Form 990-T Filing Checklist for Tax Year 2024
Overview and Applicability
The 2024 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.
Organizations that are tax-exempt under certain sections must file if they have unrelated business taxable income. 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% with indefinite carryforward.
Ten-Step Filing Process
Step 1: Confirm Filing Requirement and Organization Type
Verify that the organization qualifies to file for the calendar year 2024 or the applicable fiscal year. Mark the exempt status and organization type in item G as a 501(c) corporation, 501(c) trust, 401(a) trust, or other trust. Enter the book value of all assets in item C. Enter the total number of unrelated businesses in item H. Section 501(c)(3) organizations must not enter Social Security numbers.
Step 2: Identify All Unrelated Business Activities
Identify all separate, unrelated trades or businesses. Each requires its own Schedule A unless properly aggregated. Gather documentation including gross receipts, Forms W-2, 1099-NEC, 1099-MISC, 1099-K, partnership Schedule K-1s, cost of goods sold records showing beginning inventory, purchases, labor, section 263A costs, and ending inventory, operating expenses, Form 4562 for depreciation, interest schedules, tax records, rental income, and debt-financed property records. Segregate related and unrelated activities.
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, exploited exempt activity income, advertising income, and other income. Total all income.
Part II captures deductions 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. Apply net operating loss deductions: 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. Apply charitable contribution limitations of 10% of income before contributions when derived from unrelated business. Calculate unrelated business taxable income, ensuring it is zero or positive, as losses from one business cannot offset those from another.
Step 4: Aggregate Schedule A Results
Complete all Schedule A forms and verify accuracy. Confirm specific deduction allocation if 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 Part I entry.
Step 5: Complete Part I of the Main Form
Transfer aggregate unrelated business taxable income from all Schedule A forms to Part I using the appropriate lines per the actual form. Verify charitable contribution deductions comply with the 10% limitation when applicable. Calculate total unrelated business taxable income subject to tax.
Step 6: Calculate Tax Liability in Part II
Corporations multiply total unrelated business taxable income by 21% for regular taxes. Trusts use the 2024 trust rate schedule or Schedule D from Form 1041. Organizations subject to the proxy tax under section 6033(e) calculate it separately with schedules attached. Trusts determine alternative minimum tax if applicable. Include other taxes from Form 4255, recapture amounts, and noncompliant facility income with forms attached. Sum all tax components to calculate the 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 the corporate minimum tax credit or Form 8827 for the trust minimum tax credit.
Organizations eligible for the Inflation Reduction Act’s elective payment provisions may claim certain clean energy credits as payments. Do not claim prohibited 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, other taxes, and the section 965 tax to determine total tax liability.
Step 9: Report Payments and Calculate Balance
Enter the preceding year’s overpayment credited to 2024. Report all 2024 estimated payments, including quarterly installments using Form 990-W. Enter Form 8868 extension deposits. Report foreign withholding and backup withholding with Forms 1099 attached. Include Form 8941, small employer health insurance credit, with the form attached. Include Form 3800 elective payments. Include Form 2439 undistributed capital gains credit with Copy B attached and Form 4136 fuel tax credit. Total all payments.
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 tax exceeds payments or the overpayment if payments exceed tax. Elect to credit overpayment to 2025 or request a refund.
Step 10: Complete Part IV, Part V, Sign, and File
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 requiring possible FinCEN Form 114 with country names, foreign trust distributions requiring Form 3520 or Form 3520-A, and total tax-exempt interest received.
Assemble the return including the main Form 990-T, all Schedule A forms, supporting schedules such as Forms 4562, Schedule D, Form 4797, cost of goods sold worksheets, compensation schedules, credit forms 1118 or 1116, Form 3800, Form 8801 or Form 8827, Form 8941, Form 2220 if applicable, recapture forms, section 965 forms, elective payment documentation, and other attachments.
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
Calendar-year organizations file by May 15, 2025. An automatic six-month extension may be requested using Form 8868, extending the deadline to November 15, 2025, but not the payment deadline.
Section 401(a) trusts and IRAs are filed 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 payments and do not mail payments with paper returns.
This checklist helps you correctly fill out the 2024 Form 990-T, following the latest form layout and tax rules for organizations that have 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.
