Schedule R - Related Organizations and Unrelated Partnerships; Schedule R-1 - Continuation Sheet for Schedule R

2011

Instructions for Schedule R
(Form 990)

Department of the Treasury
Internal Revenue Service

Related Organizations and Unrelated Partnerships
Section references are to the Internal
Revenue Code unless otherwise noted.

General Instructions

Future developments.The IRS has
created a page on IRS.gov for information
about Form 990 and its instructions, at
www.irs.gov/form990. Information about
any future developments affecting Form
990 (such as legislation enacted after we
release it) will be posted on that page.
Note. Terms in bold are defined in the
Glossary of the Instructions for Form 990.

Purpose of Schedule
Schedule R (Form 990) is used by an
organization that files Form 990 to
provide information on related
organizations, on certain transactions
with related organizations, and on certain
unrelated partnerships through which the
organization conducts significant
activities.

Who Must File
The chart below sets forth which
organizations must complete all or a part
of Schedule R and attach Schedule R to
Form 990. If an organization is not
required to file Form 990 but chooses to
do so, it must file a complete return and
provide all of the information requested,
including the required schedules.

Overview

Relationships

Part I requires identifying information on
any organization that is treated for federal
tax purposes as a disregarded entity.
Part II requires identifying information on
related tax-exempt organizations. Part III
requires identifying information on any
related organization that is treated for
federal tax purposes as a partnership.
Part IV requires identifying information on
any related organization that is treated for
federal tax purposes as a C or S
corporation or trust. Part V requires
information on transactions between the
organization and related organizations
(excluding disregarded entities). Part VI
requires information on an unrelated
organization taxable as a partnership
through which the organization conducted
more than 5% of its activities (as
described in Part VI).

An organization, including a nonprofit
organization, a stock corporation, a
partnership or limited liability company, a
trust, and a governmental unit or other
government entity, is a related
organization to the filing organization if it
stands, at any time during the tax year, in
one or more of the following relationships
to the filing organization.
• Parent — an organization that controls
(see definitions of control under
Definition of Control) the filing
organization.
• Subsidiary — an organization controlled
by the filing organization.
• Brother/Sister — an organization
controlled by the same person or persons
that control the filing organization.
• Supporting/Supported — an
organization that is (or claims to be) at
any time during the organization’s tax
year (i) a supporting organization of the
filing organization within the meaning of
section 509(a)(3), if the filing organization
is a supported organization within the
meaning of section 509(f)(3), or (ii) a
supported organization, if the filing
organization is a supporting organization.
• Sponsoring Organization of a VEBA: an
organization that establishes or maintains
a section 501(c)(9) voluntary employees’
beneficiary association (VEBA) during the
tax year. A sponsoring organization of a
VEBA also includes an employee
organization, association, committee, joint
board of trustees, or other similar group of
representatives of the parties which
establish or maintain a VEBA.
• Contributing Employer of a VEBA: an
employer that makes a contribution or
contributions to the VEBA during the tax
year.
Disregarded entity exception.
Disregarded entities are treated as
related organizations for purposes of
reporting on Schedule R, Part I, but not
for purposes of reporting transactions with
related organizations in Part V, or
otherwise on Form 990. A disregarded
entity of an organization related to the
filing organization is treated as part of the
related organization and not as a
separate entity. See Appendix F in the
Instructions for Form 990.
Bank trustee exception. If the filing
organization is a trust that has a bank or
financial institution trustee that is also the
trustee of another trust, the filing
organization is not required to report the
other trust as a brother/sister related

Parts I-VI of Schedule R (Form 990)
may be duplicated if additional space is
needed to report additional related
organizations for Parts I-IV, additional
transactions for Part V, or additional
unrelated organizations for Part VI. Use
as many duplicate copies as needed, and
number each page of each part.
Part VII of Schedule R (Form 990)
may be used to provide additional
information in response to questions in
Schedule R.

Type of filer

IF you answer “Yes” to . . .

THEN you must complete . . .

All organizations

Form 990, Part IV, line 33
(regarding disregarded entities)

Schedule R, Part I.

All organizations

Form 990, Part IV, line 34
(regarding related
organizations)

Schedule R, Parts II, III, IV,
and V, line 1 as applicable.

All organizations

Form 990, Part IV, line 35a
(regarding controlled entities
under section 512(b)(13))

Schedule R, Part V, line 2.

