2023

Instructions for Schedule A 

(Form 990)

Public Charity Status and Public Support

Department of the Treasury

Internal Revenue Service

Section references are to the Internal Revenue Code unless 

otherwise noted.

Future developments. For the latest information about 

developments related to Form 990 and its instructions, such 

as legislation enacted after they were published, go to 

IRS.gov/Form990.

General Instructions

Note. Terms in bold are defined in the Glossary of the 

Instructions for Form 990, Return of Organization Exempt 

From Income Tax.

Purpose of Schedule

Schedule A (Form 990) is used by an organization that files 

Form 990, Return of Organization Exempt From Income Tax, 

or Form 990-EZ, Short Form Return of Organization Exempt 

From Income Tax, to provide the required information about 

public charity status and public support.

Who Must File

An organization that answered “Yes” to Form 990, Part IV, 

line 1, must complete and attach Schedule A (Form 990) to 

Form 990. Any section 501(c)(3) organization (or 

organization treated as such) that files a Form 990-EZ must 

complete and attach this schedule to Form 990-EZ. These 

include:

• Organizations that are described in section 501(c)(3) and 

are public charities;

• Organizations that are described in sections 501(e), 

501(f), 501(j), 501(k), or 501(n); and

• Nonexempt charitable trusts described in section 

4947(a)(1) that aren’t treated as private foundations.

If an organization isn’t required to file Form 990 or 990-EZ 

but chooses to do so, it must file a complete return and 

provide all of the information requested, including the 

required schedules.

Any organization that is exempt from tax under 

section 501(c)(3) but is a private foundation and not a 

public charity shouldn't file Form 990, Form 990-EZ, 

or Schedule A (Form 990), but should file Form 990-PF, 

Return of Private Foundation or Section 4947(a)(1) Trust 

Treated as Private Foundation. See the instructions to Part I.

Accounting Method

When completing Schedule A (Form 990), the organization 

must use the same accounting method it checked on Form 

990, Part XII, line 1, or Form 990-EZ, line G. The organization 

must use this accounting method in reporting all amounts on 

Schedule A (Form 990), regardless of the accounting method 

it used in completing Schedule A (Form 990) for prior years, 

except that in Part V, Sections D and E, distributions must be 

reported on the cash receipts and disbursements method.

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If the accounting method the organization used in 

completing the 2022 Schedule A (Form 990) was different 

from the accounting method checked on the 2023 Form 990, 

Part XII, line 1, or the 2023 Form 990-EZ, line G, the 

organization shouldn't report in either Part II or Part III the 

amounts reported in the applicable columns of the 2022 

Schedule A (Form 990). Instead, the organization should 

report all amounts in Part II or Part III using the accounting 

method checked on the 2023 Form 990, Part XII, line 1, or the 

2023 Form 990-EZ, line G.

If the organization changed its accounting method 

from a prior year, it should provide an explanation in 

Schedule O (Form 990), Supplemental Information to 

Form 990 or 990-EZ.

Example 1. An organization checks “Cash” on Form 990, 

Part XII, line 1. It should report the amounts in Part II or Part III 

using the cash method. If the organization filed a 2022 

Schedule A (Form 990) using the cash method, it should 

report in the 2019 through 2022 columns on the 2023 

Schedule A (Form 990) the same amounts that it reported in 

the 2019 through 2022 columns on the 2022 Schedule A 

(Form 990).

Example 2. An organization checks “Accrual” on Form 

990, Part XII, line 1. The organization reports grants on Form 

990, Part VIII, line 1, in accordance with the Financial 

Accounting Standards Board FASB ASC 958 (see the 

instructions for Form 990, Part VIII, line 1). During the year, 

the organization receives a grant to be paid in future years. 

The organization should report the grant's present value on 

the 2023 Schedule A (Form 990). The organization should 

report accruals of present value increments to the unpaid 

grant on Schedule A (Form 990) in future years.

Specific Instructions

Part I. Reason for Public Charity 

Status

Lines 1–12 (in general)

Check only one of the boxes on lines 1 through 12 to indicate 

the reason the organization is a public charity for the tax 

year. The reason can be the same as stated in the 

organization's tax-exempt determination letter from the IRS 

(“exemption letter”) or subsequent IRS determination letter, or 

it can be different. An organization that doesn't check any of 

the boxes on lines 1 through 12 shouldn't file Form 990, Form 

990-EZ, or Schedule A (Form 990) for the tax year, but 

should file Form 990-PF instead.

If an organization believes there is more than one reason 

why it is a public charity, it should check only one box but can 

explain the other reasons it qualifies for public charity status 

in Part VI. An organization that claims a public charity status 

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Nov 14, 2023 Cat. No. 11294Q
other than section 170(b)(1)(A)(vi) can also demonstrate that 

it qualifies under section 170(b)(1)(A)(vi) by completing Part 

II; it may want to do so for purposes such as qualifying for the 

first Special Rule in Schedule B (Form 990), Schedule of 

Contributors, by meeting the 331/3% support test.

The IRS doesn't update its records on an organization's 

public charity status based on a change the organization 

makes on Schedule A (Form 990). Thus, an organization that 

checks a public charity status different from the reason stated 

in its exemption letter or subsequent determination letter, 

although not required, may submit a request to the IRS 

Exempt Organizations Determinations Office for a 

determination letter confirming that it qualifies for the new 

public charity status if the organization wants the IRS records 

to reflect that new public charity status (also referred to as 

“private foundation status”). See the Instructions for Form 

8940, Request for Miscellaneous Determination. You must 

complete and submit Form 8940 with payment of a user fee 

through Pay.gov. The user fees are listed in Rev. Proc. 

2023-5, 2023-1 I.R.B. 265 (updated annually).

A subordinate organization of a group exemption that 

is filing its own return, but hasn't received its own tax 

exemption determination letter from the IRS, should check 

the public charity status box which most accurately describes 

its public charity status.

An organization that doesn't know the public charity status 

stated in its exemption letter or subsequent determination 

letter should call the Exempt Organizations Customer 

Account Services toll free at 877-829-5500 or write to:

Internal Revenue Service

TE/GE Customer Account Services

P.O. Box 2508

Cincinnati, OH 45201

See the following examples.

Example 1. The organization received an exemption 

letter that it is a public charity under section 170(b)(1)(A)(vi). 

For the tax year, it meets the requirements for public charity 

status under section 170(b)(1)(A)(vi). The organization 

should check the box on line 7 and complete Part II.

Example 2. The organization received an exemption 

letter that it is a public charity under section

170(b)(1)(A)(vi). For the tax year, it doesn't meet the 

requirements for public charity status under section

170(b)(1)(A)(vi). Instead, it meets the requirements for public 

charity status under section 509(a)(2). The organization 

should check the box on line 10 and complete Part III.

Example 3. The organization received an exemption 

letter that it is a public charity under section 509(a)(2). For the 

tax year, it doesn't meet the requirements for public charity 

status under section 509(a)(2) or 170(b)(1)(A)(vi). Instead, it 

meets the requirements for public charity status as a 

supporting organization under section 509(a)(3). The 

organization should:

1. Check the box for line 12 and either line 12a, 12b, 12c, 

or 12d;

2. Complete line 12f;

3. Complete the table on line 12g; and

4. Complete Part IV and (if applicable) Part V.

Example 4. The organization received an exemption 

letter that it is a supporting organization under section 

509(a)(3). Based on Rev. Proc. 2023-5, the organization 

submitted a Form 8940 request to the IRS to change its 

classification to public charity status under section 509(a)(2). 

For the tax year, it meets the requirements of section 509(a)

(2). The organization received a determination letter that it 

has been reclassified as a public charity under section 509(a)

(2). The organization should check the box on line 10 and 

complete Part III.

Example 5. The organization received an exemption 

letter that it is a public charity under section 170(b)(1)(A)(vi). 

For the tax year, it doesn't meet the requirements for public 

charity status under section 170(b)(1)(A)(vi) or 509(a)(2), or 

as a supporting organization under section 509(a)(3). Nor 

does it meet the requirements for public charity status under 

any other provision of the Internal Revenue Code. The 

organization is a private foundation and shouldn't file Form 

990, Form 990-EZ, or Schedule A (Form 990) for the tax year 

but should file Form 990-PF instead.

Example 6. The organization received an exemption 

letter that it is a supporting organization under section 

509(a)(3). The letter doesn't state which type of supporting 

organization it is. The organization should review the 

instructions for lines 12a through 12d to determine which 

type best describes the organization. The organization may 

wish to file Form 8940 to request a determination of type.

Line 1. Check the box for a church, convention of churches, 

or association of churches. Pub. 1828, Tax Guide for 

Churches and Religious Organizations, lists certain 

characteristics generally attributed to churches. These 

attributes of a church have been developed by the IRS and 

by court decisions. They include: distinct legal existence, 

recognized creed and form of worship, definite and distinct 

ecclesiastical government, formal code of doctrine and 

discipline, distinct religious history, membership not 

associated with any other church or denomination, 

organization of ordained ministers, ordained ministers 

selected after completing prescribed courses of study, 

literature of its own, established places of worship, regular 

congregations, regular religious services, Sunday schools for 

the religious instruction of the young, and schools for the 

preparation of its ministers. The IRS generally uses a 

combination of these characteristics, together with other facts 

and circumstances, to determine whether an organization is 

considered a church for federal tax purposes.

Line 2. Check the box for a school whose primary function 

is the presentation of formal instruction, which regularly has a 

faculty, a curriculum, an enrolled body of students, and a 

place where educational activities are regularly conducted. A 

private school must have a racially nondiscriminatory policy 

toward its students. For details about these requirements, 

see Schedule E (Form 990), Schools, and its related 

instructions.

An organization that checks the box on line 2 must 

also complete Schedule E (Form 990), Schools.

Line 3. Check the box for an organization whose main 

purpose is to provide hospital or medical care. A 

rehabilitation institution or an outpatient clinic can qualify as a 

hospital if its principal purposes or functions are the providing 

of hospital or medical care, but the term doesn't include 

medical schools, medical research organizations, 

convalescent homes, homes for children or the aged, or 

vocational training institutions for handicapped individuals.

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-2- Instructions for Schedule A (Form 990) 2023
Check the box on line 3 also for a cooperative hospital 

service organization described in section 501(e).

The definition of hospital for Schedule A (Form 990), 

Part I, is different from the definition for Schedule H 

(Form 990), Hospitals. Accordingly, see Who Must 

File in the Instructions for Schedule H (Form 990) about 

whether the organization is also required to complete 

Schedule H (Form 990).

Line 4. Check the box for an organization whose principal 

purpose or function is to engage in medical research, and 

that is directly engaged in the continuous active conduct of 

medical research in conjunction with a hospital. The hospital 

must be described in section 501(c)(3) or operated by the 

federal government, a state or its political subdivision, a U.S. 

territory or its political subdivision, or the District of Columbia.

If the organization primarily gives funds to other 

organizations (or grants and scholarships to individuals) for 

them to do the research, the organization isn't a medical 

research organization.

The organization isn't required to be an affiliate of the 

hospital, but there must be a joint effort by the organization 

and the hospital to maintain continuing close cooperation in 

the active conduct of medical research.

The definition of medical research for Schedule A 

(Form 990), Part I, is different from the definition for 

Schedule H (Form 990), Hospitals. Accordingly, 

research that is medical research for purposes of determining 

whether an organization is a medical research organization 

isn't necessarily medical research for Schedule H (Form 990) 

reporting purposes.

Assets test/expenditure test. An organization qualifies as 

a medical research organization if its principal purpose is 

medical research, and if it devotes more than half its assets, 

or spends at least 3.5% of the fair market value of its 

endowment, directly in conducting medical research. Either 

test can be met based on a computation period consisting of 

the immediately preceding tax year or the immediately 

preceding 4 tax years.

If an organization doesn't satisfy either the assets test or 

the expenditure test, it can still qualify as a medical research 

organization based on the circumstances involved.

These tests are discussed in Regulations sections 

1.170A-9(d)(2)(v) and (vi). Under these tests, value the 

organization's assets as of any day in its tax year using the 

same day every year, and value the endowment at fair market 

value using commonly accepted valuation methods. See 

Regulations section 2031.

Line 5. Check the box and complete Part II if the 

organization receives and manages property for and expends 

funds to benefit a college or university that is owned or 

operated by one or more states or political subdivisions. The 

school must be an organization described in the instructions 

for line 2.

Expending funds to benefit a college or university includes 

acquiring and maintaining the campus, its buildings and 

equipment, granting scholarships and student loans, and 

making any other payments in connection with the normal 

functions of colleges and universities.

The organization must meet the same public support test 

described later for line 7. See Rev. Rul. 82-132, 1982-2 C.B. 

107.

