All In One Nonprofit · User Guide

Form 990
User Guide

Determine which 990 form you file, identify every schedule that applies, document board governance and review process, calculate the public support test, structure compensation disclosures, and allocate functional expenses, with reasonableness checks at every step.

8 Generators Schedule A–R Map DOCX Export Part of Operations & Compliance Suite
Team chat. When you are signed in and part of a team, a Team chat button sits in the bottom-right corner of this app. It opens a real-time chat with your whole organization (live presence, typing indicators, and full message history), so you can message your team without leaving your work. Committee-specific chats live on your Team page.
Automations. This tool includes an AI program accomplishments drafter for Part III. For how it works, its guardrails, and how to use it well, see the AI Automations Guide.

1. About This Tool

Form 990 is the public-facing annual report card for every nonprofit that files it. The IRS uses it. State charity regulators use it. GuideStar/Candid posts it. ProPublica indexes it. Donors search it. Funders require it. Watchdog groups score it. Journalists comb it for stories. Whatever your nonprofit puts on its 990 is the single most-read document the organization will ever publish.

Despite that, 990 preparation in most nonprofits is a yearly scramble. The CPA asks for data the organization hasn't been tracking. Schedules get missed. The governance section gets answered inconsistently year to year. The board "reviews" the 990 in the last 48 hours before filing. Functional expense allocations are made by intuition rather than method. And the questions the IRS scrutinizes, public support test, compensation reasonableness, related-party transactions, get answered without the underlying analysis to back them up.

The Nonprofit Annual Return (IRS Form 990) doesn't replace your CPA. It does the upstream work the CPA assumes you've already done: figuring out which form you file, identifying every applicable schedule, documenting your governance practices, running the math on the public support test, structuring compensation disclosures with proper rebuttable-presumption protection, and allocating functional expenses with a defensible methodology.

Use this tool BEFORE your CPA starts the 990

The outputs from these generators are designed to be handed to your tax preparer as the source material for the 990. Run the tools 30-60 days before the preparer engagement begins. You'll catch missing data, identify schedule triggers, and document board governance, all of which reduces CPA hours and back-and-forth.

2. Getting Started

Who this is for

  • Executive Directors who own the 990 process and want to provide their CPA with complete, organized source material
  • Treasurers and Finance Committee members overseeing 990 quality and board governance disclosures
  • Internal accounting/finance staff who prepare the underlying data for an external preparer
  • Board members reviewing the draft 990 before filing
  • CPA firms wanting a structured client-prep package (the outputs serve as workpapers)

What you'll need to complete the org profile (5-10 minutes)

  • Organization legal name, EIN, state, fiscal year end, year founded
  • Mission statement (verbatim from governing documents preferred)
  • Tax-exempt status type (501(c)(3) public charity, 501(c)(3) private foundation, 501(c)(4), 501(c)(6), other)
  • Public charity sub-classification for 501(c)(3) public charities (170(b)(1)(A)(vi), 509(a)(2), 509(a)(1) church/school/hospital, supporting organization, other)
  • Most recent fiscal year totals: gross receipts, total assets (EOY), total expenses, net assets (EOY)
  • Activity flags: large contributors, lobbying, grants over $5K, non-cash gifts over $25K, fundraising events over $15K, foreign activities, UBI over $1K
  • Operations: employee count, contractors paid over $100K, high-comp staff over $150K, related organizations, school/hospital status, termination/dissolution status

What you'll need for the full generator suite

Different generators need different inputs. The most data-heavy generators are:

  • Public Support Test Calculator: 5 years of detailed support data (contributions by source, investment income, UBTI, other) plus identification of largest individual donors. Pull from prior 990s or accounting records.
  • Compensation Disclosure Worksheet: for each officer/director/key employee/highest-paid: W-2 box 1 (or 1099 amounts), retirement contributions, other benefits, related-org compensation, hours per week.
  • Functional Expense Allocator: total expenses by Part IX line item, plus your allocation percentages (typically pulled from your accounting system if functional accounting is in place, or built from a time study and other allocation bases).
Not a tax preparer

This tool does not file your Form 990. It produces source materials, calculations, and supporting narrative that your CPA or qualified preparer uses to complete the actual filing. The 990 itself must be filed electronically through IRS-authorized e-file providers.

3. Your First Session

This is the start-to-finish walkthrough for a brand-new user. Follow it once and you will have a completed organization profile plus your first finished document. The whole sequence takes about 20 minutes. Everything you enter is saved in your browser, so you can stop and pick up later.

Part A, Sign in and set up your profile

1
Open the app and sign in

When you open the app the sign-in screen appears. Click the blue Sign in button to use your All In One Nonprofit account (the same login works across every All In One Nonprofit app), or enter an Email and Password and click Sign In. New here? Click the Create Account tab, fill in Your Name, Email, and a Password of at least 8 characters, then click Create Account.

2
Run the onboarding wizard

The first time you sign in, the 5-step onboarding wizard opens automatically. The progress dots across the top show Step 1 of 5 through Step 5 of 5. If you ever land on the Dashboard first, open Organization Settings from the top header to fill in the same fields.

3
Step 1, Organization Basics

Fill in Organization Legal Name (as registered with the IRS, for example "Riverside Youth Arts"), EIN (format XX-XXXXXXX), State of Incorporation, Fiscal Year End (for example December 31), Year Founded, and Mission Statement. Click Next →.

4
Step 2, Tax-Exempt Status

Click the radio card that matches your IRS classification, for example 501(c)(3) Public Charity. For a 501(c)(3) public charity, also pick your sub-classification from the dropdown, for example 170(b)(1)(A)(vi), donative public charity. Click Next →.

