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Reviewed by: William McLee
Reviewed date:
December 23, 2025

Form 990-PF Filing Checklist for Tax Year 2021

Overview and Applicability

Form 990-PF serves as the annual return for private foundations, requiring them to report their financial activities, distributions, and compliance with federal tax requirements. For the 2021 tax year, private foundations must keep track of their minimum investment returns in Part X and the amount they can distribute in Part XI, based on updated inflation limits set by statute. Foundations with assets of at least $5,000 at any time during the year must complete Part XV, which includes supplementary information. The excise tax on investment income in Part VI follows 2021 rates with specific provisions applicable to this form.

990-PF - 2021

Section 4960 tax on remuneration exceeding $1,000,000 applies to covered foundation employees and managers for 2021. When this tax is applicable, foundations must indicate liability in Part VII-B, line 8, and file Form 4720 to report and pay the excise tax. Status determinations for private operating foundations under sections 4942(j)(3) or 4942(j)(5) addressed in Part XIV remain unchanged but must be current as of the 2021 tax year.

990-PF - 2021

Foundation Status and Filing Requirements

Foundations must confirm their status as section 501(c)(3) private foundations, section 4947(a)(1) nonexempt charitable trusts treated as private foundations, or other taxable private foundations eligible to file Form 990-PF. The foundation should certify the fair market value of all assets at the end of 2021 by completing Part II, column (c), line 16. Part VII-A, question 7, requires foundations to indicate whether they had at least $5,000 in assets at any time during the year. If the answer is yes, the foundation must complete Part II column (c) fair market value reporting and Part XV supplementary information.

990-PF - 2021

Nonresident aliens and foreign foundations have a limited scope for filing. Foreign organizations meeting specific requirements are subject to different excise tax rates in Part VI, line 1c, and the tax is calculated as 4% of Part I, line 12, column (b), instead of the domestic rate of 1.39% for 2021.

990-PF - 2021

Revenue and Expense Documentation

Foundations must gather and organize comprehensive financial records for Part I, the Analysis of Revenue and Expenses. This includes bank statements, investment account statements, contribution records, and transaction logs. Documentation should cover contributions, gifts, and grants received reported on Part I, line 1; interest and dividends on savings and securities on lines 3 and 4; rental income on line 5; and sales of assets on lines 6 through 8.

990-PF - 2021

Foundations should prepare detailed schedules for any lines marked with schedule requirements, including line 1 if contributions require detailed reporting, line 5c for rental expenses, line 6b for cost of goods sold, and various other expense lines, including 9, 10c, 11, 16a through 16c, 18, 19, and 23. Part IX-B requires schedules for program-related investments. The accounting method elected by the foundation in the header of Form 990-PF applies consistently to all columns of Part I unless specific line instructions indicate otherwise.

990-PF - 2021

Balance Sheet Requirements

Part II requires foundations to reconcile the opening balances in column (a), beginning of year, with the prior year closing balances. Foundations must complete end-of-year book values in column (b) for all asset and liability lines. Fair market values must be entered in column (c) at the end of the year for all assets when the foundation had at least $5,000 in assets at any time during 2021.

990-PF - 2021

Foundations must verify that the total net assets in Part II, column (b), line 29, align with the opening balance in Part III, line 1. Detailed schedules are required for accounts receivable, pledges receivable, receivables from disqualified individuals, notes and loans receivable, investments, and land, buildings, and equipment showing basis and accumulated depreciation.

990-PF - 2021

Capital Gains and Losses

Part IV requires foundations to list all sales of assets during 2021, including date acquired, date sold, gross sales price, depreciation allowed, cost or other basis, and resulting gain or loss. For assets held on December 31, 1969, foundations must complete columns (i) through (l) showing fair market value on that date and on an adjusted basis to determine long-term capital gain treatment.

990-PF - 2021

Capital gains net income from Part IV, line 2, is transferred to Part I, line 7. Net short-term capital gain or loss from Part IV, line 3 transfers to Part I, line 8, column (c).

990-PF - 2021

Excise Tax Calculation

Part VI addresses the excise tax on investment income. Foundations must determine whether they qualify for an exception to the excise tax on Part VI, line 1a, by holding a ruling or determination letter on file. If no exception applies, domestic foundations calculate the excise tax as 1.39% of Part I, line 27b. Exempt foreign organizations meeting specific requirements enter 4% of Part I, line 12, column (b) on Part VI, line 1c.

990-PF - 2021

Foundations must add any tax under section 511 on Part VI, line 2, and subtract Subtitle A income tax on line 4, when applicable, to calculate tax based on investment income on line 5. Estimated tax payments, prior-year overpayments, and backup withholding are recorded to determine the amount due or overpayment.

990-PF - 2021

Activity Statements and Form 4720 Determinations

Part VII-A contains questions regarding lobbying, political activities, unrelated business income, business holdings, jeopardy investments, and foreign financial accounts. Certain affirmative answers require filing Form 1120-POL or Form 990-T. Part VII-B addresses self-dealing, excess business holdings, prohibited grants, and section 4960 remuneration, which may require Form 4720 filing.

990-PF - 2021

Officer and Employee Information

Part VIII requires foundations to list all officers, directors, and trustees, including compensation and benefits. Additional sections require reporting the five highest-paid employees and independent contractors paid more than $50,000. All required fields must be completed regardless of whether compensation was paid.

990-PF - 2021

Charitable Activities and Program Investments

Part IX-A summarizes the four largest direct charitable activities. Part IX-B describes the two most significant program-related investments and the total amount invested.

990-PF - 2021

Minimum Investment Return

Part X calculates the minimum investment return using average monthly fair market values of securities, cash, and other assets. After deducting acquisition indebtedness and cash held for charitable activities, the net value is multiplied by 5% to determine the minimum investment return.

990-PF - 2021

Distributable Amount

Part XI calculates the distributable amount using the minimum investment return, excise tax on investment income, and income tax for 2021. The adjusted distributable amount is shown on line 7 and carried forward for undistributed income analysis.

990-PF - 2021

Qualifying Distributions

Part XII calculates qualifying distributions, including charitable expenses, program-related investments, assets acquired for charitable use, and set-asides. Total qualifying distributions are carried to Part XIII for undistributed income analysis.

990-PF - 2021

Undistributed Income

Part XIII tracks undistributed income by year, applies excess distribution carryovers, and determines amounts required to be distributed in future years. Qualifying distributions are applied in the order specified by the form instructions.

990-PF - 2021

Filing Requirements and Assembly

After completing all required parts and schedules, an authorized representative must sign and date Form 990-PF. All schedules and attachments must be assembled in the proper order and filed according to IRS instructions for the 2021 tax year.

990-PF - 2021

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This checklist is for educational purposes only and does not constitute tax or legal advice. Always review official IRS instructions andconsult a qualified professional for guidance.

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