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Line 6. Only a federal, state, or local government or 

governmental unit that has received an exemption letter 

recognizing it as exempt from tax under section 501(c)(3) 

should check this box. See Rev. Rul. 60-384, 1960-2 C.B. 

172.

Line 7. Check the box and complete Part II if the 

organization meets one of the section 170(b)(1)(A)(vi) public 

support tests. See the instructions for Part II regarding how 

an organization can qualify as a publicly supported 

organization under section 170(b)(1)(A)(vi).

Line 8. Check the box and complete Part II if the 

organization is a community trust and meets a section

170(b)(1)(A)(vi) public support test. A community trust is a 

charity that attracts large contributions for the benefit of a 

particular community or area, often initially from a small 

number of donors, and is generally governed by 

representatives of its particular community or area. See 

Regulations sections 1.170A-9(f)(10), (11), and (12).

A community trust claiming it qualifies as a public 

charity should check the box on line 8 whether it is 

structured as a corporation or as a trust.

Line 9. Check the box if the organization is an agricultural 

research organization described in section 170(b)(1)(A)(ix) 

operated in conjunction with a land-grant college or university 

or a non-land grant college of agriculture. Enter the name, 

city, and state of the college or university. You don't have to 

complete Part II.

Line 10. Check the box and complete Part III if the 

organization meets both of the section 509(a)(2) support 

tests. See the instructions for Part III regarding how an 

organization can qualify as a publicly supported organization 

under section 509(a)(2).

Line 11. Check the box only if the organization has received 

a ruling from the IRS that it is organized and operated 

primarily to test for public safety.

Lines 12 and 12a–12d. If the organization is a supporting 

organization, check the box for line 12 and then check the 

appropriate box for line 12a, 12b, 12c, or 12d to indicate the 

type of supporting organization it is. The organization must 

also complete lines 12e and 12f, the table on line 12g, and 

Part IV. If the organization is a Type III non-functionally 

integrated supporting organization, it must also complete

Part V.

For more information about supporting organizations, see 

Regulations section 1.509(a)-4 and sections 509(a)(3) and 

509(f). For a brief overview of the requirements for 

qualification as a supporting organization, and the different 

types of supporting organizations, see Pub. 557, Tax-Exempt 

Status for Your Organization, and visit IRS.gov/Charities-NonProfits/Section-509(a)(3)-Supporting-Organizations.

Use the information later to determine the supporting 

organization's type. If the organization checks the box on 

line 12e, the letter the organization received from the IRS 

identifies its type. If the box checked on any of lines 12a 

through 12d is different from the type stated in the letter (for 

example, because the organization has made significant 

changes to its structure or operations resulting in it no longer 

qualifying as the type of supporting organization indicated in 

its letter), provide an explanation in Part VI. If the organization 

doesn't check the box on line 12e, it should check the box on 

line 12a, 12b, 12c, or 12d that best describes the type of 

supporting organization it is.

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Instructions for Schedule A (Form 990) 2023 -3-
All supporting organizations, regardless of type, must 

be responsive to the needs or demands of one or 

more supported organizations, and must constitute 

an integral part of, or maintain a significant involvement in, 

the operations of one or more supported organizations. 

Although Type III supporting organizations have specific 

“responsiveness” and “integral part” tests that must be met, 

the relationship between a Type I or Type II supporting 

organization and its supported organization(s) must also 

include these responsiveness and integral part 

characteristics. The ability of the supported organization(s) in 

a Type I or Type II relationship effectively to control the 

supporting organization's board generally ensures that these 

characteristics are present. If they aren't present, however, 

don't check any box for lines 12a through 12d. For more 

information, see Regulations sections 1.509(a)-4(f)(3) and 

(4).

• Type I. A Type I supporting organization is operated, 

supervised, or controlled by one or more publicly supported 

organizations. If the organization otherwise qualifies as a 

supporting organization and can answer “Yes” to the following 

question, check the box for Type I.

Do the supported organizations have a substantial degree 

of direction over the policies, programs, and activities of the 

supporting organization, typically by ensuring that the 

governing body, officers, or membership of the supported 

organizations may regularly appoint or elect a majority of the 

supporting organization's directors or trustees?

• Type II. A Type II supporting organization is supervised 

or controlled in connection with one or more publicly 

supported organizations. If the organization otherwise 

qualifies as a supporting organization and can answer “Yes” 

to the following question, check the box for Type II.

Do the same persons, such as directors, trustees, and 

officers, supervise or control the supported organization(s) 

and the supporting organization?

• Type III—Functionally integrated. Check this box if the 

organization qualifies as a Type III functionally integrated 

supporting organization by meeting the following 

requirements.

1. The organization meets the notification requirement 

described in Part IV, Section D, line 1;

2. The organization meets the responsiveness test (both 

the relationship requirement and the significant voice 

requirement) described in Part IV, Section D, lines 2 and 3; 

and

3. The organization meets one of the alternative integral 

part tests described in Part IV, Section E.

• Type III—Non-functionally integrated. Check this box if 

the organization qualifies as a Type III non-functionally 

integrated supporting organization by meeting the following 

requirements.

1. The organization meets the notification requirement 

described in Part IV, Section D, line 1;

2. The organization meets the responsiveness test (both 

the relationship requirement and the significant voice 

requirement) described in Part IV, Section D, lines 2 and 3; 

and

3. The organization meets the integral part test by 

meeting either (a) the distribution and attentiveness 

requirements described in Part V, or (b) the alternative 

integral part test for certain trusts in existence on November 

20, 1970, described in Part V, line 1.

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Line 12e. The organization's exemption letter or subsequent 

determination letter may state the type of supporting 

organization it is. If it does, check the box on this line. If the 

letter doesn't state the type, or if the letter states Type III but 

doesn't specify whether functionally integrated or 

non-functionally integrated, leave this line blank.

A grantor to a section 509(a)(3) supporting organization, 

acting in good faith, can rely on this letter in determining 

whether the organization is a Type I, Type II, Type III 

functionally integrated, or Type III non-functionally integrated 

supporting organization until the IRS makes a public 

announcement of the entity’s change in status. See Rev. 

Proc. 2018-32, 2018-23 I.R.B. 739.

Line 12f. A supporting organization must be organized and 

operated exclusively to support or benefit one or more 

specified publicly supported organizations. Please write in 

the space provided the number of supported organizations. 

Include all supported organizations that the organization was 

organized to support at any time during the tax year, whether 

or not they actually received support during the tax year.

Line 12g. An organization checking a box on line 12a, 12b, 

12c, or 12d must complete the table on line 12g.

• Columns (i) and (ii). Enter the name and employer 

identification number (EIN) for each supported 

organization counted on line 12f. If the organization had 

more than five supported organizations during the tax year, 

enter the additional organizations on duplicate pages of 

Schedule A (Form 990), Part I. Use as many duplicate copies 

as needed, and number each page.

• Column (iii). For each supported organization named in 

column (i), enter the line number (from lines 1 through 10 

above) that best describes the foundation status of the 

supported organization.

Example 1. If the supported organization is a hospital, 

then that is an organization described in section 170(b)(1)(A)

(iii), and you should enter “3” in column (iii).

Example 2. If the supported organization is a federal, 

state, or local governmental unit, or foreign government, then 

that is an organization described in section 170(b)(1)(A)(v), 

and you should enter “6” in column (iii).

Example 3. If the supported organization is exempt under 

section 501(c)(4), 501(c)(5), or 501(c)(6), but can be 

supported by a supporting organization (see Regulations 

section 1.509(a)-4(k)), enter the line number (from lines 1 

through 10 above) that would describe the section 501(c)(4), 

501(c)(5), or 501(c)(6) organization if it were a section 501(c)

(3) organization. Identify the specific code section (501(c)(4), 

501(c)(5), or 501(c)(6)) for each such supported organization 

in Part VI.

The only correct entry in column (iii) is a line number 

(from lines 1 through 10) that corresponds to the 

description of the supported organization.

• Column (iv). Check “Yes” if the supported organization 

named in column (i) is specifically named as a supported 

organization in the organization's declaration of trust, articles 

of incorporation, or other governing document. If the 

supported organization is not named in the organizing 

documents, check “No” and explain why in Part VI.

• Column (v). Enter the total amount of monetary support 

paid to, or for the benefit of, the supported organization 

named in column (i) during the tax year. Such monetary 

support may include making payments to or for the use of 

individual members of the charitable class benefited by the 

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-4- Instructions for Schedule A (Form 990) 2023
supported organization (such as scholarships), and to 501(c)

(3) public charities operated, supervised, or controlled 

directly by or in connection with the supported organization. 

See Regulations section 1.509(a)-4(e). If no monetary 

support was provided during the tax year, enter “0”.

• Column (vi). In this column, the organization may (but 

isn't required to) provide an estimate of the fair market value 

of goods, other property, services, and use of facilities that is 

provided to or for the benefit of the supported organizations 

during the tax year. Describe in Part VI any such goods, other 

property, services, and use of facilities, whether or not an 

amount is reported for them in column (vi).

Part II. Support Schedule for 

Organizations Described in Sections 

170(b)(1)(A)(iv) and 170(b)(1)(A)(vi)

If the organization checked a box in Part I, on line 5, 

7, or 8, it should complete Part II and insert the 

appropriate dollar amounts. Don't leave Part II blank 

or report only zeros if the organization had any support during 

the period. If the organization checks the box in Part II, on 

line 13, it should stop there and not complete the rest of Part 

II.

If the organization checked a box in Part I, on line 5, 

7, or 8 and also checks the box in Part II, on line 18, 

the organization should complete Part III to determine 

if it qualifies as a publicly supported organization under 

section 509(a)(2). If it does qualify, the organization should 

instead check the box in Part I, on line 10.

Public Support Test. For an organization to qualify as a 

publicly supported organization under section 170(b)(1)(A)

(vi), either:

• 331/3% or more of its total support must come from 

governmental units, contributions from the general public, 

and contributions or grants from other public charities; or

• 10% or more of its total support must come from 

governmental units, contributions from the general public, 

and contributions or grants from other public charities and the 

facts and circumstances indicate it is a publicly supported 

organization.

Note. An organization won't meet either of these public 

support tests if almost all of its support comes from gross 

receipts from related activities and an insignificant amount of 

its support comes from governmental units and 

contributions made directly or indirectly by the general 

public.

Public support is measured using a 5-year computation 

period that includes the current and 4 prior tax years 

(including short years). If the organization's current tax year 

or any of its 4 prior tax years were short years, explain in Part 

VI.

If the organization wasn't a section 501(c)(3) organization 

for the entire 5-year period in Part II, report amounts only for 

the years the organization was a section 501(c)(3) 

organization.

Line 1. Don't include any “unusual grants.” See Unusual 

grants, later. Include membership fees only to the extent to 

which the fees are payments to provide support for the 

organization rather than to purchase admissions, 

merchandise, services, or the use of facilities. To the extent 

that the membership fees are payments to purchase 

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admissions, merchandise, services, or the use of facilities in 

a related activity, report the membership fees on line 12. To 

the extent that the membership fees are payments to 

purchase admissions, merchandise, services, or the use of 

facilities in an unrelated business activity, report the 

membership fees on line 9. See Regulations section 

1.170A-9(f)(7)(iv). Include qualified sponsorship payments 

under section 513(i).

Noncash contributions. Use any reasonable method to 

determine the value of noncash contributions reported on 

line 1.

Don't report any donations of services (such as the value 

of donated advertising space or broadcast air time) or 

donations of use of materials, equipment, or facilities, on 

line 1 as gifts, grants, or contributions. Donated services and 

facilities from a governmental unit only are reported on 

line 3.

Loss on uncollectible pledge. If an organization records 

a loss on an uncollectible pledge that it reported on a prior 

year's Schedule A (Form 990), it should deduct that loss from 

the contribution amount for the year in which it originally 

counted that contribution as revenue. For example, if in the 

prior tax year the organization reported a pledged 

contribution with a then-present value of $50,000 in Part II, 

line 1, column (e), but learned during the current tax year that 

it wouldn't receive any of that pledged contribution, it should 

deduct the $50,000 from the amount reported in Part II, 

line 1, column (d), for the prior tax year.

Support from a governmental unit. Include on line 1 

support received from a governmental unit. This includes 

contributions, but not gross receipts from exercising or 

performing the organization's tax-exempt purpose or 

function, which should be reported on line 12. An amount 

received from a governmental unit is treated as gross 

receipts from exercising or performing the organization's 

tax-exempt purpose or function if the purpose of the payment 

is primarily to serve the direct and immediate needs of the 

payor governmental unit, and is treated as a contribution, if 

the purpose is primarily to provide a direct benefit to the 

public. For example, a payment to maintain library facilities 

that are open to the public should be treated as a 

contribution. See Regulations section 1.170A-9(f)(8) and 

Rev. Rul. 81-276, 1981-2 C.B. 128. Refer to the instructions 

for Form 990, Part VIII, lines 1e and 2, for more examples 

addressing the distinction between government payments 

that are contributions and government payments that are 

gross receipts from activities related to the organization's 

tax-exempt purpose or function. Medicare and Medicaid 

payments are treated as gross receipts from patients rather 

than as contributions from the government payor for 

purposes of the public support test. See Rev. Rul. 83-153, 

1983-2 C.B. 48.