5
Step 3, Financial Size

Enter Gross Receipts (most recent fiscal year), Total Assets (end of fiscal year), Total Expenses, and Net Assets / Fund Balance. These four numbers decide which 990 you file (the hints under each field show the thresholds). Click Next →.

6
Step 4, Activities Profile

Answer the seven yes/no/unsure dropdowns (large contributors, lobbying, grants over $5,000, non-cash gifts over $25,000, fundraising events over $15,000, foreign activities, and unrelated business income). Each one quietly flags a schedule. Click Next →.

7
Step 5, Operations Profile, then finish

Enter employee count, contractors paid over $100,000, high-comp answer, related organizations, school/hospital status, and termination status. Click Complete Profile →. You land on the Dashboard.

Check the Dashboard stats

At the top of the Dashboard, the stat tiles show Tools Available, Generated So Far, Likely 990 Form, and Gross Receipts. Use Likely 990 Form as a quick sanity check that your financial-size inputs were right. If a yellow banner says "Complete your organization profile," click Complete profile → to fill any gaps.

Part B, Run your first generator end to end (Filing Form Selector)

Start with the tool the IRS picks first: which 990 you actually file. On the Dashboard, find the Filing Determination row (labeled START HERE).

1
Open the tool

In the Filing Determination section, click the Filing Form Selector card, then click its Start → button. The editor opens with a form on the left and a Live Preview on the right.

2
Confirm the inputs

Set Confirm Fiscal Year of Filing (for example "Current/most recent fiscal year"). The Confirm Tax-Exempt Status line is pulled from your profile. Check Confirm Gross Receipts and Confirm Total Assets (end of year), which prefill from your profile but can be overridden here. Answer the threshold-history dropdown, and add any Notes / special circumstances.

3
Read the Live Preview

As you type, the right-hand Live Preview updates instantly and shows the recommended form (Form 990, 990-EZ, 990-N, or 990-PF), the due date, and the reasoning. Nothing is sent anywhere; it all runs in your browser.

4
Mark it complete

When the recommendation looks right, click the green ✓ Mark Complete button at the top of the Customize panel. The card on the Dashboard turns green and the status changes to ✓ Complete.

5
Export the result

Under the Live Preview, use the action bar: click ↓ Word (.docx) to download a formatted document for your CPA or board, or 💾 Save to Library to store it in your Document Library, or 🖨️ Print / PDF, 📋 Copy, 🌐 HTML, or 📝 Text. The first Word export of a session takes a couple of seconds while the document engine loads.

6
Return and continue

Click ← Back to Dashboard at the top of the editor. Then work down the list: run the Schedule Identifier next, then the Governance & Policies tools, then the Financial Reporting tools. Each generator works the same way: read the tip, fill the form, watch the preview, mark complete, export.

This is a prep and organizing tool, not a filing tool

The Filing Form Selector and the other generators help you prepare and organize your 990 source material and supporting documents. They do not transmit anything to the IRS. The actual Form 990 must be filed electronically through an IRS-authorized e-file provider, normally by your CPA or preparer.

4. Onboarding Wizard

The wizard runs once and saves to your browser. You can re-run or update the profile any time from the dashboard.

Step 1, Organization Basics

Legal name, EIN, state, fiscal year end, year founded, and mission statement. These appear as merge fields throughout the generated documents. Use legal name as registered with the IRS (not a DBA) and EIN exactly as on your determination letter.

Step 2, Tax-Exempt Status

Which IRS classification applies. The 5 options cover 95% of nonprofits: 501(c)(3) public charity, 501(c)(3) private foundation, 501(c)(4) social welfare, 501(c)(6) business league, or other 501(c). For 501(c)(3) public charities, also pick your sub-classification (170(b)(1)(A)(vi) donative, 509(a)(2) service revenue, 509(a)(1) church/school/hospital, 509(a)(3) supporting, or other). This sub-classification drives Schedule A Part II vs Part III logic.

Step 3, Financial Size

Gross receipts and total assets determine which 990 variant you file. Total expenses and net assets are merge fields for analysis. The form determination logic:

  • Private foundation ⇒ Form 990-PF (regardless of size)
  • Gross receipts ≤ $50,000 ⇒ Form 990-N (e-Postcard)
  • Gross receipts < $200,000 AND total assets < $500,000 ⇒ Form 990-EZ
  • Otherwise ⇒ Form 990 (full)

Step 4, Activities Profile

Seven yes/no questions that each trigger one or more schedules. Each question maps directly to a schedule (Schedule B for large contributors, C for lobbying, F for foreign, G for fundraising events, I for grants, M for non-cash) plus the question about UBI which triggers a separate Form 990-T.

Step 5, Operations Profile

Employee count, contractors paid greater than $100K (Part VII Section B), high-comp identification (Schedule J trigger), related organizations (Schedule R), school status (Schedule E), hospital status (Schedule H), and termination status (Schedule N).

All five steps takes 5-10 minutes

Don't worry about being perfectly accurate the first time. The Profile screen lets you update any field, and re-running the wizard is one click. Use the dashboard's "Likely 990 Form" stat to sanity-check your profile inputs.

5. Using the Generators

Eight generators across the Dashboard: Filing Determination (START HERE), Governance & Policies (Part VI), Financial Reporting (Parts VII–IX), and Program Service Accomplishments (Part III). Each follows the same click-path: open the Dashboard section, click the generator card, click Start →, read the blue tip, fill in fields on the left, watch the Live Preview on the right, click ✓ Mark Complete, then export from the action bar.

The standard click-path for every generator

1
Open it from the Dashboard

Find the generator card in its section, then click the Start → button on the card (the button reads Continue → if you started it before, or Review once it is complete).

