filings.
Step 8: Document Governance, Policies, and Compliance
Complete Part VI (Governance, Management, and Disclosure) for all organizations filing Form 990. Confirm in Part VI, line 1a, the number of voting members of the governing body at the end of the 2016 tax year. Provide documentation of the conflict of interest policy (line 12a), whistleblower policy (line 13), document retention and destruction policy (line 14), and process for board review of Form 990 before filing (line 11a).
Prepare a Schedule O narrative explaining the governance structure, any changes to governing documents, and any diversions of assets identified during 2016.
Step 9: Complete Balance Sheet and Asset Disposition Reporting
Prepare Part X (Balance Sheet) showing the beginning and end of the 2016 year's asset and liability balances: cash (line 1), pledges and grants receivable (line 3), accounts receivable (line 4), land, buildings, and equipment (line 10a), investments in securities (line 12), other assets (line 15), total assets (line 16), total liabilities (line 26), and net assets (line 27 or 28).
If the organization sold, exchanged, disposed of, or transferred more than 25% of its net assets during 2016, complete Part IV, line 32, and attach Schedule N, Part II. If the organization liquidated, terminated, or dissolved and ceased operations during 2016, complete Part IV, line 31, and attach Schedule N, Part I.
Step 10: Sign, Date, and Assemble for Filing
Complete Part II (Signature Block) with the organization’s officer or authorized representative signature and date (must be within the later of 4 months and 15 days after the 2016 tax year ended or the extended due date). Include a preparer declaration if a paid preparer completed the return. For organizations with tax-exempt bond issues outstanding at more than $100,000 in the principal amount issued after December 31, 2002, attach Schedule K (Supplemental Information on Tax-Exempt Bonds).
Assemble all required schedules (A–N as applicable and Schedule R for related organizations) and Schedule O in alphabetical order behind Form 990 core pages. Do not include Social Security numbers, as Form 990 is publicly available.
2016 Form 990: Notable Updates
Schedule B (Donor Disclosure) – 2016 Requirements
For the 2016 tax year filings, ALL organizations filing Form 990 were required to report contributor names and addresses on Schedule B if contributions totaled $5,000 or more from any one contributor. The regulatory change permitting other 501(c) organizations to omit contributor names on Schedule B was effective May 28, 2020, and applies only to returns filed after that date. Organizations were required to maintain internal records of all substantial contributor information and make such records available to the IRS upon request.
Schedule O (Supplemental Information) – Mandatory for All Filers
The 2016 form reinforced that Schedule O was mandatory for all organizations filing Form 990 (not optional), emphasizing that supplemental narratives explaining governance practices and any “No” responses to Part VI governance questions must be documented. All Form 990 filers were required to complete Schedule O and provide explanations for Part VI, lines 11b and 19, regarding the board's review of the return and the process for making governance documents and financial statements available to the public.
Form-Specific Limitations and Restrictions for 2016 Form 990
Organizations filing Form 990 (not 990-EZ or 990-N) for 2016 could not claim or report any income tax credits, as the Form 990 is an information return only; tax liability is not computed on the form. Foreign organizations and those in U.S. possessions with gross receipts from U.S. sources of $50,000 or less that had no significant activity in the United States were exempt from filing Form 990 for 2016. Organizations that had not yet received IRS determination letters recognizing tax-exempt status but filed Form 990 in belief of exemption were required to check “Application pending” on Item B of the form heading.
Private foundations were not permitted to file Form 990 and were required instead to file Form 990-PF for 2016, regardless of financial size. Sponsoring organizations of donor-advised funds were required to file Form 990 (not 990-EZ) if any annual filing was needed. The form did not permit consolidated reporting from multiple entities with different employer identification numbers except through group return procedures for subordinate organizations.
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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.