The Coronavirus Aid, Relief, and Economic Security 

Act (CARES Act) established the Paycheck 

Protection Program (PPP) to provide loans to small 

businesses as a direct incentive to keep their workers on the 

payroll. The loans are forgiven if all employee retention 

criteria are met and the funds are used for eligible expenses. 

Amounts of PPP loans that are forgiven may be reported on 

line 1 as contributions from a governmental unit in the tax 

year when the amounts are forgiven or at such other time as 

provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.

Unusual grants. Unusual grants are generally substantial 

contributions and bequests from disinterested persons and 

are:

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Instructions for Schedule A (Form 990) 2023 -5-
1. Attracted because of the organization's publicly 

supported nature,

2. Unusual and unexpected because of the amount, and

3. Large enough to endanger the organization's status as 

normally meeting either the 331/3% public support test or the 

10%-facts-and-circumstances test.

For a list of other factors to be considered in determining 

whether a grant is an unusual grant, see Regulations section 

1.509(a)-3(c)(4).

An unusual grant is excluded even if the organization 

receives or accrues the funds over a period of years.

Don't report gross investment income items as unusual 

grants. Instead, include all investment income on line 8.

See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations 

section 1.170A-9(f)(6)(ii); and Regulations sections 

1.509(a)-3(c)(3) and (4) for details about unusual grants.

Include in Part VI a list showing the amount, but not the 

grantor, of each unusual grant actually received each year (if 

the cash accounting method is used) or accrued each year (if 

the accrual accounting method is used).

Don't include the names of the grantors because Part 

VI will be made available for public inspection.

Unusual grants recordkeeping. An organization that 

received any unusual grants during the 5-year period should 

also keep for its records a list showing, for each year, the 

name of the contributor, the date and amount of the grant, 

and a brief description of the grant. If the organization used 

the cash method for the applicable year, show only the 

amounts the organization actually received during that year. If 

the organization used the accrual method for the applicable 

year, show only the amounts the organization accrued for that 

year. An example of this list is given below.

Don't file this list with the organization's Form 990 or 

990-EZ because it may be made available for public 

inspection.

Line 1. Example—List of unusual grants

Year ▶ 2023 Description 

Name ▶ Mr. Distinguished Donor Undeveloped land 

Date of Grant ▶ January 15, 

2023

Amount of Grant ▶ $600,000

Conservation easements and qualified conservation 

contributions. The organization must report any qualified 

conservation contributions and contributions of conservation 

easements consistently with how it reports revenue from 

such contributions in its books, records, and financial 

statements and in Form 990, Part VIII, Statement of Revenue.

Reporting contributions not reported as revenue. If the 

organization reports any contributions on line 1 of 

Schedule A (Form 990), Part I, that it doesn't report on Form 

990 as revenue in Part VIII or as assets in Part X, or as 

CAUTION

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CAUTION

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revenue or assets on Form 990-EZ, explain in Part VI the 

basis for characterizing such transfers as contributions but 

not as revenue or assets. For example, if an organization is a 

community foundation that receives and holds a cash transfer 

for another tax-exempt organization and reports contributions 

of such property on Schedule A (Form 990), Part II, line 1, 

without reporting it on Form 990 as revenue in Part VIII or 

assets in Part X, explain the basis for characterizing the 

property as contributions but not as revenue or assets.

Line 2. Enter tax revenue levied for the organization's benefit 

by a governmental unit and either paid to the organization 

or expended on its behalf. Report this amount whether or not 

the organization includes this amount as revenue on its 

financial statements or elsewhere on Form 990 or 990-EZ.

Line 3. Enter the value of services or facilities furnished by a 

governmental unit to the organization without charge. Don't 

include the value of services or facilities generally furnished 

to the public without charge. For example, include the fair 

rental value of office space furnished by a governmental unit 

to the organization without charge but only if the 

governmental unit doesn't generally furnish similar office 

space to the public without charge. Report these amounts 

whether or not the organization includes these amounts as 

revenue on its financial statements or elsewhere on Form 990 

or 990-EZ.

Line 5. Enter in column (f) the portion of total contributions 

by each individual, trust, or corporation included on line 1 for 

the years reported that exceeds 2% of the amount reported in 

line 11, column (f). In applying the 2% limitation, all 

contributions made by a donor and by any person or persons 

standing in a relationship to the donor that is described in 

sections 4946(a)(1)(C) through (a)(1)(G) and the related 

regulations (for example, spouses and certain other family 

members, and entities where ownership or control interests 

exceed a threshold level) will be treated as made by one 

person. However, the 2% limitation doesn't apply to 

contributions from organizations qualifying as publicly 

supported organizations under section 170(b)(1)(A)(vi), 

governmental units described in section 170(b)(1)(A)(v), and 

other organizations, such as the following, but only if they 

also qualify as publicly supported organizations under 

section 170(b)(1)(A)(vi).

• Churches described in section 170(b)(1)(A)(i),

• Educational institutions described in section 170(b)(1)(A)

(ii),

• Hospitals described in section 170(b)(1)(A)(iii),

• Organizations operated for the benefit of a college or 

university owned or operated by a governmental unit 

described in section 170(b)(1)(A)(iv), and

• Agricultural research organizations described in section 

170(b)(1)(A)(ix).

The organization should keep for its records a list showing 

the name of and amount contributed by each donor (other 

than a governmental unit or publicly supported 

organization) whose total gifts during the years reported 

exceed 2% of the amount reported in line 11, column (f). An 

example of this list is given later.

Don't file this list with the organization's Form 990 or 

990-EZ because it may be made available for public 

CAUTION

inspection.

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-6- Instructions for Schedule A (Form 990) 2023
Line 5. Example—List of donors other than governmental units and publicly supported organizations

Assumption: 2% of the amount on Schedule A (Form 990), Part II, line 11, column (f), is $12,000.

Contributors whose total gifts from 2018 through 2022 were in excess of the 2% limitation 

(a) (b) (c) (d) (e) (f) (g)

Name 2019 2020 2021 2022 2023 Total Excess 

contributions 

(column (f) 

minus the 2% 

limitation)

XYZ Foundation $59,000 $3,000 $18,000 $80,000 $68,000 

Banana Office 

Supply 

$12,000 $3,000 $1,000 $16,000 $4,000 

Plum Corporation $15,000 $15,000 $30,000 $18,000 

John Smith $5,000 $5,000 $5,000 $1,000 $16,000 $4,000 

Sue Adams $10,000 $10,000 $10,000 $30,000 $18,000 

Raisin Trade 

Assoc. 

$20,000 $7,000 $27,000 $15,000 

Total. Add the items in column (g). Enter the total here and on Part II, column (f), line 5 ............................ $127,000 

Line 8. Include the gross income from interest, dividends, 

payments with respect to securities loans (section 512(a)(5)), 

rents, royalties, and income from similar sources. Don't 

include on this line payments that result from activities of the 

organization that further its exempt purpose. Instead, report 

these amounts on line 12.

Line 9. Enter the organization's net income from conducting 

unrelated business activities, whether or not the activities 

are regularly conducted as a trade or business. See sections 

512 and 513 and the applicable regulations. Include 

membership fees to the extent they are payments to 

purchase admissions, merchandise, services, or the use of 

facilities in an activity that is an unrelated business.

When calculating unrelated business taxable income 

(UBTI) for this purpose, an exempt organization with more 

than one unrelated trade or business may use either its UBTI 

calculated under section 512(a)(6) or its UBTI calculated in 

the aggregate. If a net loss results, enter “0” on this line.

Line 10. Include all support as defined in section 509(d) that 

isn't included elsewhere in Part II. Explain in Part VI the 

nature and source of each amount reported. Don't include 

gain or loss from amounts reportable on line 12 or from the 

sale of capital assets.

Line 12. Enter the total amount of gross receipts the 

organization received from related activities for all years 

reported in Part II. The organization won't be treated as 

meeting the section 170(b)(1)(A)(vi), 331/3% public support 

test or the 10%-facts-and-circumstances public support test, 

if almost all of its support consists of gross receipts from 

related activities and an insignificant amount of its support 

comes from governmental units and public contributions. 

See Regulations section 1.170A-9(f)(7)(iii).

Include on line 12 gross receipts from admissions, sales of 

merchandise, performance of services, or furnishing of 

facilities in any activity which isn't an unrelated trade or 

business (within the meaning of section 513). See section 

509(d)(2). Include membership fees to the extent they are 

payments to purchase admissions, merchandise, services, or 

the use of facilities in a related activity. For example, include 

on this line gross receipts from:

• A trade or business in which substantially all work is 

performed by volunteers (such as book fairs and sales of gift 

wrap paper). See section 513(a)(1).

• A trade or business carried on by the organization primarily 

for the convenience of its members, students, patients, 

officers, or employees. See section 513(a)(2).

• A trade or business which is the selling of merchandise, 

substantially all of which the organization received as gifts or 

contributions. See section 513(a)(3).

• “Qualified public entertainment activities” or “qualified 

convention and trade show activities” of certain 

organizations. See section 513(d).

• Furnishing certain hospital services. See section 513(e).

• A trade or business consisting of conducting bingo 

games, but only if the conduct of such games is lawful. See 

section 513(f).

• Qualified pole rentals by a mutual or cooperative telephone 

or electric company. See section 513(g).

• The distribution of certain low-cost articles incidental to the 

solicitation of charitable contributions (except to the extent 

such gross receipts are properly treated as charitable 

contributions reportable on line 1 rather than as proceeds of 

a sale or exchange), and exchange and rental of members 

lists. See section 513(h).

Line 13. An organization that checks this box should stop 

here and shouldn't complete the rest of Part II. It shouldn't 

make a public support computation on line 14 or 15 or check 

any of the boxes on lines 16 through 18.

Example. An organization receives an exemption letter 

from the IRS that it is exempt from tax under section

501(c)(3) and qualifies as a public charity under section 

170(b)(1)(A)(vi) effective on its date of incorporation. When 

the organization prepares Part II for each of its first 5 tax 

years as a section 501(c)(3) organization, it should check the 

box on line 13 and shouldn't complete the rest of Part II. 

When the organization prepares Part II for its sixth tax year 

and subsequent years, it shouldn't check the box on line 13 

and should complete the rest of Part II.

Instructions for Schedule A (Form 990) 2023 -7-
An organization in its first 5 years as a section 501(c)

(3) organization should make the public support 

computations on a copy of Schedule A (Form 990) 

that it keeps for itself. An organization should carefully 

monitor its public support on an ongoing basis to ensure that 

it will meet a public support test in the sixth year and 

succeeding years.

Line 14. Round to the nearest hundredth decimal point in 

reporting the percentage of public support. For example, if 

the organization calculates its public support percentage as 

58.3456%, this percentage would be rounded to 58.35% 

when reported on line 14.

Line 15. For 2023, enter the public support percentage from 

the 2022 Schedule A (Form 990), Part II, line 14. Round to 

the nearest hundredth decimal point in reporting the 

percentage of public support.

Line 16a. If the organization didn't check the box on line 13, 

and line 14 is 331/3% or more, check the box on this line 

and don't complete the rest of Part II. The organization 

qualifies as a publicly supported organization for 2023 and 

2024.

Line 16b. If the organization didn't check a box on line 13 or 

16a, and line 15 is 331/3% or more, check the box on this 

line and don't complete the rest of Part II. The 

organization qualifies as a publicly supported organization for 

2023.

Line 17a. If the organization didn't check a box on line 13, 

16a, or 16b, and line 14 is 10% or more, and if the 

organization meets the facts-and-circumstances test, check 

the box on this line and don't complete the rest of Part 

II. The organization qualifies as a publicly supported 

organization for 2023 and 2024.

If this box is checked, explain in Part VI how the 

organization meets the facts-and-circumstances test in 

Regulations section 1.170A-9(f)(3). Include the following 

information.

• Explain whether the organization maintains a continuous 

and bona fide program for solicitation of funds from the 

general public, community, membership group involved, 

governmental units, or other public charities.

• List all other facts and circumstances, including the 

sources of support, whether the organization has a 

governing body that represents the broad interests of the 

public, and whether the organization generally provides 

facilities or services directly for the benefit of the general 

public on a continuing basis.

• If the organization is a membership organization, explain 

whether the solicitation for dues-paying members is designed 

to enroll a substantial number of persons from the 

community, whether dues for individual members have been 

fixed at rates designed to make membership available to a 

broad cross-section of the interested public, and whether the 

activities of the organization will likely appeal to persons 

having some broad common interest or purpose.