2
Fill the Customize form

The left panel is titled Customize. Work through every dropdown, number field, and notes box. The blue tip box at the top explains what the tool does and which Part or Schedule it maps to.

3
Watch the Live Preview

The right panel, titled Live Preview, rebuilds the finished document as you type, including any calculated results.

4
Mark Complete, then export

Click ✓ Mark Complete in the Customize header, then choose ↓ Word (.docx), 💾 Save to Library, 🖨️ Print / PDF, 📋 Copy, 🌐 HTML, or 📝 Text from the action bar.

CategoryGeneratorTypical TimeWhen to Run
FilingFiling Form Selector5 minFirst, confirms 990, 990-EZ, 990-N, or 990-PF.
FilingSchedule Identifier10 minRight after Filing Form Selector.
GovernanceGovernance Policies Checklist15 minAnytime, produces Part VI inventory.
GovernanceBoard Review Process15 min30-60 days before filing.
FinancialPublic Support Test Calculator30-45 minFor 170(b)(1)(A)(vi) charities, annually.
FinancialCompensation Disclosure Worksheet30-60 minOnce compensation data finalized.
FinancialFunctional Expense Allocator30-60 minAfter year-end close.
ProgramsProgram Service Accomplishments20-40 minFor Part III, once your programs are listed.

Recommended order for a first-time user

  1. Filing Form Selector: confirms which form variant, identifies due dates, surfaces e-filing requirements
  2. Schedule Identifier: walks A–R and flags every required, conditional, and not-applicable schedule
  3. Governance Policies Checklist: inventories Part VI policies; identifies gaps to fix before filing
  4. Board Review Process: produces the Schedule O narrative for Part VI Q11b plus standing process document
  5. Public Support Test Calculator: only for 170(b)(1)(A)(vi) donative public charities; runs the math on 5-year support
  6. Compensation Disclosure Worksheet: per-person Part VII Section A and contractor Section B with Schedule J trigger detection
  7. Functional Expense Allocator: documents Part IX methodology with reasonableness checks against watchdog thresholds

Worked example, Governance Policies Checklist

Say "Riverside Youth Arts" wants to inventory its Part VI governance policies before the CPA starts. Here is the exact click-path with sample answers.

1
Open the tool

On the Dashboard, in the Governance & Policies section, click the Governance Policies Checklist card, then click Start →.

2
Answer each policy dropdown

In the Customize panel, set Conflict of Interest Policy to "Yes, adopted, distributed, signed annually," Whistleblower Policy to "Yes, adopted," Document Retention & Destruction Policy to "No," Gift Acceptance Policy to "Not applicable (no non-cash gifts)," and Joint Venture Policy to "Not applicable."

3
Set the review and process fields

Set Executive Compensation Review Process, Form 990 reviewed by board before filing? (Part VI Q11) to "Yes, committee reviews," Bylaws available to the public?, Audited financial statements?, Policy Adoption / Review Period to "Annual," and Adopting Body to "Board of Directors (full board)."

4
Read the gap analysis in the Live Preview

The Live Preview lists each policy with its Part VI line reference and flags the gap: "Document Retention & Destruction Policy: No, recommended" with the next-step recommendation. This is your to-do list before filing.

5
Mark Complete and export to Word

Click ✓ Mark Complete, then ↓ Word (.docx) to hand the inventory and recommendations to your board or CPA.

The tools talk to each other through the org profile

Update your org profile once; every generator picks up the latest data. The Schedule Identifier respects your activity flags. The Filing Form Selector uses your financial size. The Public Support Test uses your tax-exempt sub-classification. Keep the profile current by reopening Organization Settings from the top header.

Program Service Accomplishments (Part III)

Part III asks for narrative descriptions of the organization's program service accomplishments, including for the three largest programs by expense. This is the section donors, funders, and watchdog sites actually read, yet many filers write two or three thin sentences and miss the chance to communicate impact. The Program Service Accomplishments tool gives you a place to list each program (with its expenses, grants, and revenue) and build a proper Part III narrative for each one.

Enter your programs the same way you use the other generators: open the tool, fill the Customize form, watch the Live Preview, mark complete, and export. For each program, capture what it does, who it serves, where, and the outcomes you can quantify (people served, units delivered, hours provided). Lead with outcomes, not activities.

The tool includes an AI drafter that writes the program-accomplishments narrative from the programs you enter. It works only from the details you provide, turning your inputs into clear Part III prose, and the draft flows into your export so you can refine it before handing it to your CPA or board. Treat the output as a first draft to edit, not a finished filing: review every figure, add the specifics only you know, and never rely on it as a guarantee. For how it works and its guardrails, see the AI Automations Guide.

6. Exporting Documents

Three export options on every generator:

  • Download as Word (.docx): formatted with headings, bullets, and the All In One Nonprofit document style. The default for documents going to the CPA or board.
  • Download as HTML: for posting on a private intranet or sending as an email attachment.
  • Copy to Clipboard: plain text with Markdown-style emphasis. Useful when pasting into a board portal, Google Docs, or an existing CPA workpaper template.
Everything runs locally in your browser

No data leaves your device unless you choose to share the resulting document. The first DOCX export per session takes 2-3 seconds while the document library loads from the CDN.

Generated documents are starting drafts

These outputs are designed to be reviewed and finalized by a qualified preparer. The Filing Form Selector, Schedule Identifier, and Public Support Test Calculator perform calculations using widely-applicable rules, but edge cases (group rulings, supporting organizations, fiscal year changes, mergers, foreign affiliates) may produce different answers. Always confirm with a CPA before relying on outputs for filing decisions.

7. The 990 Form Family

There are five 990-series filings. Most nonprofits file one of them annually. Some file two.

