2009 Form 990

On February 4th, 2010 the IRS released the final version of the 2009 990. What is new and different?

The changes for 2009 are few in number and many are technical. There are more detailed trigger questions and clearer language on the form and the instructions include more detail and clearer language as well.

The instructions state that an organization must report new, significant program services or significant changes in how it conducts program services on its Form 990 rather than in a letter to IRS. The same applies with changes to its organizational documents.

A big change is the ability on the return for organizations with consolidated financial statements to indicate that they were audited on a consolidated basis. In the 2008 Form 990, more complex nonprofits with consolidated financial statements had to answer that they did not receive audited statements, only the parent organization could answer yes to the question.

Another change is a new question asking if the organization has prepared Schedule O and provided explanations there for various answers in other parts of the 990. This will hopefully guide the reader to look for explanations in the Schedule O for clarification of any answers they might be confused or concerned by.

Other highlights:

  • Schedule G requires reporting additional details for expenses related to fundraising events.
  • Schedule J (compensation) includes a new question asking whether the organization followed the procedures to establish the rebuttable presumption of reasonableness in setting compensation in an initial contract.
  • The form includes a new “leased employees” section that explains when and how compensation of leased employees must be reported.
  • Sections and items in schedules for hospitals (Schedule H) and bonds (Schedule K) that were optional for the 2008 form will be mandatory for 2009.

For a complete breakdown of the changes please click here.

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