Line 17b. If the organization didn't check a box on line 13, 

16a, 16b, or 17a, and line 15 is 10% or more, and if the 

organization meets the facts-and-circumstances test, check 

the box on this line and don't complete the rest of Part 

II. The organization qualifies as a publicly supported 

organization for 2023. If this box is checked, explain in Part VI 

how the organization meets the facts-and-circumstances test 

in Regulations section 1.170A-9(f)(3). Include the same 

information identified in the instructions for Line 17a, earlier.

TIP

Line 18. If the organization didn't check a box on line 13, 

16a, 16b, 17a, or 17b, it doesn't qualify as a publicly 

supported organization under section 170(b)(1)(A)(iv) or 

170(b)(1)(A)(vi) for the 2023 tax year and should check the 

box on this line. If the organization doesn't qualify as a public 

charity under any of the boxes in Part I, lines 1 through 12, it 

is a private foundation as of the beginning of the 2023 tax 

year for filing purposes and shouldn't file Form 990, Form 

990-EZ, or Schedule A (Form 990) for the 2023 tax year. 

Instead, the organization should file Form 990-PF and check 

Initial return of a former public charity on Form 990-PF, at the 

top of page 1.

If Form 990 or 990-EZ is for the organization's sixth 

tax year as a section 501(c)(3) organization, the 

organization should figure the public support 

percentage on its Form 990 or 990-EZ for its first 5 tax years 

before it checks the box on line 18. If its public support 

percentage for its first 5 tax years is 331/3% or more, or if it 

meets the 10%-facts-and-circumstances test for its first 5 tax 

years, it will qualify as a public charity for its sixth tax year. If 

the organization qualifies under the 10% test, explain in Part 

VI.

If the organization doesn't qualify as a publicly 

supported organization under section 170(b)(1)(A)

(vi), it can complete Part III to determine if it qualifies 

as a publicly supported organization under section 509(a)(2).

Part III. Support Schedule for 

Organizations Described in Section 

509(a)(2)

If an organization checked the box in Part I, for 

line 10, it should complete Part III and insert the 

appropriate dollar amounts. Don't leave Part III blank 

or report only zeros if the organization had any support during 

the period. If the organization checks the box in Part III, for 

line 14, it should stop there and not complete the rest of Part 

III.

If the organization checked the box in Part I, for 

line 10, and also checks the box in Part III, for line 20, 

the organization should complete Part II to determine 

if it qualifies as a publicly supported organization under 

section 170(b)(1)(A)(vi). If it does qualify, the organization 

should instead check the box in Part I, for line 5, 7, or 8, 

whichever applies.

Public Support Test. For an organization to qualify as a 

publicly supported organization under section 509(a)(2):

• More than 331/3% of its support normally must come from 

gifts, grants, contributions, membership fees, and gross 

receipts from admissions, sales of merchandise, 

performance of services, or furnishing of facilities in an 

activity which isn't an unrelated trade or business under 

section 513; and

• No more than 331/3% of its support normally must come 

from gross investment income and net unrelated business 

income (less section 511 tax) from businesses acquired by 

the organization after June 30, 1975.

Public support is measured using a 5-year computation 

period that includes the current and 4 prior tax years 

(including short years). If the organization's current tax year 

or any of its 4 prior tax years were short years, explain in Part 

VI.

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-8- Instructions for Schedule A (Form 990) 2023
In Part III, if the organization wasn't a section 501(c)(3) 

organization for the entire 5-year period, report amounts only 

for the years the organization was a section 501(c)(3) 

organization.

Line 1. Don't include any “unusual grants.” See Unusual 

grants, later. Include membership fees only to the extent to 

which the fees are payments to provide support for the 

organization rather than to purchase admissions, 

merchandise, services, or the use of facilities. To the extent 

that the membership fees are payments to purchase 

admissions, merchandise, services, or the use of facilities in 

a related activity, include the membership fees on line 2. See 

Regulations section 1.509(a)-3(h). To the extent that the 

membership fees are payments to purchase admissions, 

merchandise, services, or the use of facilities in an activity 

that isn't an unrelated business under section 513, report 

the membership fees on line 3. To the extent that the 

membership fees are payments to purchase admissions, 

merchandise, services, or the use of facilities in an activity 

that is an unrelated business, report the net amount either on 

line 10b or 11, as appropriate.

Noncash contributions. Use any reasonable method to 

determine the value of noncash contributions reported on 

line 1.

Don't report any donations of services (such as the value 

of donated advertising space or broadcast air time) or 

donations of use of materials, equipment, or facilities on 

line 1 as gifts, grants, or contributions. Donated services and 

facilities from a governmental unit are reported on line 5.

Loss on uncollectible pledge. If an organization records 

a loss on an uncollectible pledge that it reported on a prior 

year's Schedule A (Form 990), it should deduct that loss from 

the contribution amount for the year in which it originally 

counted that contribution as revenue. For example, if in the 

prior tax year the organization reported a pledged 

contribution with a then-present value of $50,000 in Part III, 

line 1, column (e), but learned during the current tax year that 

it wouldn't receive any of that pledged contribution, it should 

deduct the $50,000 from the amount reported in Part III, 

line 1, column (d), for the prior tax year.

Support from a governmental unit. Include on line 1 

support received from a governmental unit. This includes 

contributions, but not gross receipts from exercising or 

performing the organization's tax-exempt purpose or 

function, which should be reported on line 2. Contributions 

are sometimes difficult to distinguish from such gross 

receipts—the label on the agreement isn't controlling. An 

amount received from a governmental unit is treated as gross 

receipts from exercising or performing the organization's 

tax-exempt purpose or function if the purpose of the payment 

is primarily to serve the direct and immediate needs of the 

payor governmental unit. An amount is treated as a 

contribution if the purpose of the payment is primarily to 

provide a direct benefit to the public. For example, if a state 

government agency pays an organization to operate an 

institute to train agency employees in the principles of 

management and administration, the funds received should 

be included on line 2 as gross receipts. See Regulations 

section 1.509(a)-3(g). Refer to the instructions for Form 990, 

Part VIII, lines 1e and 2, for more examples addressing the 

distinction between government payments that are 

contributions and government payments that are gross 

receipts from activities related to the organization's 

tax-exempt purpose or function. Medicare and Medicaid 

payments are treated as gross receipts from patients rather 

than as contributions from the government payor for 

purposes of the public support test. See Rev. Rul. 83-153, 

1983-2 C.B. 48.

The Coronavirus Aid, Relief, and Economic Security 

Act (CARES Act) established the Paycheck 

Protection Program (PPP) to provide loans to small 

businesses as a direct incentive to keep their workers on the 

payroll. The loans are forgiven if all employee retention 

criteria are met and the funds are used for eligible expenses. 

Amounts of PPP loans that are forgiven may be reported on 

line 1 as contributions from a governmental unit in the tax 

year when the amounts are forgiven or at such other time as 

provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.

Unusual grants. Unusual grants are generally substantial 

contributions and bequests from disinterested persons and 

are:

1. Attracted because of the organization's publicly 

supported nature,

2. Unusual and unexpected because of the amount, and

3. Large enough to endanger the organization's status as 

normally meeting the 331/3% public support test.

For a list of other factors to be considered in determining 

whether a grant is an unusual grant, see Regulations section 

1.509(a)-3(c)(4).

An unusual grant is excluded even if the organization 

receives or accrues the funds over a period of years.

Don't report gross investment income items as unusual 

grants. Instead, include all investment income on line 10a.

See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations 

section 1.170A-9(f)(6)(ii); and Regulations sections 

1.509(a)-3(c)(3) and (4) for details about unusual grants.

Include in Part VI a list showing the amount, but not the 

grantor, of each unusual grant actually received each year (if 

the cash accounting method is used) or accrued each year (if 

the accrual accounting method is used).

Don't include the names of the grantors because Part 

VI will be made available for public inspection.

Unusual grants recordkeeping. An organization that 

received any unusual grants during the 5-year period, should 

also keep for its records a list showing, for each year, the 

name of the contributor, the date and amount of the grant, 

and a brief description of the grant. If the organization used 

the cash method for the applicable year, show only amounts 

the organization actually received during that year. If the 

organization used the accrual method for the applicable year, 

show only amounts the organization accrued for that year. An 

example of this list is given below.

Don't file this list with the organization's Form 990 or 

990-EZ because it may be made available for public 

inspection.

TIP

CAUTION

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CAUTION

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Instructions for Schedule A (Form 990) 2023 -9-
Line 1. Example—List of unusual grants

Year ▶ 2023 Description 

Name ▶ Mr. Distinguished Donor Undeveloped land 

Date of Grant ▶ January 15, 

2023

Amount of Grant ▶ $600,000

Conservation easements and qualified conservation 

contributions. The organization must report any qualified 

conservation contributions and contributions of conservation 

easements consistently with how it reports revenue from 

such contributions in its books, records, and financial 

statements and in Form 990, Part VIII, Statement of Revenue.

Reporting contributions not reported as revenue. If the 

organization reports any contributions on Schedule A (Form 

990), Part III, line 1, that it doesn't report on Form 990, as 

revenue in Part VIII or as assets in Part X, or as revenue or 

assets on Form 990-EZ, explain in Part VI the basis for 

characterizing such transfers as contributions but not as 

revenue or assets. For example, if an organization is a 

community foundation that receives and holds a cash transfer 

for another tax-exempt organization and reports contributions 

of such property on Schedule A (Form 990), Part III, line 1, 

without reporting it on Form 990, as revenue in Part VIII or 

assets in Part X, explain the basis for characterizing the 

property as contributions but not as revenue or assets.

Line 2. Include gross receipts from admissions, 

merchandise sold, services performed, or facilities furnished 

in any activity that is related to the organization's tax-exempt 

purpose (such as charitable, educational, etc.).

To the extent that membership fees are payments to 

purchase admissions, merchandise, services, or the use of 

facilities in a related activity, include the membership fees on 

this line 2. See Regulations section 1.509(a)-3(h).

Line 3. Include gross receipts from activities that aren't an 

unrelated trade or business under section 513, such as:

• A trade or business in which substantially all work is 

performed by volunteers (such as book fairs and sales of gift 

wrap paper). See section 513(a)(1).

• A trade or business carried on by the organization primarily 

for the convenience of its members, students, patients, 

officers, or employees. See section 513(a)(2).

• A trade or business that is the selling of merchandise, 

substantially all of which the organization received as gifts or 

contributions. See section 513(a)(3).

• “Qualified public entertainment activities” or “qualified 

convention and trade show activities” of certain 

organizations. See section 513(d).

• Furnishing certain hospital services. See section 513(e).

• A trade or business consisting of conducting bingo 

games, but only if the conduct of such games is lawful. See 

section 513(f).

• Qualified pole rentals by a mutual or cooperative telephone 

or electric company. See section 513(g).

• The distribution of certain low-cost articles incidental to the 

solicitation of charitable contributions (except to the extent 

such gross receipts are properly treated as charitable 

contributions reportable on line 1 rather than as proceeds of 

a sale or exchange), and exchange and rental of members 

lists. See section 513(h).

While the activity of soliciting and receiving qualified 

sponsorship payments is also excluded from unrelated 

business (see section 513(i)), the qualified sponsorship 

payments themselves are treated as charitable contributions 

reportable on line 1.

Line 4. Enter tax revenue levied for the organization's benefit 

by a governmental unit and either paid to the organization 

or expended on its behalf. Report this amount whether or not 

the organization includes this amount as revenue on its 

financial statements or elsewhere on Form 990 or 990-EZ.

Line 5. Enter the value of services or facilities furnished by a 

governmental unit to the organization without charge. Don't 

include the value of services or facilities generally furnished 

to the public without charge. For example, include the fair 

rental value of office space furnished by a governmental unit 

to the organization without charge, but only if the 

governmental unit doesn't generally furnish similar office 

space to the public without charge. Report these amounts 

whether or not the organization includes these amounts as 

revenue on its financial statements or elsewhere on Form 990 

or 990-EZ.

Line 7a. Enter the amounts that are included on lines 1, 2, 

and 3 that the organization received from disqualified 

persons. See the definition of disqualified person in the 

Glossary of the Instructions for Form 990.

For amounts included on lines 1, 2, and 3 that were 

received from a disqualified person, the organization should 

keep for its records a list showing the name of, and total 

amounts received in each year from, each disqualified 

person. Enter the total of such amounts for each year on 

line 7a. See an example of this list above.

Don't file this list with the organization's Form 990 or 

990-EZ because it may be made available for public 

inspection.

Line 7b. For any gross receipts included on lines 2 and 3 

from related activities received from a person or from a 

bureau or similar agency of a governmental unit, other than 

from a disqualified person, that exceed the greater of 

$5,000 or 1% of the amount on line 13 for the applicable year, 

enter the excess on line 7b. The organization should keep for 

its records a list showing, for each year, the name of the 

person or government agency, the amount received during 

CAUTION

!