Form 990-N (e-Postcard)

The shortest filing in the family, 8 fields, no attachments, no schedules, electronic only. For organizations with gross receipts $50,000 or less. Cannot be extended. Cannot use the e-Postcard if you're a private foundation, a 509(a)(3) Type III supporting organization, or part of a group ruling (the parent files for you). Three consecutive missed 990-Ns = automatic revocation of tax-exempt status with no warning.

Form 990-EZ

The 4-page short form, for organizations with gross receipts under $200,000 AND total assets under $500,000. Both conditions must be met. Schedules A, B, C, E, G, L, N, and O may still apply. Mandatory e-filing since 2020.

Form 990

The full form, 12 pages plus any applicable Schedules A–R. Required when gross receipts are $200,000+ OR total assets are $500,000+. The full 990 includes deeper reporting on programs (Part III), governance (Part VI), compensation (Part VII), and financial position (Parts VIII–XI).

Form 990-PF

The private foundation form, required for all 501(c)(3) private foundations regardless of size. Distinct structure from the 990. Includes investment income reporting, mandatory 5% qualifying distribution calculation, excise taxes under IRC 4940-4945, jeopardizing investment rules, self-dealing prohibitions, and a public list of all grants. Private foundations have substantially more compliance complexity than public charities, which is why the operational decision to be classified as a public charity (when eligible) matters so much.

Form 990-T

The unrelated business income (UBI) form. Required IN ADDITION TO the main 990 if you have $1,000+ of unrelated business gross income. Common UBI sources for nonprofits: advertising revenue, rental of debt-financed property, sale of merchandise not related to mission, parking lot fees from non-affiliated users. Tax is owed at corporate rates on UBI after a $1,000 specific deduction. Net Operating Losses can carry forward in some cases.

Group rulings

If your organization is part of a group ruling (subordinate of a central organization), the central organization may file a group return on your behalf. Some subordinates still must file their own. If you're unsure whether you're covered by a group return, check with the central organization, this is a question that should be answered before any of the tools in this app are useful.

8. Filing Calendar & Deadlines

The Form 990 (and EZ, N, PF) is due the 15th day of the 5th month after the close of your fiscal year. For calendar-year filers (the most common), that's May 15.

Fiscal Year EndOriginal Due DateExtended Due Date (Form 8868)
December 31May 15November 15
March 31August 15February 15
June 30November 15May 15
September 30February 15August 15

Extensions

Form 8868 grants an automatic 6-month extension for Form 990, 990-EZ, and 990-PF. File before the original due date. Form 990-N (e-Postcard) cannot be extended. If you miss the original due date for a 990-N, the only option is to file late (no penalty for late filing of 990-N, but it counts against the three-consecutive-year revocation rule).

Late filing penalties

For organizations with gross receipts under $1.13M: $20 per day late, capped at $10,500 or 5% of gross receipts (whichever is less). For organizations with gross receipts over $1.13M: $110 per day, capped at $56,000 or 5%. Additional penalties apply for late filing of certain schedules. Reasonable cause relief is available but must be requested in writing with detailed explanation.

Automatic revocation

Three consecutive years of non-filing (any combination of 990, 990-EZ, 990-N) results in automatic revocation of tax-exempt status. No warning, no notice, no remedy other than reapplying for tax exemption (Form 1023 or 1024) and paying the user fee. The IRS publishes the auto-revocation list publicly, revocation appears on GuideStar, Charity Navigator, and other public databases. Donations made during the revoked period are not tax-deductible to donors.

The 30-60-90 day planning rule

90 days before deadline: Confirm CPA engagement and timeline. Run the All In One Nonprofit tools to organize source material. 60 days before: Provide complete materials to CPA. Draft begins. 30 days before: Draft delivered to board for review (use the Board Review Process generator). Filing deadline: File electronically. Cushion of 5-7 days for unexpected issues.

9. Schedules A–R, The Full Map

Most filers complete only a few schedules. Some complete more than half. Knowing which ones apply, and which ones are commonly missed, prevents the most common 990 errors.

ScheduleTopicTriggers
APublic Charity Status & Public SupportAll 501(c)(3) public charities, required every year
BSchedule of ContributorsAny contributor of $5,000+ (special 2% rule for 170(b)(1)(A)(vi) public charities)
CPolitical Campaign & Lobbying ActivitiesAny lobbying or political activity (501(c)(3) cannot do political campaign activity)
DSupplemental Financial StatementsDonor-advised funds, conservation easements, art/historical collections, escrow accounts, endowments, certain liabilities
ESchoolsPrivate schools, race nondiscrimination certification
FActivities Outside the U.S.$10,000+ foreign program activity OR $5,000+ in grants outside U.S.
GFundraising/Gaming ActivitiesFundraising event gross receipts > $15,000 OR any gaming
HHospitalsHospital organizations, community benefit reporting
IGrants in the U.S.Grants greater than $5,000 to organizations, governments, or individuals
JCompensation InformationAnyone with combined compensation greater than $150,000 OR other triggers
KTax-Exempt BondsTax-exempt bonds outstanding
LTransactions with Interested PersonsLoans, grants, business transactions, excess benefit with officers/directors/key employees
MNoncash Contributions$25,000+ in non-cash contributions OR any art, historical, qualified conservation contribution
NLiquidation, Termination, DissolutionOrg terminated, liquidated, or substantially contracted
OSupplemental NarrativeUsed by nearly every full-990 filer for Part VI narrative responses
RRelated OrganizationsParent, subsidiary, brother/sister, supporting organization, or unrelated partnerships

The four most commonly missed schedules

  • Schedule L: transactions with interested persons. Any loan to or from an officer/director, any grant to a board member or family member, any business transaction over thresholds. Triggers far more often than organizations realize.
  • Schedule M: non-cash contributions. The $25,000 aggregate threshold is reached faster than expected when in-kind donations of supplies, equipment, professional services, or facility use are counted.
  • Schedule R: related organizations. Often missed when a "fiscal sponsor," "affiliated foundation," or "supporting organization" relationship exists informally.
  • Schedule O: supplemental narrative. Not so much "missed" as "minimal." Many filers use Schedule O only for Part VI Q11b; in practice it should contain narratives for many Part VI governance questions, program accomplishments details (Part III), and any "Yes" answer that benefits from explanation.

