Form 990 (2011 Tax Year) Filing Checklist
Unique Attributes of 2011 Form 990
The redesigned Form 990 introduced a restructured core form with a summary page (Part I), consolidating financial snapshots. It moved the Statement of Program Service Accomplishments to Part III and added Schedule O (Supplemental Information) as mandatory for all filers. This version emphasizes governance transparency and reporting of excess benefit transactions under Section 4958, which applies to Section 501 (c) (3) organizations claiming such status as of 2011.
Year-Specific Programs Applying to 2011
For tax year 2011, organizations must disclose activities involving foreign operations and grants exceeding thresholds; report unrelated business taxable income if $1,000 or more (Form 990-T required); and complete Schedule F based on multiple foreign activity thresholds. Section 4958 excess benefit transaction reporting became more prominently featured on the 2011 core form and Schedule J.
Ten-Step Completion Checklist
Step 1: Verify Filing Requirement
Confirm organization has gross receipts ≥ $200,000 or total assets ≥ $500,000 as of the end of the tax year 2011. If both thresholds are below and the organization qualifies, file Form 990-EZ or Form 990-N instead. Record the 2011 tax year beginning and ending dates in Part A, Heading.
Step 2: Gather Financial Documents
Collect the 2011 balance sheet (assets, liabilities, and net assets/fund balances); statement of activities or revenue/expense ledgers; Form 990-T documentation if unrelated business gross income ≥ $1,000; and employee W-2s for all officers, directors, trustees, key employees, and highest compensated employees receiving compensation.
Step 3: Complete Part I (Summary)
Enter organization’s name, EIN, and address; check applicable boxes (address change, name change, initial return, amended return, terminated); select legal form (corporation, trust, association, other); enter website; report gross receipts (line G), total assets at the beginning and end of the year, and summarize the mission.
Step 4: Complete Parts VIII, IX, X (Financial Statements)
Part VIII: Itemize contribution/gift revenue (line 1), program service revenue (line 2g), investment income (lines 3-4), other revenue (lines 5-6d, 8c-11e), and total revenue (line 12).
Part IX: Report functional expenses by category; if compensation of officers/directors/key employees or grants exceed thresholds (e.g., grants ≥ $5,000 to a single recipient), complete applicable schedules.
Part X: Balance sheet with assets (lines 1-15), liabilities (lines 17-25), and reconciled to net assets.
Step 5: Complete Part VII, Section A (Officers, Directors, Trustees, Key Employees)
List all current officers, directors, and trustees, regardless of compensation; key employees with compensation ≥ $150,000 from the organization and related organizations and significant responsibilities (top 20 only); and the five highest compensated employees receiving ≥ $100,000 (not already listed as officer/director/trustee/key employee). Display the average number of hours worked per week and the relationships to the organization. Note: positions in column C are mutually exclusive—check only one box per individual.
Step 6: Determine and Complete Required Schedules (Part IV Checklist)
Answer all 38 Part IV questions to trigger required schedules: Schedule A if 501(c)(3); Schedule B if donors ≥ $5,000 (except private foundations and 527 organizations already reporting elsewhere); Schedule F triggers on multiple thresholds: (1) If aggregate revenues/expenses from foreign activities exceed $10,000 OR aggregate foreign investments exceed $100,000, complete Parts I and IV; (2) If aggregate grants to foreign organizations/governments exceed $5,000, complete Parts II and IV; (3) If aggregate grants to foreign individuals exceed $5,000, complete Parts III and IV; Schedule I if domestic grants ≥ $5,000; Schedule J if the highest-paid individual’s total compensation exceeds $150,000; Schedule K if the tax-exempt bond issue outstanding principal is > $100,000 issued after 12/31/2002; Schedule L if excess benefit transactions, loans to insiders, or business transactions with related individuals are reported. Attach all triggered schedules with complete information as specified in each schedule’s instructions.