Section 501(c)(3) organization

Form 990, Part IV, line 36
(regarding transfers to exempt
noncharitable related
organizations)

Schedule R, Part V, line 2.

All organizations

Form 990, Part IV, line 37
(regarding conduct of activity
through unrelated partnership)

Schedule R, Part VI.

Jan 13, 2012

Cat. No. 51519M

organization on the ground of common
control by the bank or financial institution
trustee.

Definition of Control
Related organizations For purposes of
determining related organizations:
Control of a nonprofit organization
(or other organization without owners
or persons having beneficial interests,
whether the organization is taxable or
tax-exempt)
One or more persons (whether
individuals or organizations) control a
nonprofit organization if they have the
power to remove and replace (or to
appoint, elect, or approve or veto the
appointment or election of, if such power
includes a continuing power to appoint,
elect, or approve or veto the appointment
or election of, periodically or in the event
of vacancies) a majority of the nonprofit
organization’s directors or trustees, or a
majority of the members who have the
power to elect a majority of the nonprofit
organization’s directors or trustees. Such
power can be exercised directly by a
(parent) organization through one or more
of the (parent) organization’s officers,
directors, trustees, or agents, acting in
their capacity as officers, directors,
trustees, or agents of the (parent)
organization. Also, a (parent) organization
controls a (subsidiary) nonprofit
organization if a majority of the
subsidiary’s directors or trustees are
trustees, directors, officers, employees,
or agents of the parent.
Control of a stock corporation
One or more persons (whether
individuals or organizations) control a
stock corporation if they own more than
50% of the stock (by voting power or
value) of the corporation.
Control of a partnership or limited
liability company
One or more persons control a
partnership if they own more than 50% of
the profits interests or capital interests in
the partnership (including a limited liability
company treated as a partnership or
disregarded entity for federal tax
purposes, regardless of the designation
under state law of the ownership interests
as stock, membership interests, or
otherwise). A person also controls a
partnership if the person is a managing
partner or managing member of a
partnership or limited liability company
which has three or fewer managing
partners or managing members
(regardless of which partner or member
has the most actual control), or if the
person is a general partner in a limited
partnership which has three or fewer
general partners (regardless of which
partner has the most actual control). For
this purpose, a “managing partner” is a
partner designated as such under the
partnership agreement, or regularly
engaged in the management of the
partnership.

Control of a trust with beneficial
interests
One or more persons control a trust if
they own more than 50% of the beneficial
interests in the trust. A person’s beneficial
interest in a trust shall be determined in
proportion to that person’s actuarial
interest in the trust as of the end of the
tax year.
See Regulations sections 301.7701-2,
3, and 4 for more information on
classification of corporations,
partnerships, disregarded entities, and
trusts.
Examples of control by multiple
persons.
Example 1. Organizations A and B
each appoint one-third of the board
members of Organizations C and D, and
are not otherwise related to Organizations
C and D. Although neither Organization A
nor Organization B is a parent of
Organization C or Organization D,
Organizations C and D are controlled by
the same persons, and therefore are
brother/sister related organizations with
respect to each other.
Example 2. Organization E has
1,000 individual members who elect its
board members. The membership of
Organization E also is the membership of
Organization F, and elects the board
members of Organization F.
Organizations E and F are brother/sister
related organizations with respect to each
other.
Indirect control. Control can be
indirect. For example, if the filing
organization controls Entity A, which in
turn controls (under the definition of
control in these instructions) Entity B, the
filing organization will be treated as
controlling Entity B. To determine indirect
control through constructive ownership of
a corporation, rules under section 318
apply. Similar principles apply for
purposes of determining constructive
ownership of another entity (a partnership
or trust). If an entity (X) controls an entity
treated as a partnership by being one of
three or fewer partners or members, then
an organization that controls X also
controls the partnership.
Example 1. B, an exempt
organization, wholly owns (by voting
power) C, a taxable corporation. C holds
a 51% profits interest in D, a partnership.
Under the principles of section 318, B is
deemed to own 51% of D (100% of C’s
51% interest in D). Thus, B controls both
C and D, which are therefore both related
organizations with respect to B.
Example 2. X, an exempt
organization, owns 80% (by value) of Y, a
taxable corporation. Y holds a 60% profits
interest as a limited partner of Z, a limited
partnership. Under the principles of
section 318, X is deemed to own 48% of
Z (80% of Y’s 60% interest in Z). Thus, X
controls Y. X does not control Z through
X’s ownership in Y. Y is a related
organization with respect to X, and
(absent other facts) Z is not.