10. Part VI Governance Deep Dive

Part VI of Form 990 ("Governance, Management, and Disclosure") asks a series of questions about governance practices. None of these governance policies are legally required for federal tax exemption. But the IRS asks about them in every 990, every answer becomes public, and most funders/accreditors/watchdogs treat them as expected practice.

The Part VI questions worth most of the attention

Section A: Governing Body and Management

  • Q1a-b: Number of voting members of the governing body; how many are independent. "Independent" has a specific definition (no compensation from the org or related orgs, no family/business ties to officers/directors). Organizations with very few independent directors get attention.
  • Q3: Did any officer, director, or key employee have a family or business relationship with another? "Yes" answers require explanation in Schedule O and may trigger Schedule L.
  • Q4: Did the org delegate management duties to a management company? Common with smaller orgs using fiscal sponsors or backbone organizations.
  • Q7a-b: Does the governing body have authority to designate or change members of the governing body? And to designate one or more members of the governing body? These reveal self-perpetuating boards vs. member-elected boards.

Section B: Policies

  • Q11a-b: Process used to review the Form 990 before filing. Use the Board Review Process generator to document this properly.
  • Q12a-c: Conflict of interest policy: written, distributed, annually signed. All three required for "yes" to all three questions.
  • Q13: Whistleblower policy.
  • Q14: Document retention and destruction policy. The All In One Nonprofit Document Retention & Security Policy Generator produces this.
  • Q15a-b: Process used to determine compensation of CEO/Executive Director (Q15a) and other key employees (Q15b). The "rebuttable presumption" 3-prong test is what the IRS expects here.
  • Q16a-b: Joint venture policy with for-profit entities.

A note on the audit questions: they live in Part XII, not Part VI

A common mix-up: Part VI Line 12 is the conflict-of-interest policy, not anything about audits. The audit questions sit in Part XII, Financial Statements and Reporting: Line 2a (were the financials compiled or reviewed by an independent accountant), Line 2b (were they audited), Line 2c (does an audit or finance committee assume responsibility for oversight of the audit and selection of the accountant), and Line 3 (the federal Single Audit, required when the organization spends $1,000,000 or more in federal awards in a year). The Governance Policies Checklist generator now labels this row correctly as Part XII.

Section C: Disclosure

  • Q17-18: State filing requirements; how Form 990, 990-T, and exempt application are made available to the public.
  • Q19-20: Governing documents, conflict of interest policy, and financial statements made available to the public; books and records location.

Why the IRS cares

Part VI doesn't determine your tax-exempt status. It does determine your visibility to IRS Examination Division. The IRS uses Part VI responses as a "soft" enforcement screen, organizations reporting weak governance practices are statistically more likely to have other compliance issues, so they attract examination attention. Investing in adopting the recommended governance policies isn't just good practice, it lowers your audit profile.

Cross-reference: All In One Nonprofit tools that produce Part VI policies

Document Retention & Security Policy Generator (Operations & Compliance Suite), produces the document retention policy for Q14. Nonprofit HR Management Policy Generator (Operations & Compliance Suite), produces the whistleblower policy for Q13. Board Review Process tool (this app): produces the Q11a-b documentation. Compensation Disclosure Worksheet (this app): supports the Q15 rebuttable presumption documentation. Risk Management & Insurance Audit (Governance Suite), the Risk Committee Charter supports the broader governance oversight structure that makes Part VI responses defensible.

11. Public Support Tests Deep Dive

For 501(c)(3) public charities classified under 170(b)(1)(A)(vi) or 509(a)(2), passing the public support test annually is the price of admission to public charity status. Failing it leads to reclassification as a private foundation, with substantially higher tax, distribution, and compliance burdens.

The 170(b)(1)(A)(vi) "donative" public charity test (1/3 test)

For organizations that receive substantial support from gifts, grants, and contributions from the public. The test averages 5 years of support:

  • Numerator (public support) = total contributions, minus the portion of any single non-PC donor's 5-year cumulative giving that exceeds 2% of 5-year total support
  • Denominator (total support) = all contributions + investment income + UBTI + other income
  • Pass threshold = 33⅓% (one-third)

The 2% cap explained

The math behind the 2% cap is the most-misunderstood part of the test. The rule: for individuals and non-public-charity entities, contributions counted toward "public support" are capped at 2% of the org's 5-year total support. Contributions from governmental units and other public charities are NOT subject to this cap (they're counted fully in public support).

Why this matters: a single $500,000 gift from one individual donor to a $400,000-revenue org will mostly NOT count as public support, because 2% of 5-year total support might only be $40,000, so $460,000 of the gift is excluded from the numerator. This is the mechanism that prevents very large individual gifts from undermining the "publicly supported" rationale for public charity status.

The facts and circumstances test (between 10% and 33%)

If public support falls below 33⅓% but is at least 10%, the org may still qualify via the "facts and circumstances" test under Treasury Reg 1.170A-9(f)(3). This requires demonstrating ALL FIVE of:

  1. Continuous active program of fundraising from the general public, governmental units, or other public charities
  2. Representative governing body (not dominated by donors or insiders)
  3. Services or facilities available to the general public
  4. Participation in programs by representative members of the public
  5. Other facts (such as nature of activities, sources of support, etc.)

