Form 990 Tax Year 2017 Filing Checklist
Year-Specific Context
Form 990 for 2017 requires all filers to complete Schedule O, which provides supplemental information. Noncash contribution reporting on Schedule M triggers at the $25,000 aggregate threshold. Functional expense allocation across program, management, and fundraising columns is mandatory for all Section 501 (c) (3) and 501 (c) (4) organizations. The Tax Cuts and Jobs Act was enacted on December 22, 2017, affecting tax reporting for unrelated business income for tax years beginning after December 31, 2017.
No Economic Impact Payment reconciliation applies to 2017. Organizations with gross unrelated business income of $1,000 or more must file Form 990-T in addition to Form 990. Public charity support tests cover the five prior years (2012–2016 for 2017 filers) and determine Schedule A completion under sections 509(a)(1) and 509(a)(2).
Filing Requirements
Organizations must file Form 990 if gross receipts are at least $200,000 or total assets are at least $500,000 at year-end 2017. Organizations with gross receipts less than $200,000 and total assets less than $500,000 may file Form 990-EZ or voluntarily file Form 990. Organizations with gross receipts of normally $50,000 or less may submit Form 990-N, unless they are voluntarily filing Form 990 or Form 990-EZ. Section 509(a)(3): Supporting organizations must file Form 990 or Form 990-EZ regardless of gross receipts, and they cannot file Form 990-N.
Ten-Step Filing Checklist
Step 1: Determine Filing Requirement and Form Selection
File Form 990 if the organization has gross receipts of $200,000 or more or total assets of $500,000 or more at year-end 2017. Do not file Form 990-N if either threshold applies. Organizations below both thresholds may file Form 990-N unless they are section 509(a)(3) supporting organizations, sponsoring organizations of donor-advised funds, or controlling organizations under section 512(b)(13). Calendar year 2017 returns are due May 15, 2018.
Step 2: Gather Financial Records and Revenue Documentation
Collect all revenue sources, including contributions, grants, program service revenue with corresponding business codes, investment income statements, gaming and fundraising event records, and noncash contributions with valuation methods. Maintain records supporting all amounts reported in Part VIII columns for revenue, unrelated business income, and amounts excluded from tax under section 512. Gather documentation for contributions in accordance with IRS charitable gift recordkeeping requirements, including bank records and written communications from donors showing the organization’s name, date, and contribution amount.
Step 3: Identify Officers, Directors, Trustees, Key Employees, and Highest Compensated Individuals
List all current officers, directors, and trustees regardless of compensation amount. List all key employees with reportable compensation greater than $150,000 from the organization and related organizations. List the five current highest compensated employees (apart from officers, directors, trustees, and key employees) with reportable compensation of $100,000 or more from the organization and related organizations.
List former officers, key employees, and the highest compensated employees if compensation exceeded $100,000 in their capacity as former. Report calendar year compensation and average hours per week for both the filing organization and related organizations.
Step 4: Complete Schedule A Public Charity Support Test
If the organization is described in section 501(c)(3), determine public charity status by checking the appropriate box on Schedule A Part I for organizational classification. Organizations qualifying under section 509(a)(1) or 509(a)(2) must complete Part II or Part III of Schedule A for the five-year public support test using 2012–2016 data. Report gifts, grants, contributions, membership fees, and gross receipts from exempt activities. Calculate support percentages. Organizations failing to meet the required threshold may need to file Form 990-PF instead of Form 990.
Step 5: Calculate and Report Revenue in Part VIII
Enter all revenue sources in Part VIII columns for total revenue, unrelated business income, and amounts excluded from tax. Complete business codes for program service revenue and other revenue regardless of whether the activity constitutes trade or business or relates to tax-exempt purposes. Report fundraising event contributions and fundraising event gross income separately. If the combined fundraising event totals exceed $15,000, Schedule G, Part II, is required. Ensure total revenue in Part VIII, column A, flows to Part I, line 12.
Step 6: Report All Expenses in Part IX Statement of Functional Expenses
Classify all expenses across total, program services, management and general, and fundraising columns. Report salaries, other compensation, and employee benefits separately. Report grants and allocations, benefits paid to members, and professional fundraising fees on designated lines. Calculate total expenses. If professional fundraising fees exceed $15,000, Schedule G, Part I, is required. If any other costs (line 25, column A) exceed 10 percent of total functional expenses, itemize the type and amount in Schedule O.
Step 7: Determine Required Schedules Using Part IV Checklist
Answer all Part IV yes/no questions to trigger schedule requirements. Schedule A is required for section 501(c)(3) organizations. Schedule B is required if contributions from any single contributor exceed $5,000. Schedule D is necessary if the value of land, buildings, and equipment exceeds 5 percent of total assets or if other specific asset or investment thresholds apply. Schedule F is required for significant foreign activities.
Schedule G is required if gaming or fundraising gross income exceeds $15,000 or if professional fundraising fees exceed $15,000. Schedule I is necessary if grants to domestic organizations or individuals exceed $5,000. Schedule K is required if the tax-exempt bond principal outstanding exceeds $100,000. Schedule M is required if noncash contributions total more than $25,000.