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Example 3. Same facts as in
Example 2, except that Y is also one of
three general partners of Z. Because Y
controls Z through means other than
ownership percentage, and X controls Y,
in these circumstances, Z is a related
organization with respect to X. The other
general partners of Z (if organizations)
are not related organizations with respect
to X, absent other facts.
Example 4. Organizations A, B, C,
and D are nonprofit organizations.
Organization A appoints the board of
Organization B, which appoints the board
of Organization C. A majority of the board
members of Organization D are also
board members of Organization A. Under
these circumstances, Organizations B
and D are directly controlled by
Organization A, and Organization C is
indirectly controlled by Organization A.
Therefore, Organizations B, C, and D are
subsidiaries of Organization A;
Organization C is also a subsidiary of
Organization B; and Organizations B and
C have a brother/sister relationship with
Organization D.
Group exemption. Central
organizations and subordinate
organizations of a group exemption are
not required to be listed as related
organizations in Schedule R, Part II. All
other related organizations of the
central organization or of a subordinate
organization are required to be listed in
Schedule R. The following rules apply.
• An organization that is a central or
subordinate organization in a group
exemption (whether filing an individual
return or a group return) is not required
to list any of the subordinate
organizations of the group in Schedule R,
Part II.
• In the case of a group return, the
central organization must attach a list of
the subordinate organizations included in
the group return in response to Form 990,
page one, item H(b). The central
organization must list in Schedule R the
related organizations of each subordinate
organization other than (1) related
organizations that are included within the
group exemption, or (2) related
organizations that the central organization
knows to be included in another group
exemption. If an organization is not listed
because it is known to be included in
another group exemption, the central
organization must explain in Part VII the
relationship between its own group and
members and the related organization
known to be included in another group
exemption (but you need not include the
names of such related organizations).
• An organization that is not included in a
group exemption is not required to list a
related organization that is included in a
group exemption. Similarly, an
organization that is included in a group
exemption is not required to list a related
organization that is included in another
group exemption. In either case, the
organization must explain in Part VII the
relationship between it and the related

organization included in another group
exemption (but you need not include the
names of such related organizations).
Even if a related organization is not
required to be listed in Part II, however,
the organization must report its
transactions with the related organization
in Part V, as required by the Part V
instructions (for example, transactions
over the applicable $50,000 reporting
threshold for line 2), including listing the
name of the related organization in Part
V, line 2, column (a), for transactions that
must be reported in line 2.

Specific Instructions
Part I. Identification of
Disregarded Entities
Enter the details of each disregarded
entity on a separate line of Part I. If there
are more disregarded entities to report in
Part I than space available, use as many
duplicate copies of Part I as needed, and
number each page.
Column (a) Name, address, and EIN.
Enter the full legal name and mailing
address of the disregarded entity. Enter
also the employer identification
number (EIN) of the disregarded entity, if
it has one.
A disregarded entity generally
TIP must use the EIN of its sole
member. An exception applies to
employment taxes: for wages paid to
employees of a disregarded entity on or
after January 1, 2009, the disregarded
entity must file separate employment tax
returns and use its own EIN on such
returns. See Regulations sections
301.6109-1(h) and 301.7701-2(c)(2)(iv).
Column (b) Primary activity. Briefly
describe the primary activity of the
disregarded entity.
Column (c) Legal domicile. List the
U.S. state (or U.S. possession) or
foreign country in which the disregarded
entity is organized (the state or foreign
country whose law governs the
disregarded entity’s internal affairs).
Column (d) Total income. Enter the
amount of the filing organization’s total
revenue reported in Form 990, Part VIII,
line 12, column (A), attributable to the
disregarded entity.
Column (e) End-of-year assets. Enter
the amount of the organization’s total
assets reported in Form 990, Part X, line
16, column (B), attributable to the
disregarded entity.
Column (f) Direct controlling entity.
Enter the name of the entity that directly
controls the disregarded entity. If the filing
organization directly controls, enter its
name.