The facts and circumstances test is judgment-based and requires careful documentation. Working with a CPA experienced in public charity classification is strongly recommended if you find yourself in this zone.

The consequences of failure

Public support below 10% for the test period: cannot use facts and circumstances. Test failed entirely.

Public support below 33⅓% for two consecutive years (with the second year also below 10% in some interpretations): organization is reclassified as a private foundation for the third year forward. Reclassification brings:

  • 1.39% excise tax on net investment income
  • Mandatory annual distribution of 5% of investment assets (qualifying distributions)
  • Jeopardizing investment restrictions (4944)
  • Self-dealing prohibitions (4941), very strict
  • Excess business holdings limits (4943)
  • Public disclosure of every grant on Form 990-PF
  • Loss of deduction percentage advantages (50% AGI cap for public charities vs 30% for private foundations)
  • Substantially higher compliance complexity and cost

The 509(a)(2) "service revenue" public charity test

For organizations whose support is primarily from gross receipts from program activities (service fees, ticket sales, tuition, related revenue) rather than from contributions. The 509(a)(2) test has two prongs:

  • Support prong: more than 33⅓% of support from gifts/grants/contributions/membership fees PLUS gross receipts from exempt-purpose activities (with per-payer/2% limits)
  • Investment limit prong: no more than 33⅓% of support from investment income and UBTI combined

The All In One Nonprofit Public Support Test Calculator currently supports only the 170(b)(1)(A)(vi) test. For 509(a)(2) calculations, work directly with your CPA using Schedule A Part III worksheets.

Strategies for orgs near the 33% line

If you're approaching the 33% line in either direction: (1) Diversify funding, broader donor base reduces the impact of any single donor's 2% cap; (2) Convert large gifts to multi-year pledges, smooths timing across the 5-year test period; (3) Pursue grants from other public charities and foundations, these are NOT subject to the 2% cap; (4) Cultivate corporate giving programs (which are typically not 2%-capped if the corporation is itself a public charity-equivalent); (5) Apply for support from governmental units, which is fully counted in public support.

12. Compensation Reporting Deep Dive

Part VII is the most scrutinized public-disclosure section of the 990. Journalists, donors, and watchdogs pull executive compensation from Part VII for compensation studies, news stories, and donor stewardship.

Who is reportable

  • All current officers, directors, and trustees: regardless of compensation. Even unpaid board members.
  • Key employees: persons receiving greater than $150,000 reportable compensation who also (a) have organization-wide responsibilities, (b) manage a discrete segment representing 10%+ of assets/revenue/expenses, OR (c) have authority over 10%+ of activities. Key employees are limited to the top 20 meeting these tests.
  • 5 highest-compensated employees: the 5 highest-paid employees with reportable compensation ≥ $100,000 who are NOT already listed as officer, director, key employee, or trustee.
  • Former officers/directors/key employees/highest-paid: persons who held one of these positions in any of the 5 prior years and received greater than $10,000 in the current year. Includes consulting payments, deferred comp, severance, supplemental retirement.

What "compensation" means

Compensation in Part VII includes:

  • Reportable compensation (Box 1 of W-2 or Box 7 of 1099-NEC): wages, salary, taxable benefits
  • Retirement and other deferred compensation: employer contributions to qualified retirement plans, 457(b), 457(f), supplemental retirement
  • Nontaxable benefits: employer-paid health insurance premiums, dependent care, tuition, etc.

Compensation from related organizations is reported separately. The IRS aggregates compensation across all related organizations for purposes of Schedule J trigger ($150K) and reasonableness analysis.

Schedule J triggers

Schedule J is required if ANY individual listed in Part VII Section A received total reportable + deferred + nontaxable + related-org compensation greater than $150,000. Schedule J requires disclosure of:

  • Severance and change-of-control payments
  • Supplemental retirement (SERP) details
  • Contingent and equity-based compensation
  • Deferred compensation balances
  • First-class or charter travel
  • Travel for companions (spouse, family)
  • Tax indemnification or gross-up payments
  • Discretionary spending account
  • Housing allowance or personal use of org-provided residence
  • Payments for business use of personal residence
  • Health or social club dues
  • Personal services (e.g., chef, chauffeur, maid)

The "Rebuttable Presumption of Reasonableness" (4958)

IRC 4958 and Treas. Reg. 53.4958-6 establish a process by which the IRS will rebuttably presume executive compensation is reasonable. Meeting all three criteria provides strong protection against intermediate-sanction penalties:

  1. Approved by an independent body: the board, a board committee, or an officer/director without a conflict of interest. The "disqualified person" (the executive whose comp is being set) cannot participate in or be present during the decision.
  2. Appropriate comparable data: salary surveys, GuideStar/Candid nonprofit comp reports, ERI data, or comparable 990 research. Comparables should be for organizations of similar size, geography, and mission.
  3. Contemporaneous documentation: minutes or written record made at the time of the decision (not after) that document the comparables used, the discussion, and the basis for concluding compensation is reasonable.

What happens if compensation is found unreasonable

If compensation is found "excessive" (unreasonable), 4958 imposes intermediate sanctions:

  • The disqualified person (executive) owes 25% excise tax on the excess plus must return the excess to the org
  • If not corrected, an additional 200% tax applies
  • Organization managers who knowingly participated in the excess benefit transaction face their own 10% tax (capped at $20,000 per transaction per manager)
  • The organization may face loss of tax-exempt status in extreme cases
The defensive playbook

Run an annual compensation review for the Executive Director/CEO. Use comparable data from at least two sources. Convene a Compensation Committee (or Executive Committee, or full board minus the Executive Director). Discuss comparables openly. Document the discussion and the vote in minutes BEFORE the next paycheck reflecting any change. Use the Compensation Disclosure Worksheet generator to structure this annually.

