Form 990 Tax Year 2013: IRS-Accurate Checklist for Paper Filing
Why the 2013 Form 990 Differs from Prior Years
The 2013 Form 990 introduced clarifications on accounting period changes requiring section 481(a) adjustment reporting in Parts VIII through XI; revised Schedule A instructions for Type III functionally integrated and non-functionally integrated supporting organizations reflecting final December 28, 2012 regulations; updated Schedule D program-related investment reporting requiring separate line description for each investment with loan/equity classification; expanded Schedule H guidance on direct offsetting revenue and financial assistance definitions for hospitals; and formalized Schedule N documentation requirements for liquidation, termination, dissolution, or merger activities.
Year-Specific Rules Applicable to 2013 Form 990
Organizations changing their accounting period during 2013 must report section 481(a) adjustments in Parts VIII through XI of Form 990 and Parts XI–XII of Schedule D to prevent duplication or omission of income or expense items. Type III functionally integrated supporting organizations must demonstrate they are responsive to the needs or demands of one or more supported organizations under final regulations effective December 28, 2012, with instructions in 2013 Schedule A clarifying the notification requirement, responsiveness test, and integral part test. No stimulus reconciliation, ACA shared responsibility payment thresholds, TCJA rules, or ARPA expansions apply to the 2013 tax year.
Ten-Step Checklist for Form 990 Tax Year 2013
Step 1: Determine Filing Requirement and Form Selection
Verify the organization has gross receipts of $200,000 or more or total assets of $500,000 or more at the end of the tax year; if yes, Form 990 (complete form) is required. If gross receipts are usually $50,000 or less, the organization may file Form 990-N electronic notice instead, unless it is a section 509(a)(3) supporting organization (which must file Form 990 or 990-EZ regardless of receipts).
Step 2: Collect Heading Information and Identify Changes
Complete Form 990 Heading Items A–M: tax year, organization name, EIN, address, and telephone. Check the appropriate boxes for the final return/terminated status, the amended return, or the application pending status. If the organization has undergone a name change in 2013, attach a copy of the amendment to the articles of incorporation with proof of state filing; for trusts and unincorporated associations, the attachment must be signed by at least one trustee (trusts) or two officers/trustees/members (associations) and bear the effective date of the name change.
Step 3: Complete Core Financial and Organizational Parts
Complete Part I (Summary) with mission description, employee and volunteer counts, and governance information. Complete Part III (Program Service Accomplishments) by describing the three most extensive program services measured by expenses. Complete Part IV (Checklist of Required Schedules) by answering each question to identify which supplemental Schedules A–N and Schedule R must be filed.
Complete Parts V, VI, and VII with compliance certifications, governance disclosures, and compensation reporting for officers, directors, trustees, key employees (those with reportable compensation greater than $150,000), and the five highest compensated employees with reportable compensation of at least $100,000 from the filing organization and related organizations.
Step 4: Prepare Financial Statements—Parts VIII, IX, X
In Part VIII, report all revenue sources: contributions, grants, program service revenue, investment income, gaming/fundraising revenue, and other income; ensure column (A) total revenue (line 12) matches Part I line 12. In Part IX, allocate expenses by functional category (program services, management, fundraising) across three columns, with total on line 25 matching Part I line 18. In Part X, list assets (cash, investments, receivables, fixed assets, other assets) with beginning and ending balances; list liabilities (payables, escrow accounts, debt, other liabilities) with beginning and ending balances; and reconcile net assets on lines 27–34.
Step 5: Reconcile Net Assets and Disclose Accounting Methods—Parts XI and XII
In Part XI, begin with net assets at the beginning of the year (line 1a), add total revenue (line 3), subtract total expenses (line 4), add unrealized gains/losses on investments (line 6), subtract donated services and use of facilities (line 8), subtract investment expenses (line 7), and record other changes (line 9) to arrive at net assets at end of year (line 11).
In Part XII, disclose the accounting method (accrual or cash), indicate whether audited or reviewed financial statements were prepared, and answer whether a single audit was required under Federal Audit Clearinghouse rules (if the organization received $500,000 or more in federal awards).
Step 6: Identify and Attach Required Schedules Based on Part IV Responses
For each “Yes” answer in Part IV Checklist, attach the corresponding supplemental Schedule: Schedule A (Public Charity Status and Public Support) if organization is a 501(c)(3) or 4947(a)(1) nonexempt charitable trust; if Type III functionally integrated or non-functionally integrated supporting organization, ensure instructions requiring responsiveness test and integral part test documentation are applied. Schedule B (Contributors) if contributors donated $5,000 or more during the year or 2 percent or more of total contributions. Schedule C (Political and Lobbying Activities) for section 501(c)(3) organizations engaging in political campaign activities or lobbying.
Schedule D (Supplemental Financial Statements) for organizations reporting depreciation, conservation easements, art/historical treasures, endowments, or significant assets/liabilities; for program-related investments, the organization must describe each investment on a separate line, indicate whether a loan or equity investment, and identify domestic organizations in which investments are made. Schedule E (Schools) if the organization is a private school.
Schedule F (Statement of Activities Outside the United States) if the organization reported foreign activities or grants/assistance to foreign organizations or individuals exceeding $5,000. Schedule G (Supplemental Information Regarding Fundraising or Gaming) if professional fundraising expenses exceeded $15,000 or gross income from gaming/fundraising events exceeded $15,000. Schedule H (Hospitals) if the organization operated a hospital facility during the year. Schedule I (Grants and Other Assistance) if the organization made grants/assistance over $5,000 to domestic organizations or governments.