Part II. Identification of
Related Tax-Exempt
Organizations
For purposes of Schedule R, treat
governmental units and
instrumentalities and foreign
governments as tax-exempt
organizations.
Enter the details of each related
organization on a separate line of Part II.
If there are more related organizations to
report in Part II than space available, use
as many duplicate copies of Part II as
needed, and number each page.
Column (a) Name, address, and EIN.
Enter the related organization’s full legal
name, mailing address, and EIN.
Column (b) Primary activity. Briefly
describe the primary activity of the
related organization.
Column (c) Legal domicile. List the
U.S. state (or U.S. possession) or
foreign country in which the related
organization is organized. For a
corporation, enter the state of
incorporation (or the country of
incorporation for a foreign corporation
formed outside the U.S.). For a trust or
other entity, enter the state whose law
governs the organization’s internal affairs
(or the foreign country whose law governs
for a foreign organization other than a
corporation).
Column (d) Exempt Code section.
Enter the section under which the related
organization is exempt (for example,
section 501(c)(3), 501(c)(6), or 527). For
purposes of Schedule R, an organization
that claims exemption is treated as
exempt. Also for purposes of Schedule R,
treat as a section 501(c)(3) organization a
related foreign organization recognized as
a charity by the foreign country, or for
which the filing organization has made a
reasonable judgment (or has an opinion
of U.S. counsel) that the foreign
organization is described in section
501(c)(3). The filing organization is not
required to make or obtain such a
determination for purposes of Schedule
R. For governmental units,
instrumentalities, and foreign
governments that do not have a section
501(c) determination letter, leave blank.
Column (e) Public charity status. For a
related section 501(c)(3) organization,
report its public charity status, using the
appropriate line number (line 1 through
11d) corresponding to the public charity
status checked on Schedule A (Form
990), Public Charity Status and Public
Support, Part I. If the related organization
is a private foundation, use the
designation “PF.” If the related
organization is a section 509(a)(3)
supporting organization, also indicate
its type: I, II, III-FI, or III-O (for Type I,
Type II, Type III functionally integrated, or
Type III other, respectively).
For purposes of Schedule R, treat as a
public charity a related foreign
organization that has not been recognized

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as section 501(c)(3) by the IRS but for
which the filing organization has made a
good faith determination, based on an
affidavit from the foreign organization or
the opinion of counsel, that the foreign
organization is the equivalent of a public
charity. The filing organization is not
required to make or obtain such a
determination for purposes of Schedule
R; if it has not, leave Column (e) blank.
Column (f) Direct controlling entity.
Enter the name of the entity (if any) that
directly controls the related organization.
Otherwise, enter “N/A”. If the filing
organization directly controls, enter its
name.
Column (g) Section 512(b)(13)
controlled entity. Check “Yes” if the
related organization is a controlled
entity of the filing organization under
section 512(b)(13). If not, check “No.”

Part III. Identification of
Related Organizations
Taxable as a Partnership
In this part, identify any related
organization treated as a partnership for
federal tax purposes. If the partnership is
related to the filing organization by reason
of being its parent or brother/sister and
the filing organization is not a partner or
member in the partnership, then complete
only columns (a), (b), and (c), and enter
“N/A” in columns (d), (e), (f), (g), (h), (i),
(j), and (k).
Enter the details of each related
organization on a separate line of Part III.
If there are more related organizations to
report in Part III than space available, use
as many duplicate copies of Part III as
needed, and number each page.
Some of the information requested in
this part is derived from Schedule K-1
(Form 1065) issued to the organization. If
the Schedule K-1 (Form 1065) is not
available, provide a reasonable estimate
of the required information.
Column (a) Name, address, and EIN.
Enter the related partnership’s full legal
name, mailing address, and EIN.
Column (b) Primary activity. Briefly
describe the primary business activity
conducted, or product or service
provided, by the related partnership (for
example, investment in other entities,
low-income housing, etc.).
Column (c) Legal domicile. List the
U.S. state (or U.S. possession) or
foreign country in which the related
partnership is organized (the state or
foreign country whose law governs the
related partnership’s internal affairs).
Column (d) Direct controlling entity.
Enter the name of the entity (if any) that
directly controls the related partnership.
Otherwise, enter “N/A.” If the filing
organization directly controls, enter its
name.
Column (e) Predominant income.
Classify the predominant type of
partnership income as:

• Related;
• Unrelated; or
• Excluded from tax under section 512,

513, or 514.
In other words, enter which of the three
types listed above is more prevalent than
the others.
For classification purposes, use the
definitions of columns (B), (C), and (D)
set forth in the instructions to the
Statement of Revenue in Form 990, Part
VIII.
Column (f) Share of total income.
Enter the dollar amount of the filing
organization’s distributive share of the
related partnership’s total income, in
accordance with the organization’s profits
interest as specified by the partnership or
LLC agreement, for the related
partnership’s tax year ending with or
within the filing organization’s tax year.
Use the total amount reported by the
related partnership on Schedule K-1
(Form 1065) for the partnership’s tax year
ending with or within the filing
organization’s tax year (total of Schedule
K-1, Part III, lines 1 through 11 and 18,
tax-exempt income).
Column (g) Share of end-of-year
assets. Enter the dollar amount of the
filing organization’s distributive share of
the related partnership’s end-of-year total
assets, in accordance with the
organization’s capital interest as specified
by the partnership or LLC agreement, for
the related partnership’s tax year ending
with or within the filing organization’s tax
year. Use Schedule K-1 (Form 1065) for
the partnership’s year ending with or
within the organization’s tax year to
determine this amount by adding the
organization’s ending capital account to
the organization’s share of the
partnership’s liabilities at year end
reported on the Schedule K-1.
Column (h) Disproportionate
allocations. Check “Yes” if the interest
of the filing organization as a partner of
the partnership (or as a member of the
LLC) in any item of income, gain, loss,
deduction, or credit, or any right to
distributions was disproportionate to the
filing organization’s investment in such
partnership or LLC at any time during the
filing organization’s tax year. Otherwise,
check “No.”
Column (i) Code V — UBI amount in
box 20 of Schedule K-1 (Form 1065).
Enter the dollar amount, if any, listed as
the Code V amount (unrelated business
taxable income) in box 20 of Schedule
K-1 (Form 1065) received from the
related partnership for the partnership’s
tax year ending with or within the filing
organization’s tax year. If no Code V
amount is listed in box 20, enter “N/A.”
If the organization has reason to
TIP believe that the stated amount in
box 20 is incorrect, it should
consult with the partnership. The stated
amount in box 20 is not controlling with
respect to the organization’s unrelated
business income tax liability.

Column (j) General or managing
partner. Check “Yes” if the filing
organization was at any time during its
tax year a general partner of a related
limited partnership, or a managing partner
or managing member of a related general
partnership, LLC, or other entity taxable
as a partnership. Otherwise, check “No.”
Column (k) Percentage ownership.
Enter the filing organization’s percentage
interest in the profits or in the capital of
the related partnership, whichever is
greater.

Part IV. Identification of
Related Organizations
Taxable as a Corporation
or Trust
In this part, identify any related
organization treated as a C or S
corporation or trust for federal tax
purposes (such as a charitable remainder
trust), other than a related organization
reported as a tax-exempt organization in
Part II. If the corporation or trust is related
to the filing organization as its parent or
as a brother/sister organization, and the
filing organization does not have an
ownership interest in the corporation or
trust, then complete only columns (a), (b),
(c), and (e), and enter “N/A” in columns
(d), (f), (g), and (h). Do not report trusts
described within section 401(a).
Enter the details of each related
organization on a separate line of Part IV.
If there are more related organizations to
report in Part IV than space available, use
as many duplicate copies of Part IV as
needed, and number each page.
Some of the information requested in
this part is derived from Schedule K-1
(Form 1041) or Schedule K-1 (Form
1120S) issued to the organization. If the
Schedule K-1 is not available, provide a
reasonable estimate of the required
information.
Add an additional copy of this page if
you have more than 11 unrelated
organizations to report. Fill in the page as
needed.
Column (a) Name, address, and EIN.
Enter the related organization’s full legal
name, mailing address, and EIN.
Column (b) Primary activity. Briefly
describe the primary business activity
conducted, or product or service
provided, by the related organization
(for example, holding company,
management company).
Column (c) Legal domicile. List the
U.S. state (or U.S. possession) or
foreign country in which the related
organization is organized. For a
corporation, enter the state of
incorporation (or the country of
incorporation for a foreign corporation
formed outside the U.S.). For a trust or
other entity, enter the state whose law
governs the organization’s internal affairs
(or the foreign country whose law governs

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for a foreign organization other than a
corporation).
Column (d) Direct controlling entity.
Enter the name of the entity (if any) that
directly controls the related organization.
Otherwise, enter “N/A.” If the filing
organization directly controls, enter its
name.
Column (e) Type of entity. Use one of
the following codes to indicate the tax
classification of the related organization:
C (corporation or association taxable
under subchapter C), S (corporation or
association taxable under subchapter S),
or T (trust taxable under subchapter J).
Column (f) Share of total income. For
a related organization that is a C
corporation, enter the dollar amount of the
organization’s share of the C
corporation’s total income. To calculate
this share, multiply the total income by the
following fraction: the value of the filing
organization’s shares of all classes of
stock in the C corporation, divided by the
value of all outstanding shares of all
classes of stock in the C corporation. The
total income is for the related
organization’s tax year ending with or
within the filing organization’s tax year.
For a related organization that is an S
corporation, enter the filing organization’s
allocable share of the S corporation’s total
income. Use the amount on Schedule K-1
(Form 1120S) for the S corporation’s tax
year ending with or within the filing
organization’s tax year (Schedule K-1,
Part III, lines 1 through 10).
For a related organization that is a
trust, enter the total income and gains
reported on Part III, lines 1 through 8 of
Schedule K-1 (Form 1041) issued to the
filing organization for the trust’s tax year
ending with or within the filing
organization’s tax year.
A section 501(c)(3) organization
TIP that is an S corporation
shareholder must treat all
allocations of income from the S
corporation as unrelated business
income, including gain on the disposition
of stock.
Column (g) Share of end-of-year
assets. Enter the dollar amount of the
filing organization’s allocable share of the
related organization’s total assets as of
the end of the related organization’s tax
year ending with or within the filing
organization’s tax year. For related C and
S corporations, this amount is determined
by multiplying the corporation’s
end-of-year total assets by the fraction
described in column (f). For related trusts,
this amount corresponds to the filing
organization’s percentage ownership in
the trust.
Column (h) Percentage ownership.
For a related organization taxable as a
corporation, enter the filing organization’s
percentage of stock ownership in the
corporation (total combined voting power
or total value of all outstanding shares,
whichever is greater). For a related S
corporation, use the percentage reported

on Schedule K-1 (Form 1120S) for the
year ending with or within the filing
organization’s tax year. For a related
organization taxable as a trust, enter the
filing organization’s percentage of
beneficial interest. In each case, enter the
percentage interest as of the end of the
related organization’s tax year ending
with or within the filing organization’s tax
year.
Split-interest trusts. If the related
organization is a split-interest trust
described in section 4947(a)(2), the
organization may enter in column (a) the
term, “Charitable remainder trust,”
“Charitable lead trust,” or “Pooled income
fund,” as appropriate, instead of the
trust’s name, EIN, or address. If the
organization was related to more than
one of a certain type of related
split-interest trust during the tax year, it
should enter the number of that type of
trust in parentheses after the name. For
instance, if the organization had two
related charitable remainder trusts and
three related charitable lead trusts, it
should enter “Charitable remainder trusts
(2)” on one line of column (a) and
“Charitable lead trusts (3)” on another line
in column (a). The organization may leave
columns (f), (g), and (h) blank for these
lines. Use Part VII if the organization
needs space to provide additional
information for columns (b), (c), (d), or (e).

Part V. Transactions With
Related Organizations
Line 1. Check “Yes” in the appropriate
boxes of Line 1 if the filing organization
engaged in any of the transactions listed
in Part V with any of the related
organizations listed in Parts II through
IV. A single transaction may be described
by and reported in more than one line. A
“transfer” includes any conveyance of
funds or property not described in lines 1a
through 1p, whether or not for
consideration, such as a merger with a
related organization.
Line 2. All organizations filing Schedule
R must report the following transactions
with a controlled entity of the filing
organization as defined in section
512(b)(13).
• All transactions described in line 1a,
which includes all receipts or accruals of
interest, annuities, royalties, or rent from
a controlled entity under section
512(b)(13), regardless of amount.
• Any other type of transaction described
in lines 1b through 1r with controlled
entities, if the amounts involved during
the tax year between the filing
organization and a particular controlled
entity exceed $50,000 for that type of
transaction.
Section 501(c)(3) organizations must
also report on line 2 transactions
described in Part V, lines 1b through 1r
with related tax-exempt organizations not
described in section 501(c)(3) (including
section 527 political organizations), if the
amounts involved during the tax year