Step 7: Disclose Unrelated Business Income
Part V, line 3a: If the organization had unrelated business gross income ≥ $1,000 during 2011, answer “Yes” and attach Form 990-T (Exempt Organization Business Income Tax Return). Report net unrelated business taxable income (Form 990-T, line 34) on Part I, line 7b and Part XI, line 5b. Failure to file Form 990-T when required is a compliance violation.
Step 8: Complete Part VI (Governance, Management, Disclosure)
Certify whether the organization reviewed Form 990 before filing (lines 11a-b); confirm a written conflict of interest policy exists (line 12a), and officers/directors/trustees are required to make annual disclosure (line 12b). Additionally, address Part IV (Checklist of Required Schedules), line 25a (excess benefit transactions), and line 28 (business transactions with interested persons) by completing the applicable triggered schedules (Schedule L); confirm Form 990 is made available to the public (line 19); and describe governance processes and Board meeting documentation in Schedule O as instructed.
Step 9: Complete Part XI (Reconciliation of Net Assets)
Reconcile beginning net assets (line 20, from prior year) with current year revenue (line 12), expenses (line 18), and other changes (line 5, explained in Schedule O). Calculate ending net assets (line 22). Verify Part X, line 16 (total assets) minus line 26 (total liabilities) equals line 22 (net assets).
Step 10: Sign, Date, and Attach Schedule O
Under penalty of perjury, the authorized officer and, if applicable, the paid preparer sign Part II with the date. Include the PTIN for the preparer. Attach Schedule O (mandatory for all 2011 filers), providing narrative explanations for all “Yes” responses in Part III (new or discontinued programs), Part IV (schedule triggers), Part V (IRS filing compliance), Part VI (governance and disclosure questions), and Part XI (reconciliation changes). Include the preparer’s firm name, EIN, address, and phone number. Per IRS instructions, file Form 990 by the 15th day of the 5th month after the organization’s accounting period ends (May 15 for calendar-year filers). See the IRS Where to File page for the 2011 Form 990 mailing address (paper only—no e-file referenced here).
Form-Specific Limitations
Nonexempt charitable trusts (section 4947(a)(1)) completing 2011 Form 990 cannot use simplified Form 990-EZ and must report income distribution information. Private foundations use Form 990-PF, not 990 or 990-EZ. Section 527 political organizations use specialized question sets in Part IV and must file Schedule B for donors over $200 (not $5,000). Black lung benefit trusts and certain exempt pension/profit-sharing trusts (section 401) are excepted from 990 filing; use Form 5500 instead.
Key Structural Changes in 2011 Form 990
Page 1: Prior years had a signature block at the end of the form; the 2011 redesign moved the signature block (Part II) to page 1.
Part III: Prior years separated Analysis of Income-Producing Activities and Relationship of Activities to Exempt Purpose; 2011 consolidated these into the Statement of Program Service Accomplishments with new/discontinued/altered program services.
Schedule O: Previously, the optional narrative became mandatory for all 2011 filers, with explanations required for specific Part III, V, VI, XI questions.
Part VII, Column F: Added “Compensation reported in a prior Form 990” for deferred compensation clarification to avoid double-counting.
Form-Specific Compliance Notes
No section 501(c)(3) organization filing 2011 Form 990 may omit Schedule O or fail to answer all Part IV checklist questions; incomplete responses prevent accurate schedule trigger determination. Organizations with unrelated business income must file Form 990-T concurrently; absence of Form 990-T when required is a filing failure. Schedule B (Contributors) must list all donors giving ≥ $5,000 on the schedule filed with the IRS; however, for most 501(c)(3) organizations, donor names and identifying information are NOT REQUIRED to be publicly disclosed. The IRS excludes donor-identifying information from public disclosure for all organizations, except private foundations and Section 527 political organizations, which are required to reveal contributors who give $200 or more. Officers, directors, and trustees must be listed in Part VII regardless of compensation; omission is a material error.
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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.