Schedule J (Compensation) if applicable thresholds are met. Schedule K (Supplemental Information on Tax-Exempt Bonds) if the organization had an outstanding tax-exempt bond issue with principal exceeding $100,000 at the end of the year. Schedule L (Transactions With Interested Persons) for excess benefit transactions, loan receivables/payables from interested persons. Schedule M (Noncash Contributions) if aggregate noncash contributions exceeded $25,000 or the organization received artwork, historical treasures, or qualified conservation contributions regardless of value.
Schedule N (Liquidation, Termination, Dissolution, or Significant Disposition of Assets) if the organization is liquidated, terminated, or disposed of more than 25 percent of its net assets. Schedule O (Supplemental Information) required for all Form 990 filers; provides narrative explanations for Part IV checkboxes, Part VI governance questions, and supplemental details for each applicable schedule. Schedule R (Related Organizations and Unrelated Organizations) should be completed if the organization has related organizations or controlled entities that require disclosure.
Step 7: Report Unrelated Business Income and Employment Taxes—Part V
Answer question 3 regarding unrelated business gross income; if the organization had $1,000 or more of gross income from unrelated trade or business during 2013, file Form 990-T in addition to Form 990; indicate whether Form 990-T was filed (line 3b). Report whether the organization filed required federal employment tax returns (Form 940, 941, 943, 944, or 945) if it had employees (line 2a–2b). Report backup withholding compliance and Form 8886-T filings for transactions meeting the prohibited tax shelter transaction definition (if applicable).
Step 8: Disclose Governance, Conflicts of Interest, and Policies—Part VI
Report the number of voting members of the governing body and the number who are independent (lines 1a–1b). Disclose whether the organization has a written conflict-of-interest policy (line 12a), whistleblower policy (line 13), and document retention/destruction policy (line 14). Disclose the process for determining compensation for the CEO/top officer and key employees, including whether independent persons reviewed comparability data and contemporaneously substantiated the decision (lines 15a, 15b); describe the review process in Schedule O if it says "yes" to either line.
Step 9: Prepare and Review Compensation Disclosure—Part VII
List all current officers, directors, and trustees (regardless of compensation) with reportable compensation greater than $0. List up to 20 current key employees (persons with specific responsibilities and reportable compensation greater than $150,000 from the filing organization and related organizations combined) and five highest compensated employees (reportable compensation at least $100,000 from the filing organization and associated organizations, who are not officers, directors, trustees, or key employees).
Report compensation in columns for base salary, cash bonuses/grants, noncash compensation, health benefits, and estimated other compensation. Include former officers, directors, trustees, key employees, and the highest compensated employees if they served in any such capacity during one of the five prior reporting years. Report the five highest compensated independent contractors receiving more than $100,000 compensation in Part VII, Section B.
Step 10: Sign, Date, and Assemble Return with Schedules
Ensure authorized officer or principal officer signs and dates Form 990 Part II (Signature Block) under penalties of perjury; enter title and date of signature. If a paid preparer prepares the return, the preparer must sign, date, provide an address, and indicate whether the IRS may contact the preparer. Assemble a complete return by attaching all required Schedules A–N and Schedule R identified in Part IV Checklist as completed.
Arrange Schedule O as the final supplemental schedule. For paper filing, consult the current IRS Form 990 instructions publication for the mailing address specific to your location. The Form 990 for calendar year 2013 filers is due on May 15, 2014, or November 15, 2014, if an extension is granted. Do not enter Social Security numbers on any page of Form 990, as the entire return is subject to public disclosure.
Form 990 Schedule Changes Implemented in 2013
Schedule A (Clarified)
Prior-year supporting organizations are subject to the general rules. 2013 instruction: Type III functionally integrated and non-functionally integrated supporting organizations must demonstrate responsiveness to supported organizations under final regulations effective December 28, 2012. The instructions now specify the notification requirement, responsiveness, and integral part tests.
Schedule D (Updated)
The report includes a general description of prior-year program-related investments. 2013 Instructions: Each program-related investment must be described on a separate line. The investment must be classified as either a loan or equity. Domestic organizations must be identified in which investments are made. Organizations must report credit counseling, debt management, credit repair, or debt negotiation services in Schedule D, Part IV, if applicable.
Schedule H (Updated)
Definitions for prior-year financial assistance and community benefits are provided. 2013 instruction: "Direct offsetting revenue" was expanded to include restricted grants for community benefit if the restriction was stated in writing; it clarified that financial assistance does not include self-pay or prompt-pay discounts.
Schedule L (Clarified)
Prior-year interested person transactions are generally reported. 2013 instruction: If the organization reported receivables from or payables to interested persons on Part X lines 5, 6, or 22, the organization must file Schedule L Part II.
Schedule N (Updated)
Prior year liquidation/termination/dissolution documentation not specified. 2013 instruction: Organizations must attach a certified copy of the articles of dissolution or merger, if available; otherwise, a copy of the governing body resolution approving plans to liquidate, terminate, dissolve, or merge.
Schedule R (Clarified)
Prior year-related organizations are listed without specific guidance. 2013 instruction: Updated to clarify when to include disregarded entities, partnerships, and corporations, and when a single-member LLC is treated as a disregarded entity.
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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.
