IRS Form 990 Revised by osp18113

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									         The IRS released on October 7 its draft Form 990 for public review and comment (a
draft, revised Form 990-EZ was also made public – revised Schedules A and B, with no
particularly notable changes, were released on August 5). No revised instructions accompanied
the draft Form 990 (instructions are not presented for public comment). Comments on the draft
Form 990 must be submitted to the IRS by November 7.

          The following is a list of highlights of changes from the prior Form 990.

          •      Filing organizations must indicate (Part II, line 22, on page 2) whether any of the
                 “grants or allocations” identified in their itemized expenses include foreign
                 grants.

          •      Line 75 (now in Part V-A on page 6), has been changed so that instead of only
                 asking whether any officer, director, trustee or key employee received aggregate
                 compensation of more than $100,000 from the filing organization and all related
                 organizations (of which more than $10,000 was provided by the related
                 organizations), it now asks for the following information:

                 -       the total number of officers, directors and trustees permitted to vote on the
                         organization’s business at board meetings;

                 -       whether (1) any officers, directors, trustees or key employees listed in Part
                         V-A, (2) any of the five highest paid employees listed in Part I of
                         Schedule A, and/or (3) any of the five highest paid professional services
                         independent contractors or other independent contractors listed in Parts II-
                         A or II-B of Schedule A, are "related to each other through family or
                         business relationships" (and, if so, an attached statement identifying the
                         individuals and explaining the relationship(s) is required);

                 -       whether any of the officers, directors, trustees or key employees (or any of
                         five highest paid employees, or professional services independent
                         contractors or other independent contractors described in the previous
                         bullet point) received compensation from any other organization, tax-
                         exempt or taxable, related to the filing organization through "common
                         supervision or common control" (and, if so, an attached statement
                         identifying the individuals, explaining the relationship(s) between the
                         organizations, and describing the compensation arrangements, including
                         amounts paid to each individual by each related organization is required);

                 -       whether the filing organization has a written conflict of interest policy.

          •      A new Part V-B provides a schedule for reporting loans and advances,
                 compensation, employee benefits and deferred compensation contributions and
                 expense allowances to former officers, directors, trustees or key employees. This
                 prevents any avoidance of reporting of any deferred compensation, severance pay,
                 consulting pay and any other benefits provided to former officers, directors and
                 key employees.



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          •    A new line 91b asks whether during the reporting year the organization had an
               interest in, or authority over, a financial account in a foreign country (and if so,
               where; and a new line 91b asks whether the organization maintained an office
               outside of the U.S. (and if so, where).




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