Form 990-T Filing Checklist for Tax Year 2022
Overview and Applicability
The 2022 Form 990-T requires separate Schedule A forms for each unrelated trade or business. The Tax Cuts and Jobs Act applies a 21% flat corporate rate to organizations taxable as corporations. Trusts use graduated rates and may claim the section 199A deduction via Form 8995 or Form 8995-A.
Tax-exempt organizations under sections 501(c), 401(a), 408(e), 408A, 220(e), 529(a), 529A, or 530(a) with unrelated business taxable income must file. Organizations must track pre-2018 net operating losses, subject to two-year carryback and twenty-year carryforward rules, separately from post-2017 net operating losses, which are limited to 80% of taxable income with indefinite carryforward.
Ten-Step Filing Process
Step 1: Confirm Filing Requirement and Organization Type
Verify the organization qualifies to file for the calendar year 2022 or the applicable fiscal year. Mark the organization type in item G, selecting 501(c) corporation, 501(c) trust, 401(a) trust, or other trust. Confirm unrelated business taxable income meets the filing threshold. Section 501(c)(3) organizations must not include Social Security numbers, as Form 990-T may be publicly disclosed.
Step 2: Identify All Unrelated Business Activities
Identify all separate, unrelated trades or businesses conducted during 2022. Enter the total number in item H. Each activity requires its own Schedule A, unless it is properly aggregated.
Gather documentation including gross receipts, returns and allowances, cost of goods sold records showing beginning inventory, purchases, labor, section 263A costs, and ending inventory, operating expenses, depreciation records using Form 4562, interest, taxes, rental income, debt-financed property records, and partnership Schedule K-1s.
Step 3: Complete Schedule A for Each Business
Prepare a separate Schedule A for each business. Part I reports income, including gross receipts less returns, cost of goods sold, gross profit, capital gains with Schedule D attached, Form 4797 gains, partnership income, rental income, debt-financed income, controlled organization income, investment income for section 501(c)(7), (9), or (17) organizations, and other income. Total all income.
Part II captures deductions directly connected to income, including officer compensation with a schedule, salaries and wages, repairs, bad debts, interest with schedules, taxes and licenses, depreciation from Form 4562 less amounts claimed elsewhere, depletion, deferred compensation contributions, employee benefits, and other deductions. Total all deductions.
Calculate income before specific deductions by subtracting deductions from income. Apply net operating loss deductions, maintaining separate tracking: pre-2018 NOLs offset income fully subject to carryback and carryforward limits, while post-2017 NOLs are limited to 80% with indefinite carryforward. Apply a specific deduction of generally $1,000, allocating it among the controlled group if applicable. Calculate unrelated business taxable income, ensuring it is zero or positive, as losses cannot offset other businesses.
Step 4: Aggregate Schedule A Results
Complete all Schedule A forms and verify accuracy. Confirm specific deduction allocation if the organization is part of a controlled group. Ensure each Schedule A shows zero or positive unrelated business taxable income. Sum unrelated business taxable income from all Schedule A forms for the main form entry.
Step 5: Complete Part I and Calculate Charitable Contributions
Transfer the aggregated unrelated business taxable income from all Schedule A forms to Part I. Calculate the charitable contribution deduction limited to 10% of unrelated business taxable income before contributions. Gather documentation verifying recipient qualifications under section 170. Enter the lesser of actual contributions or limitations. Reduce aggregate unrelated business taxable income by allowable contributions to determine total unrelated business taxable income subject to tax.
Step 6: Calculate Tax Liability in Part II
Corporations multiply the total unrelated business taxable income by 21% for regular taxes. Trusts use the 2022 trust rate schedule or Schedule D from Form 1041. Organizations subject to the proxy tax under Section 6033(e) calculate separately, with schedules attached. Trusts determine alternative minimum tax if applicable. Include other taxes with forms attached. Sum regular tax, proxy tax, alternative minimum tax, and other taxes for total tax before credits.
Step 7: Claim Credits in Part III
Attach Form 1118 for the corporate foreign tax credit or Form 1116 for the trust foreign tax credit. Attach Form 3800 for general business credits. Attach Form 8801 for corporate minimum tax credit or Form 8827 for trust minimum tax credit. Attach Form 8941 for the health insurance credit for small employers.
Do not claim prohibited credits, including earned income, child tax, or education credits. Sum the credits and subtract them from the tax to calculate the net tax.
Step 8: Report Other Taxes
Complete recapture forms if applicable, including Form 4255 for investment credit, Form 8611 for low-income housing credit, Form 8697 for long-term contract interest, and Form 8866 for property depreciation interest. Report section 965 tax from Form 965-A or Form 965-B if applicable. Add net tax after credits and other taxes to determine total tax liability.
Step 9: Report Payments and Calculate Balance
Enter the 2021 overpayment credited to 2022. Report all 2022 estimated payments, including quarterly installments. Enter Form 8868 extension deposits. Report foreign withholding and backup withholding with Forms 1099 attached. Include the Form 2439 credit with Copy B attached and the Form 4136 fuel tax credit. Total all payments and compare against total tax.
Step 10: Calculate Penalty, Complete Disclosures, and Sign
Complete Form 2220 if an underpayment exists for organizations with a tax liability of $500 or more. Enter the penalty and attach the form. Calculate the balance due if the tax exceeds payments, or the overpayment if payments exceed the tax. Choose to credit the overpayment to 2023 or request a refund.
Complete Part IV by answering questions on at-risk limitations under section 465, excess business loss limitations under section 461(l), passive activity basis limitations under section 469, and aggregate unrelated business taxable income disclosure.
Complete Part V by reporting foreign financial accounts that may require FinCEN Form 114, foreign trust distributions requiring Form 3520 or Form 3520-A, and total tax-exempt interest received.
The authorized officer signs with their date and title. Item J requires a contact name and phone number. Indicate whether the IRS may discuss the return with the preparer. Paid preparers complete their section with signature, date, PTIN, firm information, and phone number.
Filing Requirements
Assemble the return with the main Form 990-T, all Schedule A forms, and supporting schedules including Forms 4562, Schedule D, Form 4797, cost of goods sold worksheets, and compensation schedules. Attach credit forms such as Forms 1118 or 1116, Form 3800, Form 8801 or Form 8827, and Form 8941, as well as Form 2220 if applicable and other required documentation.
Calendar-year organizations file by May 15, 2023. An automatic six-month extension may be requested using Form 8868, extending the filing deadline to November 15, 2023, but not the payment deadline. Section 401(a) trusts and IRAs file by the 15th day of the fourth month after the end of the year.
Consult the IRS “Where to File” page for the correct mailing address. Electronic filing is encouraged through approved software. Use the Electronic Federal Tax Payment System for all payments and do not mail payments with paper returns.
This checklist helps ensure correct completion of the 2022 Form 990-T and compliance with tax rules for organizations that generate unrelated business income.
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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.