Line 7a. Example—List of amounts received from disqualified persons

Disqualified Person (a) 2019 (b) 2020 (c) 2021 (d) 2022 (e) 2023 (f) Total 

David Smith $7,000 $6,000 $2,000 $15,000 

Anne Parker $5,000 $7,000 $4,000 $16,000 

Total $7,000 $6,000 $5,000 $7,000 $6,000 $31,000 

-10- Instructions for Schedule A (Form 990) 2023
the applicable year, the larger of $5,000 or 1% of the amount 

on line 13 for the applicable year, and the excess, if any. See 

an example of this list above.

Don't file this list with the organization's Form 990 or 

990-EZ because it may be made available for public 

inspection.

Line 10a. Include the gross income from interest, dividends, 

payments received on securities loans (section 512(a)(5)), 

rents, royalties, and income from similar sources. Don't 

include on this line payments that result from activities of the 

organization that further its exempt purpose. Instead, report 

these amounts on line 2.

Line 10b. Enter the excess of the organization's unrelated 

business taxable income (UBTI) (as defined in section 

512) from trades or businesses that it acquired or 

commenced after June 30, 1975, over the amount of tax 

imposed on this income under section 511. Include 

membership fees to the extent they are payments to 

purchase admissions, merchandise, services, or the use of 

facilities in an unrelated business activity that is a trade or 

business that was acquired or commenced after June 30, 

1975.

When calculating UBTI for this purpose, an exempt 

organization with more than one unrelated trade or business 

may use either its UBTI calculated under section 512(a)(6) or 

its UBTI calculated in the aggregate.

Line 11. Enter the organization's net income from 

conducting unrelated business activities not included on 

line 10b, whether or not the activities are regularly conducted 

as a trade or business. Don't include net income from 

conducting trades or businesses acquired or commenced by 

the organization prior to July 1, 1975. See sections 512, 513, 

and 514, and the applicable regulations. Include membership 

fees to the extent they are payments to purchase admissions, 

merchandise, services, or the use of facilities in an activity 

that is an unrelated business not included on line 10b.

When calculating UBTI for this purpose, an exempt 

organization with more than one unrelated trade or business 

may use either its UBTI calculated under section 512(a)(6) or 

its UBTI calculated in the aggregate. If a net loss results, 

enter “0” on this line.

Line 12. Include all support as defined in section 509(d) that 

isn't included elsewhere in Part III. Explain in Part VI the 

nature and source of each amount reported. Don't include 

gain or loss from the sale of capital assets.

Line 14. An organization that checks this box should stop 

here and shouldn't complete the rest of Part III. It shouldn't 

make a public support computation on line 15 or 16 or an 

investment income computation on line 17 or 18, or check 

any of the boxes for line 19 or 20.

CAUTION

!

Example. An organization receives an exemption letter 

from the IRS that it is exempt from tax under section

501(c)(3) and qualifies as a public charity under section 

509(a)(2) effective on its date of incorporation. When the 

organization prepares Part III for its first 5 tax years, it should 

check the box on line 14 and shouldn't complete the rest of 

Part III. When the organization prepares Part III for its sixth 

tax year and subsequent years, it shouldn't check the box on 

line 14 and should complete the rest of Part III.

An organization in its first 5 years as a section 501(c)

(3) organization should make the public support and 

investment income computations on a copy of 

Schedule A (Form 990) that it keeps for itself. An organization 

should carefully monitor its public support on an ongoing 

basis to ensure that it will meet the public support tests in the 

sixth year and succeeding years.

Line 15. Round to the nearest hundredth decimal point in 

reporting the percentage of public support. For example, if 

the organization calculates its public support percentage as 

58.3456%, this percentage would be rounded to 58.35% 

when reported on line 15.

Line 16. For 2023, enter the public support percentage from 

2022 Schedule A (Form 990), Part III, line 15. Round to the 

nearest hundredth decimal point in reporting the percentage 

of public support.

Line 17. Round to the nearest whole percentage.

Line 18. For 2023, enter the investment income percentage 

from the 2022 Schedule A (Form 990), Part III, line 17. Round 

to the nearest whole percentage.

Line 19a. If the organization didn't check the box on line 14, 

line 15 is more than 331/3%, and line 17 isn't more than 

331/3%, check the box on this line and don't complete 

the rest of this schedule. The organization qualifies as a 

publicly supported organization for 2023 and 2024.

Line 19b. If the organization didn't check the box on line 14 

or 19a, line 16 is more than 331/3%, and line 18 isn't more 

than 331/3%, check the box on this line and don't 

complete the rest of this schedule. The organization 

qualifies as a publicly supported organization for 2023.

Line 20. If the organization didn't check the box on line 14, 

19a, or 19b, it doesn't qualify as a publicly supported 

organization under section 509(a)(2) for the 2023 tax year 

and should check the box on this line. If the organization 

doesn't qualify as a public charity under any of the boxes on 

Schedule A (Form 990), Part I, lines 1 through 12, it is a 

private foundation for filing purposes as of the beginning of 

the tax year and shouldn't file Form 990, Form 990-EZ, or 

Schedule A (Form 990) for the 2023 tax year. Instead, the 

organization should file Form 990-PF, and check Initial return 

of a former public charity on Form 990-PF, at the top of 

page 1.

TIP

Line 7b. Example—List of amounts received from other than disqualified persons

Year 2023

(a) Name (b) Amount received in 

2023

(c) 1% of amount on 

line 13 in 2023 

(d) Enter the larger of 

column (c) or $5,000 

(e) 2023 excess 

(column (b) minus 

column (d)) 

Word Processing, Inc. $25,000 $2,000 $5,000 $20,000 

Enter on Schedule A (Form 990), column (e), line 7b ................................... $20,000 

Instructions for Schedule A (Form 990) 2023 -11-
If Form 990 or 990-EZ is for the organization's sixth 

tax year as a section 501(c)(3) organization and it 

checked the box on line 20, it should figure the public 

support percentage and the investment income percentage 

on its Form 990 for its first 5 tax years. If its public support 

percentage for its first 5 tax years is more than 331/3% and 

the investment income percentage for its first 5 tax years isn't 

more than 331/3%, it will qualify as a public charity for its sixth 

tax year. If the organization qualifies in this manner, explain in 

Part VI.

If the organization doesn't qualify as a publicly 

supported organization under section 509(a)(2), it 

can complete Part II to determine if the organization 

qualifies as a publicly supported organization under section 

170(b)(1)(A)(vi).

Part IV. Supporting Organizations

Complete the sections of Part IV that correspond below with 

the type of supporting organization indicated on line 12a, 

12b, 12c, or 12d of Part I.

• Type I: Sections A and B;

• Type II: Sections A and C;

• Type III Functionally Integrated: Sections A, D, and E; and

• Type III Non-Functionally Integrated: Sections A and D, 

and Part V.

Section A. All Supporting Organizations

Line 1. The organization's articles of incorporation or trust 

instrument must designate the publicly supported 

organization(s) on whose behalf the supporting organization 

is operated. The articles of a Type I or Type II supporting 

organization may designate its supported organization(s) 

either by class or purpose or by name. The articles of a Type 

III supporting organization must designate the supported 

organization(s) by name, unless a historic and continuing 

relationship exists between the organizations.

Check “Yes” only if the organization supports no 

organization other than those listed by name in its governing 

instrument. If the organization supports any organization not 

specifically listed, check “No” and describe in Part VI how the 

supported organizations are designated. If designated by 

class or purpose, describe the class or purpose. If the 

organization and its supported organization(s) have a historic 

and continuing relationship, explain that relationship. If 

support of one or more organizations is subject to certain 

future contingencies, explain those contingencies, and 

explain what organizations will be supported or benefited if 

those contingencies occur.

Line 2. If the organization supported any domestic or foreign 

organization (other than an organization described in section 

501(c)(4), (5), or (6)) that didn't have an IRS determination of 

status under section 509(a)(1) or (2), check “Yes” and explain 

in Part VI how the organization determined that the supported 

organization was described in section 509(a)(1) or (2) and 

why the supported organization doesn't have such an IRS 

determination (for example, because it has applied for but not 

yet received such a determination, or it isn't required to obtain 

recognition of its public charity status because it is a church, 

a state university, or described in section 4948(b)).

Line 3a. A supporting organization may support an 

organization described in section 501(c)(4), (5), or (6), if the 

supported organization satisfies the public support tests 

applicable to a section 509(a)(2) organization. See 

TIP TIP

Regulations section 1.509(a)-4(k) and the instructions for 

Part III. If the organization supports a section 501(c)(4), (5),

or (6) organization, check “Yes” for line 3a.

Line 3b. If the organization confirmed that the supported 

organization qualified under section 501(c)(4), (5), or (6) and 

met the section 509(a)(2) public support test for its most 

recent tax year, check “Yes” and describe in Part VI how the 

organization made this determination. For example, the 

organization may ask its section 501(c)(4), (5), or (6) 

supported organization to furnish a copy of its IRS 

determination letter and to complete annually a pro forma 

Schedule A (Form 990), Part III, and keep the letter and 

support calculation in the supporting organization’s files.

If the supporting organization doesn't annually confirm that 

its supported organization satisfies the section 509(a)(2) 

public support test, it must explain in Part VI how it knows that 

the supported organization would’ve been described in 

section 509(a)(2) if it were described in section 501(c)(3) 

during the tax year.

Line 3c. Support given to a supported section 501(c)(4), (5), 

or (6) organization must be used solely for charitable 

purposes. If the supporting organization has put into place 

measures to ensure that such support is used solely for 

charitable purposes, check “Yes” and describe those 

measures in Part VI. If not, check “No” and describe in Part VI 

how the supporting organization ensured during the tax year 

that its assets were used solely for charitable purposes.

Line 4a. A supporting organization can't qualify for Type III 

status in the tax year if any supported organization wasn't 

organized in the United States.

Lines 4b and 4c. A supporting organization must exercise 

control and discretion over funds granted to an organization 

that isn't exempt under section 501(c)(3). See Rev. Rul. 

68-489, 1968-2 C.B. 210. Also, a domestic charity must 

generally exercise control and discretion over funds granted 

to a foreign organization. See Rev. Rul. 63-252, 1963-2 C.B. 

101, and Rev. Rul. 66-79, 1966-1 C.B. 48.

Explain in Part VI how the organization retained such 

control and discretion despite being controlled or supervised 

by or in connection with such foreign supported 

organization(s). Also, explain what controls the organization 

used to ensure that all support to the foreign supported 

organization(s) was used exclusively for charitable, 

educational, etc., purposes described in section 170(c)(2)(B) 

if the foreign supported organization doesn't have an IRS 

determination under sections 501(c)(3) and 509(a)(1) or (2).

Line 5. Supporting organizations may add, substitute, or 

remove supported organizations only in certain limited 

situations. See Regulations section 1.509(a)-4(d). Generally, 

a Type I or Type II supporting organization may add or 

substitute particular supported organizations within the class 

or classes designated in its articles, but may not add or 

substitute supported organizations outside of the designated 

class(es). A Type III supporting organization, which must 

specify its supported organizations by name, may only 

substitute supported organizations if such substitution is 

conditioned upon the occurrence of an event that is beyond 

the control of the supporting organization (such as a 

supported organization’s lapse into private foundation 

status).

If the organization has added, substituted, or removed any 

supported organization during the tax year, check “Yes” and 

provide detail in Part VI, including (i) the names and EINs of 

-12- Instructions for Schedule A (Form 990) 2023
the organizations added, substituted, or removed; (ii) the 

reasons for each addition, substitution, or removal; (iii) the 

authority under the organization’s organizing document for 

each addition, substitution, or removal; and (iv) an 

explanation of how the action was accomplished (such as by 

amendment to the organizing document substituting a new 

supported organization).

Line 6. A supporting organization must engage solely in 

activities that support or benefit its supported organization(s). 

In addition to making grants and providing services and 

facilities directly to its supported organization(s), a supporting 

organization may also generally make grants or provide 

services or facilities to (1) individual members of the 

charitable class benefited by its supported organization(s), or 

(2) other supporting organizations that also support or benefit 

its supported organization(s). See Regulations section 

1.509(a)-4(e). If the organization made any grants or 

provided any benefits to any other organization or individual, 

check “Yes” and provide detail in Part VI.

Lines 7 and 8. Under section 4958(c)(3), any grant, loan, 

compensation, or other similar payment provided by a 

supporting organization to a substantial contributor (defined 

in section 4958(c)(3)(C)), to a family member (defined in 

section 4958(f)(4)), and to a 35% controlled entity of such 

persons, is considered a per se excess benefit in its entirety, 

regardless of the fairness or reasonableness of the payment, 

and is subject to tax under section 4958(a). The same is true 

of any loan by a supporting organization to a disqualified 

person under section 4958 (other than loans to certain 

exempt organizations). If the organization made any such 

payment or loan during the tax year, check “Yes” and report 

the transaction on Schedule L (Form 990), Transactions With 

Interested Persons, Part I. For more information on excess 

benefit transactions generally, see the Instructions for 

Schedule L (Form 990).

