Clarifications on 2011 Form 990

February 13, 2012

The 2011 Form 990 is not significantly changed from the prior year, but the instructions do have some possibly significant clarifications contained in them, if the particular area is applicable to your situation.  Here is a bullet list of the significant clarifications:

  • Any organization must file Form 990, 990EZ or 990-N, even if an exemption application has not been filed or approved yet.  (The exemption for churches and certain religious organizations still exists.)
  • If you had foreign investments valued at $100,000 or more, you must complete Schedule F, Part I and IV.
  • Clarification on when to complete the parts of Schedule F providing grants or assistance made to organizations or individuals outside the United States.
  • Clarification with examples for when a board member is considered independent.
  • If the governing body allowed an executive committee to act on its behalf, it must provide an explanation in Schedule O.
  • The governance section now asks if any governance decisions of the organization reserved to (or subject to approval by) members, stockholder, or persons other than the governing body.
  • Instructions added that an organization cannot say “yes” to the governance area question (line 11a) about providing the 990 to the voting governing body before filing with the IRS if it merely notifies them that the 990 is available upon request for review.  It is satisfactory, though, to provide a link to a password-protected web site on which the entire Form 990 can be viewed.

The 2011 form can be found at:

The 2011 990 instructions can be found at: