Schedule O: Supplemental Information to Form 990 or 990-EZ
This is the third year of the “new” and expanded IRS Form 990. An article in the July 2011 Journal of Accountancy states, per the IRS, that not filing Schedule O is a major problem with Form 990 preparation.
Schedule O is not optional!
While Schedule O is a blank form to provide supplemental information to the IRS, it is not optional. The instructions for Schedule O clearly state two lines of Part VI of Form 990 require an explanation on it. Here they are:
- 11b: Describe in Schedule O the process, if any, used by the organization to review this Form 990.
- 19: Describe in Schedule O whether (and if so, how), the organization makes its governing documents, conflict of interest policy, and financial statements available to the public.
Form 990’s objective is to provide information to the public. Despite new streamlining, explanation of some issues deserve verbiage on Schedule O. An implication of Schedule O, beyond public disclosure, is that the IRS still must hand process parts of Form 990.
“CPAs routinely include supplemental information for tax forms. This proactive technique (hopefully) keeps “out of range”, but legitimate, tax figures from being audited. ”
Gary Bode, Wilmington NC CPA and tax accountant
Another Function of Schedule O
Nonprofits evolve over time, often changing functions significantly from what was originally filed with the IRS during setup. In the past, this required “re-determination”. But now questions on Form 990, and subsequent explanation on Schedule O, replace re-determination.
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