Line 9. A supporting organization may not be controlled by 

disqualified persons, as defined in section 4946. Section 

509(a)(1) or (2) organizations, and foundation managers who 

are disqualified persons only as a result of being foundation 

managers, aren't treated as disqualified persons for this 

purpose. Impermissible control may be direct or indirect. If a 

disqualified person holds any of the interests described on 

line 9b or 9c, or derives personal benefit from any such 

assets, provide detail in Part VI.

Line 10. Under section 4943(f), a Type II supporting 

organization that accepts a contribution from a person who 

controls the governing body of a supported organization (or 

from a family member of such person, or from a 35% 

controlled entity of such person) is subject to the excess 

business holdings tax under section 4943. All Type III 

non-functionally integrated supporting organizations are also 

generally subject to the tax. For more information about 

excess business holdings, see the Instructions for Form 

4720, Return of Certain Excise Taxes Under Chapters 41 and 

42 of the Internal Revenue Code.

Line 11. Section 509(f)(2) prohibits Type I and Type III 

supporting organizations from accepting a gift or contribution 

from certain persons associated with a supported 

organization of such supporting organization. Specifically, if a 

Type I or Type III supporting organization accepts a 

contribution after August 16, 2006, from a person who 

controls the governing body of a supported organization (or 

from a family member of such person, or from a 35% 

controlled entity of such person), then the supporting 

organization loses its status as a supporting organization. 

Such supporting organization must file Form 990-PF unless it 

qualifies as a public charity under section 509(a)(1) or (2).

Section B. Type I Supporting Organizations

Line 1. A Type I supporting organization must be operated, 

supervised, or controlled by one or more of its supported 

organizations (the “controlling supported organizations”). 

This means that the controlling supported organizations must 

have a substantial degree of direction over the policies, 

programs, and activities of the supporting organization, and 

the supporting organization in turn must be responsive to the 

needs or demands of the controlling supported 

organizations, and must constitute an integral part of, or 

maintain a significant involvement in, the operations of the 

controlling supported organizations. This relationship is most 

clearly established when one or more supported 

organizations (through their officers, directors, trustees, or 

membership) have the unconditional power to remove and 

replace at least a majority of the supporting organization’s 

directors or trustees at any time. The relationship is also 

commonly established when one or more supported 

organizations have the power to appoint or elect at least a 

majority of the supporting organization’s directors or trustees 

at regular intervals. However, there may be other ways to 

establish this relationship. If the organization relies on other 

ways to establish the relationship, check “No” and describe in 

Part VI how the necessary relationship is established.

Line 2. The supporting organization may benefit 

organizations that don't participate in the control relationship 

described on line 1, but only if such activity carries out the 

purposes of the controlling supported organizations.

Section C. Type II Supporting Organizations

Line 1. A Type II supporting organization must be 

supervised or controlled in connection with its supported 

organization(s). This means that there must be common 

supervision or control by the persons supervising or 

controlling both the supporting organization and the 

supported organization(s) to ensure that the supporting 

organization will be responsive to the needs and 

requirements of the supported organization(s). This 

relationship is most clearly established when the same 

persons serve as all or a majority of the directors or trustees 

of all of the organizations involved. However, there may be 

other ways to establish this relationship. If the organization 

relies on other than overlap of at least a majority of directors 

or trustees of all organizations involved, check “No” and 

describe in Part VI how the necessary relationship is 

established.

Section D. All Type III Supporting Organizations

Line 1. A Type III supporting organization must supply 

annually a written notice, addressed to a principal officer of 

each supported organization, which includes the following.

1. A description of the type and amount of all support the 

supporting organization provided to the supported 

organization during the supporting organization’s tax year 

preceding the tax year in which the notice is provided.

2. A copy of the supporting organization’s most recently 

filed Form 990 (the supporting organization may redact the 

names and addresses of contributors).

3. A copy of the supporting organization’s updated 

governing documents (including articles of organization, 

Instructions for Schedule A (Form 990) 2023 -13-
bylaws, and any amendments), to the extent not previously 

provided.

See Regulations section 1.509(a)-4(i)(2). The notice must be 

submitted by the last day of the fifth month of the supporting 

organization's tax year being reported (May 31 for 

calendar-year filers). An organization that doesn't timely 

submit the required information in the required manner 

doesn't qualify as a Type III supporting organization for the 

tax year in which it fails to timely submit.

State whether during the tax year being reported the 

organization provided a timely notice with the required 

information in the required manner.

Lines 2 and 3. A Type III supporting organization must be 

responsive to the needs or demands of a supported 

organization. An organization meets this responsiveness test 

with regard to a particular supported organization if:

1. The supported organization has an adequate 

relationship with the supporting organization because:

a. The supported organization regularly appoints or 

elects (whether or not during the tax year) at least one 

officer, director, or trustee of the supporting organization;

b. At least one member of the governing body of the 

supported organization also serves as an officer, director, 

or trustee of the supporting organization; or

c. The officers, directors, or trustees of the supporting 

organization and of the supported organization maintain a 

close and continuous working relationship; and

2. Because of this relationship, the supported 

organization has a significant voice in the supporting 

organization’s investment policies, timing of grants, manner 

of making grants, selection of grant recipients, and other use 

of income or assets (the “significant voice” test).

In the case of a supporting organization that supported a 

supported organization before November 20, 1970, 

additional facts and circumstances such as a historic and 

continuing relationship between the organizations may also 

be taken into account in considering the responsiveness test.

If the organization has an adequate relationship with at 

least one supported organization only by means of a “close 

and continuous working relationship” or a “historic and 

continuing relationship,” then in Part VI explain the 

relationship and how it has been maintained. Also, all Type III 

supporting organizations that claim to meet the significant 

voice test must describe in Part VI the voice or role of the 

supported organization(s) in directing the supporting 

organization’s use of its income or assets.

Section E. Type III Functionally Integrated 

Supporting Organizations

Line 1. A Type III supporting organization must constitute an 

integral part of one or more of its supported organizations by 

maintaining significant involvement in its operations and 

providing support on which the supported organization is 

dependent. To satisfy this requirement as a Type III 

functionally integrated supporting organization, an 

organization may (a) pass an Activities Test (see the 

instructions for Line 2, later), (b) be the parent of its 

supported organizations (see the instructions for Line 3, 

later), or (c) support one or more governmental entities (see 

Support of governmental entity, later). If the organization 

can't satisfy any of these tests, it may still qualify as a Type III 

non-functionally integrated supporting organization (see Part 

V, later).

Support of governmental entity. A Type III supporting 

organization meets the integral part test for a functionally 

integrated supporting organization if it (1) supports at least 

one supported organization that is a governmental entity to 

which the supporting organization is responsive (as 

discussed in the instructions for Section D, Lines 2 and 3, 

earlier), and (2) engages in activities for or on behalf of such 

governmental supported organization that performs the 

functions or carries out the purposes of such governmental 

supported organization and that, but for the involvement of 

the supporting organization, would normally be engaged in 

by the governmental supported organization itself. See 

Notice 2014-4. A Type III supporting organization that claims 

to meet the integral part test for a functionally integrated 

supporting organization by supporting a governmental entity 

must describe in Part VI how it met these requirements for the 

tax year.

Line 2. Activities Test. To meet the activities test of a Type 

III functionally integrated supporting organization, 

substantially all of the supporting organization’s activities 

must (1) directly further the exempt purposes of the 

supported organization(s) to which the supporting 

organization was responsive, and (2) be activities that such 

supported organization(s) would normally be engaged in but 

for the supporting organization’s involvement.

Direct furtherance. Substantially all of the supporting 

organization’s activities must be “direct furtherance” 

activities. Direct furtherance activities are conducted by the 

supporting organization itself, rather than by a supported 

organization. Holding title to exempt-use assets and 

managing them are direct furtherance activities. Fundraising, 

investing and managing non-exempt-use assets, 

grant-making to organizations, and grant-making to 

individuals (unless it meets the requirements of Regulations 

section 1.509(a)-4(i)(4)(ii)(D)) aren't direct furtherance 

activities.

But for. In addition, the direct furtherance activities must 

be activities in which, but for the supporting organization’s 

involvement, the supported organization would normally be 

involved.

Examples include holding and managing facilities used by 

a church for its religious purposes, operating a food pantry for 

a group of churches that normally would operate food 

pantries themselves, and maintaining local parks for a 

community foundation that otherwise would maintain those 

parks. See Regulations section 1.509(a)-4(i)(4)(v) for more 

detailed examples.

Line 3. Parent of Supported Organizations. To qualify as 

the parent of all the supported organizations, a supporting 

organization must (1) have the power to appoint or elect, 

directly or indirectly, a majority of the officers, directors, or 

trustees of every supported organization; and (2) exercise a 

substantial degree of direction over the policies, programs, 

and activities of every supported organization.

Part V. Type III Non-Functionally 

Integrated 509(a)(3) Supporting 

Organizations

A Type III supporting organization (other than a Type III 

functionally integrated supporting organization) must 

generally satisfy a distribution requirement described in 

Regulations section 1.509(a)-4(i)(5)(ii) along with an 

attentiveness requirement described in Regulations section 

1.509(a)-4(i)(5)(iii) to meet the integral part test for a Type III 

-14- Instructions for Schedule A (Form 990) 2023
relationship. To satisfy the distribution requirement, the 

organization must make a minimum amount (distributable 

amount) of distributions to or for the use of one or more 

supported organizations. Carryovers of excess distributions 

from certain prior years may be used for this purpose.

Sections A through E of Part V show whether the 

organization has satisfied its distribution and attentiveness 

requirements for its tax year. Sections A and B determine the 

organization’s adjusted net income and minimum asset 

amount. These amounts are used in determining the 

distributable amount in Section C. Section D determines the 

organization’s distributions that count toward the distributable 

amount and determines whether the attentiveness 

requirement is met. Section E determines whether the 

distributable amount is satisfied through current distributions 

and prior-year carryovers, and determines carryovers to 

future years.

A trust is excepted from the general distribution and 

attentiveness requirements (and need not complete Sections 

A through E) if on November 20, 1970, it met and continues 

to meet the requirements set forth in Regulations section 

1.509(a)-4(i)(9). A trust that claims this status by checking 

the box on line 1 at the beginning of Part V must explain in 

Part VI how it meets each of the requirements. A trust that 

has obtained a ruling from the IRS on this issue must so 

indicate in Part VI.

Section A. Adjusted Net Income

The principles of section 4942(f) and Regulations section 

53.4942(a)-2(d) apply in determining adjusted net income. 

See Regulations section 1.509(a)-4(i)(5)(ii)(B).

Prior and current year columns. The organization’s 

adjusted net income for the prior tax year is used in 

determining the organization’s distributable amount for the 

current tax year. The form also allows for reporting the 

organization’s adjusted net income for the current tax year for 

use in next year’s calculations; this reporting is optional but 

may be helpful if the organization anticipates being required 

to complete Part V next year.

Definition. Adjusted net income is gross income for the tax 

year less deductions allowable to a corporation subject to tax 

under section 11, with certain modifications discussed in the 

line instructions later. In computing gross income and 

deductions, the principles of the income tax provisions of the 

Code apply (except to the extent inconsistent with section 

4942 or the underlying regulations), but exclusions, 

deductions, and credits aren't allowed unless expressly 

provided for under section 4942 or the underlying 

regulations. See Regulations section 53.4942(a)-2(d)(1).

Line 1. Report the organization’s net short-term capital gain, 

if any. Long-term capital gains and losses from the sale or 

disposition of property aren't taken into account in 

determining adjusted net income (unless reportable on line 2 

as recoveries of prior-year distributions). Net short-term 

capital loss can't be carried back or forward to other tax 

years. Amounts treated as long-term capital gains include 

capital gain dividends from a regulated investment company 

and net section 1231 gains (but net section 1231 losses are 

treated as ordinary losses and thus taken into account). If the 

fair market value of property distributed for charitable 

purposes exceeds adjusted basis, the excess isn't deemed 

includible in income.

Adjusted basis. The adjusted basis for purposes of 

determining gain from the sale or other disposition of 

property is the greater of:

1. The fair market value of such property on August 17, 

2006, plus or minus all adjustments thereafter and before the 

date of disposition under sections 1011–1023, if the property 

was held continuously from August 17, 2006, to the date of 

disposition.

2. The adjusted basis under sections 1011–1023, without 

regard to section 362(c). If assets acquired before August 17, 

2006, were subject to depreciation or depletion, to determine 

the adjustments to basis between the date of acquisition and 

August 17, 2006, straight-line depreciation or cost depletion 

must be taken into account. Any other adjustments that 

would’ve been made during such period (such as a change in 

useful life based upon additional data or a change in facts) 

must also be taken into account.

The adjusted basis for purposes of determining loss is only 

the amount described in item 2 above.

Line 2. Recoveries of prior-year distributions include the 

following.

• Repayments received of amounts which were taken into 

account as a distribution counting toward the distribution 

requirement in a prior tax year.

• Proceeds from the sale or disposition of property to the 

extent that acquisition of such property was taken into 

account as a distribution counting toward the distribution 

requirement in a prior tax year.

• An amount set aside and taken into account as a 

distribution counting toward the distribution requirement in a 

prior tax year to the extent it is determined that such amount 

isn't necessary for the purposes for which it was set aside.

Line 3. Report all other gross income. Gross income 

includes all amounts derived from, or in connection with, 

property held by the organization (except as specified 

otherwise in the instructions for Line 1). Include income from 

any related or unrelated trade or business. Include income 

from tax-exempt bonds. Don't include the following.

• Gifts, grants, or contributions received.

• Long-term capital gains or losses or net short-term capital 

losses.

• Income received from an estate, unless the estate is 

considered terminated due to a prolonged period of 

administration.

• Distributions from a trust created and funded by another 

person.

• Certain amounts received by an organization in the 

redemption of stock in a corporate disqualified person in 

order to avoid excess business holdings, which are treated as 

not essentially equivalent to a dividend under section 302(b)

(1) (and thus as amounts received in exchange for the stock, 

giving rise to long-term capital gain or loss) if the conditions 

of Regulations section 53.4942(a)-2(d)(2)(iv) are met.

Line 5. The deduction for depreciation under section 167 is 

allowed, but only on the basis of the straight-line method. The 

deduction for depletion under section 611 is allowed, but 

without regard to section 613 (percentage depletion).

Lines 6 and 7. No deduction is allowed except ordinary and 

necessary expenses paid or incurred for the production or 

collection of gross income, or for the management, 

conservation, or maintenance of property held for the 

production of income. Such expenses may include operating 

expenses such as compensation of officers and employees, 

Instructions for Schedule A (Form 990) 2023 -15-
interest, rent, and taxes. Where only a portion of property 

produces income (or is held for the production of income) 

and the remainder is used for charitable purposes, the 

expenses must be apportioned between exempt and 

non-exempt use on a reasonable basis.

Don't deduct the following.

• Net losses from a related business or other charitable 

activity that produces gross income (no deduction in excess 

of the income from such activity).

• Charitable contributions under section 170 or 642.

• Net operating loss carrybacks and carryovers under 

section 172.

• Dividends under section 241 and the sections following it 

(the dividends-received deductions for corporations).

• Net capital losses (short-term or long-term).

Expenses and interest relating to tax-exempt income under 

section 265 are deductible.

Section B. Minimum Asset Amount

The rules for determining the supporting organization’s 

minimum asset amount are set forth in Regulations sections 

1.509(a)-4(i)(5)(ii)(C) and 1.509(a)-4(i)(8), using valuation 

methods described in Regulations section 53.4942(a)-2(c).

Prior and current year columns. The organization’s 

minimum asset amount for the prior tax year is used in 

determining the organization’s distributable amount for the 

current tax year. The form also allows for reporting the 

organization’s minimum asset amount for the current tax year 

for use in next year’s calculations; this reporting is optional 

but may be helpful if the organization anticipates being 

required to complete Part V next year.

Definition. In figuring the minimum asset amount, include 

only assets of the supporting organization that aren't used or 

held for use by the supporting organization (or by a 

supported organization, if the supporting organization 

provides the asset free of charge or at nominal rent) to carry 

out the exempt purposes of the supported organization(s). 

Assets held for the production of income or for investment 

aren't considered to be used directly for charitable functions 

even though the income from the assets is used for charitable 

functions. It is a factual question whether an asset is held for 

the production of income or for investment rather than used 

or held for use directly by the supporting organization or a 

supported organization for charitable purposes. For example, 

an office building used to provide offices for employees 

engaged in managing endowment funds for the supporting 

organization or supported organization isn't considered an 

asset used for charitable purposes.

Dual-use property. When property is used for both 

charitable and other purposes, the property is considered 

used entirely for charitable purposes if 95% or more of its 

total use is for that purpose. If less than 95% of its total use is 

for charitable purposes, a reasonable allocation must be 

made between charitable and noncharitable use.

Excluded property. Certain assets (in addition to 

exempt-use assets) are excluded entirely from the 

computation of the minimum asset amount. These include 

charitable pledges and interests in an estate or trust (created 

and funded by another person) prior to distribution to the 

supporting organization.

Line 1a. Report on line 1a the average monthly fair market 

value of securities (such as common and preferred stock, 

bonds, and mutual fund shares) for which market quotations 

are readily available. A supporting organization may use any 

reasonable method to make this determination if consistently 

used. For example, a value for a particular month might be 

determined by the closing price on the first or last trading day 

of the month or an average of the closing prices on the first 

and last trading days of the month. Market quotations are 

considered readily available if a security is any of the 

following.

• Listed on the New York or American Stock Exchange or 

any city or regional exchange in which quotations appear on 

a daily basis, including foreign securities listed on a 

recognized foreign national or regional exchange;

• Regularly traded in the national or regional 

over-the-counter market for which published quotations are 

available; or

• Locally traded, for which quotations can be readily 

obtained from established brokerage firms.

If securities are held in trust for, or on behalf of, a supporting 

organization by a bank or other financial institution that 

values those securities periodically using a computer pricing 

system, the organization may use that system to determine 

the value of the securities. The system must be acceptable to 

the IRS for federal estate tax purposes.

Line 1b. Figure cash balances on a monthly basis by 

averaging the amount of cash on hand on the first and last 

days of each month. Include all cash balances and amounts, 

even if they may be used for charitable purposes (see the 

instructions for Line 4, later) or set aside and taken as a 

distribution (see the instructions for Section D, Line 5, later).

Line 1c. The fair market value of assets other than securities 

for which market quotations are readily available is 

determined annually except as described later. The valuation 

may be made by supporting organization employees or by 

any other person even if that person is a disqualified person. 

If the IRS accepts the valuation, it is valid only for the tax year 

for which it is made. A new valuation is required for the next 

tax year.

Valuation date. An asset required to be valued annually 

may be valued as of any day in the supporting organization's 

tax year, provided the organization values the asset as of that 

date in all tax years. However, a valuation of real estate 

determined on a 5-year basis by a certified, independent 

appraisal (discussed later) may be made as of any day in the 

first tax year of the organization to which the valuation 

applies.

Proration of value of assets held for part of year or in a 

short tax year. The value of an asset held less than a full 

tax year is prorated by multiplying the value of the asset by a 

fraction, of which the numerator is the number of days the 

organization held the asset during its tax year, and the 

denominator is 365 (366 if the tax year includes February 

29). If the supporting organization has a short tax year, the 

value of all assets is accordingly prorated.

5-year valuation for real estate. A written, certified, and 

independent appraisal of the fair market value of any real 

estate, including any improvements, may be determined on a 

5-year basis by a qualified person. The qualified person may 

not be a disqualified person with respect to the supporting 

organization or an employee of the supporting organization.

Commonly accepted valuation methods must be used in 

making the real estate appraisal. A valuation based on 

acceptable methods of valuing property for federal estate tax 

purposes will be considered acceptable.

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The real estate appraisal must include a closing statement 

that, in the appraiser's opinion, the appraised assets were 

valued according to valuation principles regularly employed 

in making appraisals of such property, using all reasonable 

valuation methods. The supporting organization must keep a 

copy of the independent appraisal for its records. If a 

valuation is reasonable, the organization may use it for the 

tax year for which the valuation is made and for each of the 4 

following tax years.

Any valuation of real estate by a certified independent 

appraisal may be replaced during the 5-year period by a 

subsequent 5-year certified independent appraisal or by an 

annual valuation, as described earlier. The most recent 

valuation should be used to figure the organization's 

minimum asset amount.

If the valuation is made according to the above rules, the 

IRS will continue to accept it during the 5-year period for 

which it applies even if the actual fair market value of the real 

estate changes during the period.

Line 1e. If the fair market value of any securities, real estate 

holdings, or other assets reported on lines 1a and 1c reflects 

a blockage discount, marketability discount, or other 

reduction from full fair market value because of the size of the 

asset holding or any other factor, enter on line 1e the 

aggregate amount of the discounts claimed. Provide an 

explanation in Part VI that includes the following information 

for each asset or group of assets involved.

1. A description of the asset or asset group (for example, 

20,000 shares of XYZ, Inc., common stock);

2. For securities, the percentage of the total issued and 

outstanding securities of the same class that is represented 

by the organization's holding;

3. The fair market value of the asset or asset group 

before any claimed blockage discount or other reduction;

4. The amount of the discount claimed; and

5. An explanation of the reason for the discount.

In the case of securities, there are certain limitations on 

the size of the reduction in value that can be claimed. The 

organization may reduce the fair market value of securities 

only to the extent that it can establish that the securities could 

only be liquidated in a reasonable period of time at a price 

less than the fair market value because:

• The securities are such a large block that liquidation would 

depress the market,

• The securities are in a closely held corporation, or

• The sale would result in a forced or distress sale.

Any reduction in value of securities may not exceed 10% of 

the fair market value (determined without regard to any 

reduction in value).

Line 2. Enter the total acquisition indebtedness that applies 

to assets included on line 1 (prorated in the case of assets 

held for a portion of the year or in a short tax year). For details 

on acquisition indebtedness, see section 514(c)(1).

Line 4. Supporting organizations may exclude from the 

minimum asset amount the reasonable cash balances 

necessary to cover current administrative expenses and 

other normal and current disbursements directly connected 

with the charitable, educational, or other similar activities. 

The amount of cash that may be excluded is generally 1.5% 

of the fair market value of all assets (minus any acquisition 

indebtedness). However, if under the facts and 

circumstances an amount larger than the deemed amount is 

necessary to pay expenses and disbursements, then the 

organization may enter the larger amount instead (prorated in 

the case of a short tax year). If the organization uses a larger 

amount, explain why in Part VI.

Line 7. Enter the amount of recoveries (if any) reportable on 

Section A, line 2.

Section C. Distributable Amount

The organization’s distributable amount for the current tax 

year is ordinarily the greater of:

1. 85% of its adjusted net income for the prior tax year or

2. Its minimum asset amount for the prior tax year,

less income taxes imposed on the organization during the 

prior tax year. See Regulations section 1.509(a)-4(i)(5)(ii)(B).

First tax year. The distributable amount for the first tax year 

that an organization is treated as a non-functionally 

integrated Type III supporting organization is zero rather than 

the amount as ordinarily determined. Such an organization 

should check the box on line 7. For purposes of determining 

whether the organization has an excess of distributions in its 

tax year that can be carried over to future years, the 

distributable amount as ordinarily determined applies to 

every non-functionally integrated Type III supporting 

organization (including an organization that checked the box 

on line 7 for the current year). The distributable amount as 

ordinarily determined is reported in Sections C and E.

Emergency temporary reduction. In cases of disaster or 

emergency, the IRS may provide for a temporary reduction in 

the distributable amount by publication in the Internal 

Revenue Bulletin. In these cases, the reduced amount should 

be reported on line 6 and the reduction noted in Part VI.

Section D. Distributions

Section D sets forth the supporting organization’s 

distributions that count toward its distribution requirement, 

and determines whether the attentiveness requirement is 

met. The amount of a distribution made to a supported 

organization is the amount of cash or fair market value of 

property on the date of distribution. The organization must 

use the cash method of accounting for this purpose. See 

Regulations section 1.509(a)-4(i)(6).

Line 1. Report amounts paid to supported organizations to 

accomplish their exempt purposes. Distributions furthering 

the “exempt” purposes of supported organizations not 

described in section 501(c)(3) refer solely to distributions for 

section 501(c)(3) purposes.

Line 2. Report amounts paid to perform any activity that 

directly furthers exempt purposes of supported organizations 

and that would otherwise normally be engaged in by the 

supported organizations, but only to the extent that expenses 

from the activity exceed income from the activity. See the 

Schedule A (Form 990), Part IV, Section E, Line 2, 

instructions on “direct furtherance” activities.

Line 3. Report reasonable and necessary administrative 

expenses paid to accomplish exempt purposes of supported 

organizations. Don't include expenses incurred in the 

production of investment income.

Line 4. Report amounts paid to acquire exempt-use assets. 

Such assets must be used (or held for use) to carry out the 

exempt purposes of the supported organizations. The assets 

may be used or held by either the supporting organization or 

one or more supported organizations; if the latter, the 

Instructions for Schedule A (Form 990) 2023 -17-
supporting organization must make the asset available to the 

supported organization(s) free of charge or for nominal rent. 