13. Functional Expense Allocation Deep Dive

Part IX requires every expense to be allocated across three columns: (B) Program services, (C) Management and general, (D) Fundraising. Column (A) is the unallocated total. Getting this right matters more than most filers realize.

Why functional expense allocation matters

  • Donor scrutiny: the "program expense ratio" (Column B as % of Column A) is the single most-quoted metric in donor decisions and watchdog ratings
  • Charity Navigator: uses program expense ratio in its Financial Health score; below 65% is concerning
  • BBB Wise Giving Alliance: 65% program minimum + 35% fundraising maximum thresholds
  • Funder grant scrutiny: major institutional funders examine the allocation for reasonableness and consistency
  • IRS examination risk: aggressively under-allocating to management/fundraising is a red flag
  • State charity regulators: some states (notably California, New York, Florida, Pennsylvania) examine allocation methodology in registration renewals

The four allocation approaches

  • Direct identification: the expense is identifiable as supporting a single function. Best methodology where it applies. (Example: program director salary ⇒ 100% program; auditor fees ⇒ 100% M&G; capital campaign consultant ⇒ 100% fundraising.)
  • Time studies: for salaries and time-based costs. Sample 1-2 weeks per quarter; staff record what they're working on in 15-minute increments. Aggregate to produce annual allocation percentages. Most defensible methodology for salary allocation.
  • Square footage: for occupancy costs (rent, utilities, repairs). Measure or estimate program space vs admin space vs fundraising space; allocate proportionally.
  • Proportional methods: allocating shared costs proportionally to direct costs, headcount, or other rational basis.

SOP 98-2 Joint Cost Allocation

Statement of Position 98-2 governs allocation of "joint costs" between program and fundraising. A joint cost is one that supports both a program purpose and a fundraising appeal (most commonly: an educational direct-mail piece that also asks for donations). SOP 98-2 requires ALL THREE tests to be met before any portion can be allocated away from fundraising:

  1. Purpose Test: the activity must have a bona fide program purpose, separate from fundraising. A "general awareness" mailing usually fails this test.
  2. Audience Test: the audience must be selected based on need or ability to take a specific program action, not based on capacity or likelihood to contribute. Mailing to past donors usually fails.
  3. Content Test: the materials must call for specific action by the recipient that helps accomplish the org's mission. Generic "support our cause" appeals fail; "smoke detectors save lives, check yours today" succeeds.

Failure of any test means 100% of joint costs are classified as fundraising. Document each test in writing for every joint activity. This is one of the most-examined areas when the IRS does scrutinize functional expense allocations.

Reasonableness benchmarks

RatioTypical RangeConcerning
Program services / Total65-85%Below 65% OR above 95%
Management & general / Total5-15%Above 20% or near 0%
Fundraising / Total5-20%Above 25% (without capital campaign rationale) or 0% on a meaningful budget

These are typical ranges, not rules. Legitimate variations exist: new organizations, organizations conducting capital campaigns, advocacy-heavy nonprofits, grant-making foundations, and organizations with significant in-kind program services may legitimately fall outside these ranges. The key is documenting the methodology that produces your allocation, not chasing a benchmark number.

Don't manipulate the allocation to hit a target

The temptation to "make the program ratio look good" by aggressively allocating shared costs to program is real and dangerous. Aggressive over-allocation is the single most common form of 990 dishonesty, and the IRS, watchdogs, and journalists all know to look for it. Adopt a documented methodology, apply it consistently, and let the numbers be what they are.

14. Common 990 Pitfalls and How to Avoid Them

The Form 990 has hundreds of fields, dozens of schedules, and decades of accumulated reporting rules. These are the issues that come up most often in real nonprofit filings.

Schedule L: the most commonly missed schedule

Schedule L reports transactions with "interested persons", officers, directors, key employees, family members, and entities they control. Common Schedule L triggers that get missed:

  • Loans to or from the organization (including informal advances)
  • Grants to a board member's family member
  • Business transactions with a board member's company over thresholds
  • "Excess benefit" transactions under 4958
  • Rent paid to a board member for facility use
  • Professional services from a board member (auditor, lawyer, consultant) over thresholds

Run a Schedule L screen annually: ask every officer/director/key employee to disclose any transactions during the year. The Conflict of Interest annual disclosure (Q12) is the upstream mechanism.

Part III: program service accomplishments, written too briefly

Part III asks for narrative descriptions of the organization's program service accomplishments, including for the three largest programs (by expense). This is the section donors actually read. Many filers write 2-3 sentences and miss the opportunity to communicate impact. Use Schedule O if more space is needed. Lead with outcomes, not activities. Quantify (people served, units delivered, hours provided) where possible. The Program Service Accomplishments generator, with its AI drafter, helps you build out a fuller Part III narrative from your program details.

Part VI Q11a-b: "yes" without process

Answering "yes" to "Did the organization provide a complete copy of this Form 990 to all members of its governing body before filing?" requires actual process. Email-blasting the draft 48 hours before filing doesn't constitute meaningful review. Use the Board Review Process generator to document a defensible process, and start it 2-4 weeks before filing.

Compensation Q15 without rebuttable presumption documentation

Q15a-b asks whether the process used to set CEO/Executive Director and other key employee compensation included: (1) review and approval by independent persons, (2) comparability data, AND (3) contemporaneous substantiation. All three are required for "yes" to qualify for IRS rebuttable presumption. Many filers say "yes" without all three; if examined, the protection collapses.