Step 8: Report Related Organizations and Transactions
Complete Schedule R, Part I, if the organization has disregarded entities. Complete Schedule R Parts II through IV if the organization has related tax-exempt or taxable entities. Report all transactions with related organizations in Schedule R Part V. Complete Schedule L if business transactions occurred with current or former officers, directors, trustees, or key employees exceeding applicable thresholds.
Complete Schedule L Part I if the organization engaged in excess benefit transactions with disqualified persons. Complete Schedule C if the organization is involved in political campaign activities or lobbying activities.
Step 9: Complete Part VI Governance Section and Schedule O
Report the number of voting members of the governing body and the number of independent voting members using IRS definitions. Answer all questions regarding family relationships, delegation of authority, significant changes to governing documents, asset diversion, governance structure, conflicts of interest, whistleblower policies, document retention policies, and the public's availability of documents.
Complete Schedule O supplemental information for all Part VI responses requiring narrative explanation, Part III program service descriptions, Part IV schedule determinations, and all other explanations needed. All Form 990 filers are required to complete and file Schedule O.
Step 10: Complete Parts X, XI, and XII; Sign and Prepare for Filing
Report beginning and ending balances for all assets and liabilities in Part X. Ensure total assets equal total liabilities plus net assets for both beginning and ending columns. Complete Part XI to reconcile net assets from beginning to ending balance.
Complete Part XII to report on financial statements and reporting, indicating whether the organization obtained separate, independent audited financial statements or was included in consolidated statements. Verify preparer information, including name, address, phone, firm name, and EIN. Enter the organization’s name exactly as it appears on the EIN letter. Check the appropriate boxes for an amended return, initial return, or final return, as applicable.
Sign and date the return under penalty of perjury. File the original return by May 15, 2018, for calendar year 2017 filers. Mail to Department of the Treasury, Internal Revenue Service Center, Ogden, UT 84201-0027.
Key 2017 Requirements
Schedule O is mandatory for all Form 990 filers. Organizations must complete Schedule O to provide required narrative responses to specific questions, such as Part VI, lines 11b and 19, and to provide supplemental information for other questions throughout the form and schedules.
Functional expense allocation is mandatory for Section 501 (c) (3) and 501 (c) (4) organizations. All expenses must be allocated across program services, management and general, and fundraising categories in Part IX.
Organizations with unrelated business income of $1,000 or more must file Form 990-T separately. The threshold for Form 990-T filing is gross unrelated business income, not net income.
Form Limitations
Private foundations file Form 990-PF, not Form 990. Organizations with gross receipts of normally $50,000 or less may file Form 990-N unless they are section 509(a)(3) supporting organizations, sponsoring organizations of donor-advised funds, or controlling organizations under section 512(b)(13) with fund transfers during the year.
Section 527: Political organizations must file Form 990 or Form 990-EZ if their gross receipts are $25,000 or more, even if they are usually $50,000 or less. Qualified state or local political organizations file only if gross receipts are $100,000 or more.
Organizations filing at least 250 returns of any type during the calendar year and having total assets of $10 million or more at year-end must file Form 990 electronically. Organizations not required to file electronically may voluntarily do so.
Section 509(a)(3) supporting organizations must file Form 990 or Form 990-EZ, regardless of gross receipts. It cannot file Form 990-N, except for integrated auxiliaries of churches, exclusively religious activities of religious orders, or organizations supporting section 501 (c) (3) religious organizations with gross receipts typically not exceeding $5,000.
Organizations failing to file required annual returns for three consecutive years automatically lose tax-exempt status on the third annual return's due date. This automatic revocation applies to most tax-exempt organizations, except churches and specific other organizations.
Penalties and Compliance
Organizations that file late or incomplete returns face penalties of $20 per day, not to exceed the lesser of $10,000 or 5 percent of their gross receipts for the year, unless they can demonstrate reasonable cause. Organizations with annual gross receipts exceeding $1,028,500 are subject to penalties of $100 per day, with a maximum penalty of $51,000 for any one return.
Responsible individuals who fail to file complete returns or furnish correct information after IRS notification face penalties of $10 per day. The maximum penalty for all individuals who fail to file any one return is $5,000.
Filing an incomplete return includes failing to complete required line items, required parts of schedules, or required schedules. Organizations must complete all applicable line items, answer each question unless instructed to skip, make entries on all lines requiring amounts or information, and provide required explanations.
Recordkeeping Requirements
Organizations should maintain records supporting all amounts and information reported on Form 990 for at least three years from the later of the filing date or the due date. Records supporting depreciation deductions or other items requiring more extended retention periods should be kept for a minimum of three years.
Organizations must make the completed Form 990 available for public inspection for three years from the filing date or three years from the due date, whichever is later. Schedule B contributor information is generally protected from public disclosure except for section 527 political organizations.
Organizations should retain copies of all filed returns to facilitate the preparation of future returns and facilitate computations when filing amended returns. Organizations with audited financial statements must provide reconciliations between the financial statements and Form 990, specifically on Schedule D, Parts XI and XII.
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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.