See Regulations section 53.4942(a)-2(c)(3) for further 

discussion of exempt-use assets.

Line 5. Report qualified amounts set aside for a specific 

project that accomplishes the exempt purposes of a 

supported organization to which the supporting organization 

is responsive. A qualified set-aside counts toward the 

distribution requirement in the tax year set aside but not 

again when paid.

Approval required. For each set-aside, a supporting 

organization must obtain the written approval of both the 

pertinent supported organization(s) and the IRS. The 

supporting organization must apply to the IRS for approval 

(using Form 8940) before the end of its tax year in which the 

amount is set aside. Explain in Part VI whether the 

organization has requested and obtained the necessary 

approvals for the set-aside. See Regulations section 

1.509(a)-4(i)(6)(v) for more information.

Line 6. Report any other distributions not described above 

that the organization claims are for the use of its supported 

organizations, and describe such distributions in detail in Part 

VI.

Lines 8–10. Report on line 8 the amount of distributions 

reported on line 1 to supported organizations that met the 

attentiveness and responsiveness tests, discussed later, and 

provide in Part VI the supplemental information, discussed 

later.

A Type III non-functionally integrated supporting 

organization must distribute at least one-third of its 

distributable amount each tax year to one or more supported 

organizations that are “attentive” to its operations and to 

which the supporting organization is “responsive” (as 

described later); thus, the line 10 amount must be at least 

0.333. Carryovers of excess distributions from prior years 

don't count toward the attentiveness requirement.

If the line 10 amount is less than one-third (that is, the 

amount of distributions to supported organizations that met 

both the attentiveness test and responsiveness test is less 

than one-third of the distributable amount), then the 

organization doesn't qualify as a Type III non-functionally 

integrated supporting organization for the tax year. See 

Regulations sections 1.509(a)-4(i)(5)(i) and (iii). If the 

organization doesn't otherwise qualify as a public charity, 

then the organization is a private foundation and must file 

Form 990-PF for the tax year.

Attentiveness test. A supported organization is 

“attentive” to the operations of a supporting organization if, 

during the tax year, at least one of the following requirements 

is satisfied.

1. The supporting organization distributes to the 

supported organization at least 10% of the supported 

organization’s total support in its tax year ending before the 

beginning of the supporting organization’s tax year. For 

example, if the supporting organization and the supported 

organization both use a calendar year, and the supported 

organization has total support of $X in a year, then the 

supporting organization’s support in the following year must 

be at least 10% of $X. Where the supporting organization 

supports a particular department or school of a university, 

hospital, or church, the department’s or school’s total support 

is considered instead.

2. The amount of support received from the supporting 

organization is necessary to avoid the interruption of a 

particular function or activity of the supported organization.

3. The amount of support received from the supporting 

organization is a sufficient part of the supported 

organization’s total support to ensure attentiveness, based on 

all pertinent facts, including the number of supported 

organizations, the length and nature of the relationship 

between the supporting organization and supported 

organization, and the purpose to which the funds are put. The 

attentiveness of a supported organization is normally 

influenced by the amounts received from the supporting 

organization, but evidence of actual attentiveness to the 

operations (including investments) of the supporting 

organization is of almost equal importance. Where the 

supporting organization supports a particular department or 

school of a university, hospital, or church, the department’s or 

school’s total support is considered instead of the supported 

organization’s total support.

Amounts received from a supporting organization that are 

held in a donor-advised fund of the supported organization 

are disregarded in determining attentiveness.

See the examples in Regulations section 1.509(a)-4(i)(5)

(iii)(D).

Responsiveness test. A supporting organization is 

“responsive” to the needs and demands of a supported 

organization if it meets the responsiveness test set forth in 

the instructions for Part IV, Section D, Lines 2 and 3, with 

respect to the supported organization.

Supplemental information required. In Part VI, identify 

each of the supported organizations listed in Part I, line 12g, 

column (i), that met both of the following conditions for the tax 

year.

1. The supporting organization was responsive to the 

supported organization, and

2. The supported organization was attentive to the 

supporting organization. With respect to each of the identified 

supported organizations, set forth the facts that show how 

both the attentiveness test and the responsiveness test were 

met by the supporting organization and the supported 

organization.

Section E. Distribution Allocations

Section E determines whether the distributable amount for 

the current tax year (and any underdistribution for reasonable 

cause in a prior year) is satisfied through current-year 

distributions and carryovers of prior-year excess distributions. 

Section E also determines carryovers of excess distributions 

to future years. Several lines in Section E aren't yet applicable 

during the phase-in period of the new regulations for Type III 

non-functionally integrated supporting organizations. Those 

lines are grayed out.

In applying distributions, there are three basic steps.

1. First, apply distributions to eliminate any 

underdistribution for reasonable cause in a prior tax year.

2. Second, apply distributions to satisfy the distributable 

amount for the current year.

3. Third, carry over to future years any remaining excess 

distributions.

Apply the oldest distributions first. Carryovers of excess 

distributions from prior years are always applied in full before 

current-year distributions (unlike the rules for qualifying 

-18- Instructions for Schedule A (Form 990) 2023
distributions by private foundations), and older carryovers are 

applied before newer carryovers. Excess distributions of a 

given year can't be carried over for more than 5 years.

Example 1. X is a Type III non-functionally integrated 

supporting organization that for its tax year including 

December 28, 2020, and through its following 2021 tax year 

meets the requirements of Regulations section 1.509(a)-4(i)

(3)(iii) as in effect prior to December 28, 2020. Under 

transition rules, X is deemed to meet its distribution 

requirement for 2021, but its distributable amount is 

calculated in the ordinary manner to determine its excess 

distributions. For 2021, X had a distributable amount, as 

ordinarily determined, of $80,000 and distributions of 

$100,000. Accordingly, X had excess distributions of 

$20,000. For 2022, X had a distributable amount of $95,000 

and distributions of $85,000. X first applied its 2021 excess 

distributions carryover of $20,000 to the 2022 distributable 

amount of $95,000. Then, X applied $75,000 of its 2022 

distributions of $85,000 to the remaining 2022 distributable 

amount. Accordingly, X has excess distributions of $10,000 

from 2022 (2022 distributions of $85,000 minus $75,000 

applied to the 2022 distributable amount), which it may carry 

over to 2023. For 2023, X has a distributable amount of 

$100,000 and distributions of $150,000. X applies the 

$10,000 excess distribution carryover from 2022 to the 2023 

distributable amount. Then, X applies $90,000 of its 2023 

distributions to the remaining 2023 distributable amount. 

Section E will show $0 carryovers for 2021 and 2022 

(because the excess carryovers for each of those years were 

previously applied). In addition, Section E will show excess 

distributions of $60,000 in 2023 (2023 distributions of 

$150,000 minus $90,000 applied to the 2023 distributable 

amount), which it may carry over in the next 5 tax years until 

applied.

Example 2. Y is a Type III supporting organization that for 

its tax year including December 28, 2020, meets the 

requirements of Regulations section 1.509(a)-4(i)(3)(iii) as in 

effect prior to such date, but doesn't meet such requirements 

in its following 2021 tax year (because of underdistributions 

for which the prior regulation didn't expressly provide a 

reasonable cause exception). Therefore, Y didn't benefit from 

the transition rule for its 2021 tax year. Y's distributable 

amount was $120,000 for 2021. Y made distributions of that 

amount and had no excess distributions to carry over to 

2022. Y calculated that its distributable amount was 

$150,000 for 2022 and made distributions of exactly that 

amount in 2022. Early in its 2023 tax year, Y discovers that its 

distributable amount for 2022 actually was $200,000. Within 

180 days, Y makes a $110,000 distribution ($50,000 to cover 

the underdistribution for 2022 and $60,000 as part of its 2023 

distributions). Later in the 2023 tax year, Y makes additional 

distributions totaling $200,000. Y’s distributable amount in 

the 2023 tax year is $190,000. In its 2023 Form 990, Y claims 

reasonable cause for the 2022 underdistribution due to a 

clerical error. Under these circumstances, Y first applies 

$50,000 of its 2023 distributions of $310,000 to the 2022 

underdistribution of $50,000 ($200,000 minus $150,000), 

then applies $190,000 of its remaining 2023 distributions of 

$260,000 ($310,000 minus $50,000) to satisfy its 2023 

distributable amount. Y’s remaining $70,000 of distributions 

in 2023 ($310,000, minus $50,000 allocated to 2022, and 

minus $190,000 allocable to 2023) are excess distributions 

that may be carried over to future years.

Line 1. Report the distributable amount for 2023 from 

Section C, line 6.

Line 2. An organization that is treated as a Type III 

non-functionally integrated supporting organization for the 

first time in its 2022 tax year will have a distributable amount 

of zero during the 2022 tax year.

If the organization had any underdistributions for a prior 

tax year (2021 or 2022), then it didn't qualify as a Type III 

non-functionally integrated supporting organization in that tax 

year and subsequent years (and would be classified as a 

private foundation unless it met the requirements of another 

public charity status) unless it met the requirements of the 

reasonable cause exception or the judicial proceeding 

exception discussed in the instructions for Lines 5 and 6, 

later. If the organization met either of these exceptions, 

explain in detail in Part VI how the organization met the 

requirements for the exception.

Line 3. On lines 3d and 3e, enter the amounts reported on 

lines 8d and 8e, respectively, from the organization's return 

for the 2022 tax year. The sum of the amounts on lines 3d 

and 3e is also reported on line 3f. The amount reported on 

line 3f is then applied in the following priority.

1. First to any prior-year underdistributions on line 3g,

2. Second (if any remaining amount) to the current-year 

distributable amount on line 3h, and

3. Third (if any remaining amount) on line 3j for carryover 

to future years.

Excess distributions can't be carried over for more than 5 tax 

years immediately following the tax year in which the excess 

amount is created, and thus are forfeited if not used in the 

fifth year of carryover. Such amounts are set forth on line 3i 

(not applicable to the 2023 tax return).

Line 4. Apply the current-year distributions (from Section D, 

line 7) in the same order of priority as described in the 

instructions for Line 3 to any prior-year underdistributions 

(line 4a) and current-year distributable amount (line 4b) 

remaining after applying carryovers on line 3. Any remaining 

distributions are reported on line 4c for carryover to future 

years.

Lines 5 and 6. If the current-year distributable amount is 

greater than the sum of the excess distributions carryover 

from the prior year plus the current-year distributions, then 

the organization doesn't meet the distribution requirement 

and can't qualify as a Type III non-functionally integrated 

supporting organization for the tax year, unless an exception 

applies. If the organization doesn't qualify as a supporting 

organization or otherwise as a public charity for the tax year, 

then it is a private foundation and must file Form 990-PF for 

the tax year and subsequent years until private foundation 

status is terminated under section 507. If either the 

reasonable cause or judicial proceeding exception applies, 

then explain in detail in Part VI how the organization met the 

requirements for the exception.

Reasonable cause exception. An organization that fails 

to distribute its distributable amount won't be classified as a 

private foundation for the year of the failure if the organization 

establishes to the satisfaction of the IRS that:

1. The failure was due to unforeseen events or 

circumstances beyond its control, a clerical error, or an 

incorrect valuation of assets;

2. The failure was due to reasonable cause and not to 

willful neglect; and

3. The distribution requirement is met within 180 days 

after the organization is first able to distribute its distributable 

Instructions for Schedule A (Form 990) 2023 -19-
amount notwithstanding the unforeseen events or 

circumstances, or within 180 days after the clerical error or 

incorrect valuation was or should have been discovered.

Amounts paid to meet a distribution requirement of a prior tax 

year can't also be counted toward the distribution 

requirement for the tax year in which paid.

Judicial proceeding exception. An organization is 

excused from meeting the distribution requirements to the 

extent of a conflicting mandatory provision in its governing 

instrument, if a judicial proceeding is pending to reform a 

governing instrument that prohibits compliance, under the 

circumstances set forth in Regulations section 1.509(a)-4(i)

(11)(ii)(E).

Lines 7 and 8. Enter on line 7 the prior-year carryover and 

the current-year distributions to the extent not applied to 

prior-year underdistributions and the current-year 

distributable amount (and not already carried over for 5 tax 

years). The organization may carry over these amounts to 

future years. Prior-year carryovers are applied before 

current-year distributions.

Part VI. Supplemental Information

Use Part VI to provide narrative information required by these 

instructions or to supplement responses to questions on 

Schedule A (Form 990). Identify the specific part and line 

number that the response supports, in the order in which they 

appear on Schedule A (Form 990). Part VI can be duplicated 

if more space is needed.

Don't include in Part VI the names of any donors, 

grantors, or contributors because Part VI will be 

CAUTION

made available for public inspection.

!

-20- Instructions for Schedule A (Form 990) 2023