Volunteer hours reported as expenses

Volunteer time is NOT a reportable expense on the 990. Even though many nonprofits track and value volunteer hours for grant reporting, GAAP recognition, or insurance purposes, none of that goes on Form 990. The 990 reports only actual cash and in-kind contributions. (Donated professional services that meet GAAP recognition criteria CAN be reported, but only with proper valuation.)

Aggregating with related organizations: missed

Compensation reporting requires aggregating across related organizations. A $100K salary from the filer plus $80K from a related foundation = $180K combined, which triggers Schedule J. Schedule R relationships often expose related-org compensation that wasn't being aggregated.

"Other Expenses" line: too much in the catch-all

Part IX line 24 ("Other expenses") is meant for items not fitting in other categories. If "Other" is the biggest expense category, the 990 raises questions. Discipline expense categorization at the bookkeeping level so other-expenses stays small.

Year-over-year inconsistency without explanation

Material changes from prior year, in revenue mix, expense categories, governance answers, functional allocation percentages, even mission statement, should be explained in Schedule O. Unexplained year-over-year changes are an examination red flag.

State filings forgotten

The federal Form 990 is one filing. Most states require their own annual charity registration renewal, which may require attaching the 990 plus state-specific schedules. States vary widely: some require audited financials, some require specific narrative disclosures, some require notarization. Check your state attorney general's charitable registration unit.

The defensive 990 mindset

The 990 is filed annually for a reason: it's a continuous public record. Every year's filing is compared to prior years. Every governance answer is scrutinized by potential funders. Every compensation number can become news. Treat the 990 as the most important external communication of the year, not a compliance afterthought. Run the seven All In One Nonprofit generators 60-90 days before filing, document everything, and let the numbers tell a defensible story.

🎨 Document Branding

Brand the documents this tool generates. Open your Organization profile (Edit Organization) and use the Document branding section:

  • Letterhead: upload your organization's letterhead image; it appears at the top of every Word document.
  • Footer: your org name, address, and EIN (from your profile) print at the bottom, along with any phone, email, and website you add here, plus optional page numbers.

Set it up once and it's applied automatically to your exports.

Signature details. Beyond the signature image, you can also save a default closing (for example, "Sincerely,"), your name, and your title. These are added with your signature when you export a document, so letters sign off correctly without retyping them each time.

Snippets and stats. Your settings also include a Stats & Snippets panel. Save reusable blocks of text you use often (your mission statement, standard boilerplate, a recurring call to action) and copy any of them into a document you are drafting, so you never rewrite the same wording twice.

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Administrator Access

This app supports a separate Administrator role with elevated permissions. The administrator can view all user accounts, reset application data, and perform setup tasks.

First-Time Setup

From the sign-in screen, click Administrator Access in the side links below the Sign In button. On first use, you will be asked to set a password (enter once, confirm once). This password is stored as a hash in your browser's local storage, the actual password is never stored in cleartext.

Subsequent Sign-In

After setup, the Administrator Access link prompts only for the password. Successful sign-in lands you on the dashboard with administrative privileges enabled (synthetic user admin@local, isSuperAdmin: true).

Forgot the Admin Password?

The password is stored locally in your browser and cannot be recovered. To reset, sign in as any regular user, open the Admin Settings page if you have admin privileges, and use Reset All Data. This clears all application data including the admin password hash, allowing you to set a new one. Be aware that this also clears all generated documents and user accounts, export anything you want to keep first.

Administrator role is per-browser

Because the app runs entirely in your browser with no server-side accounts, the administrator role is browser-specific. If you sign in from a different browser or device, you will need to complete first-time setup again on that device.

Contact & Support

This Nonprofit Annual Return (IRS Form 990) is part of All In One Nonprofit, a growing library of self-service tools and learning content for nonprofit organizations. We are nonprofit board members ourselves, building the tools we wished existed when we started.

Looking for help beyond the platform? See our Helpful Resources page for vetted external resources on legal and tax filing, funder research, governance training, insurance, technology discounts, and more.

Other All In One Nonprofit tools that pair with 990 preparation

Questions, suggestions, bug reports

We read every message and incorporate feedback into the tools. Reach us through the contact form on buildyourclub.com or via the support links on the main BYC site.

A note on legal advice

All In One Nonprofit provides plain-language educational tools and document drafts, not legal advice. For decisions with legal consequences, consult a qualified attorney who works with nonprofits.

Important disclaimers

This tool generates document drafts and calculations based on widely-applicable Form 990 reporting rules. It is not tax advice and does not establish a CPA-client or attorney-client relationship. Form 990 reporting rules are detailed and edge cases (group rulings, supporting organizations, fiscal-year changes, mergers, foreign affiliates, certain industry-specific rules) may produce different answers than this tool's general logic. Always confirm with a qualified CPA or tax preparer before relying on any output for an actual Form 990 filing. The All In One Nonprofit is not responsible for filing decisions, penalties, or other consequences arising from use of the outputs.

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Working with your organization

All In One Nonprofit works as a shared organization. From My Organization you can set up your organization and see who has joined, and everyone is recognized across every app once they sign in. Anyone who signs in with an email address on your organization's own domain (for example you@yournonprofit.org) joins automatically; people using a personal address such as Gmail, Yahoo, or Outlook join with the invite code or email invitation you send them. Signing in is passwordless: enter your email at the member portal, app.allinonenonprofit.com, and we email you a one-click sign-in link (signing in with Google also works). New to the platform? The Platform Workflows shows what to do first, by role. For step-by-step walkthroughs of real situations, see the Workflow Scenarios. Deeper in-app collaboration arrives with your suite as we roll it out, so you can set up your organization now and grow into it.

See the whole platform

Want to see how this fits the rest of All In One Nonprofit? The Complete Platform Guide walks through every app and suite, with screenshots.

Open the Complete Platform Guide →