between the filing organization and a
particular related tax-exempt organization
exceed $50,000.
Enter the details of each related
organization and each transaction type on
a separate line of the table. If there are
more related organizations or transaction
types to report than space available, use
as many duplicate copies of Part V as
needed, and number each page.
Transactions of a specified type
described in lines 1b through 1r with a
particular organization do not need to be
reported if the total amount of
transactions of such type during the tax
year did not exceed $50,000.
Column (a) Name. Enter the full legal
name of the related organization.
Column (b) Transaction type. Enter the
transaction type (lines 1a through 1r).
Aggregate all transactions of the same
type with the same related organization.
Column (c) Amount involved. The
amount involved in a transaction is the
fair market value of the services, cash,
and other assets provided by the filing
organization during its tax year, or the fair
market value received by the filing
organization, whichever is higher,
regardless of whether the transaction was
entered into by the parties in a prior year.
Any reasonable method for determining
such amount is acceptable.
Column (d) Method of determining
amount involved. Describe the method
used to determine the value of the
services, cash, and other assets reported
in column (c).
Split-interest trusts. If the organization
engaged in a type of transaction
reportable in Part V, line 2 with one or
more split-interest trusts described in
section 4947(a)(2), the organization may
enter in column (a) the term, “Charitable
remainder trust,” “Charitable lead trust,”
or “Pooled income fund,” as appropriate,
instead of the trust’s name. For instance,
if the organization carried a $100,000
liability for a loan it received from a
related charitable lead trust, it should
enter “Charitable remainder trust” in
column (a), transaction type “e” in column
(b), and “$100,000” in column (c). Multiple
transactions of the same type with the
same type of split-interest trust may be
aggregated on the same line, with the
number of each type of trust listed in
parentheses. For instance, if the
organization received $60,000 from one
related charitable remainder trust as
payment for investment services and
$70,000 from another related charitable
remainder trust as payment for
investment services during the tax year, it
may enter “Charitable remainder trusts
(2)” in column (a), transaction type “k” in
column (b), and “$130,000” in column (c).

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Part VI. Unrelated
Organizations Taxable as a
Partnership
In this part, provide information on any
unrelated organization (an organization
that is not a related organization with
respect to the filing organization) that
meets all of the following conditions.
1. The unrelated organization is
treated as a partnership for federal tax
purposes (S corporations are excluded).
2. The filing organization was a
partner or member of the unrelated
partnership at any time during the filing
organization’s tax year.
3. The filing organization conducted
more than 5% of its activities, based on
the greater of its total assets at the end
of its tax year or its total revenue for its
tax year, through the unrelated
partnership.
In determining the percentage of the
filing organization’s activities as
measured by its total assets, use the
amount reported on Form 990, Part X,
line 16, column (B) as the denominator,
and the filing organization’s ending capital
account balance for the partnership tax
year ending with or within the filing
organization’s tax year as the numerator
(the amount reported on Schedule K-1
can be used). In determining the
percentage of the filing organization’s
activities as measured by its total
revenue, use the amount reported on
Form 990, Part VIII, line 12, as the
denominator, and the filing organization’s
proportionate share of the partnership’s
gross revenue for the partnership tax year
ending with or within the filing
organization’s tax year as the numerator.
Example. X, a section 501(c)(3)
organization, is a partner of Y, an
unrelated partnership, which conducts an
activity that constitutes an unrelated
trade or business with respect to X. X’s
proportionate share of Y’s gross revenue
is $60,000 for Y’s tax year ending with or
within X’s tax year. X has an ending
capital account balance in Y of $120,000
as reported on Schedule K-1. X’s gross
revenue and total assets for its tax year
are $1,000,000 and $1,200,000,
respectively. Because X’s total assets
exceed X’s gross revenue for its tax year,
X must consider total assets in
determining whether X conducted more
than 5% of its activities through Y for X’s
tax year. X conducted 10% of its activities
through Y, as measured by X’s total
assets ($120,000/$1,200,000), and thus
must identify Y in Schedule R, Part VI,
and provide the required information. If,
instead, X’s gross revenue for its tax year
were $1,300,000, then gross revenue
would be considered rather than total
assets; X’s activities conducted through
Y, as measured by X’s gross revenue
($60,000/$1,300,000) would not be
greater than 5% of X’s total activities, and
therefore X would not be required to
identify Y in Schedule R, Part VI.

Disregard unrelated partnerships that
meet both of the following conditions.
1. 95% or more of the filing
organization’s gross revenue from the
partnership for the partnership’s tax year
ending with or within the organization’s
tax year is described in sections
512(b)(1) – (3) and (5), such as interest,
dividends, royalties, rents, and capital
gains (including unrelated debt-financed
income).
2. The primary purpose of the filing
organization’s investment in the
partnership is the production of income or
appreciation of property and not the
conduct of a section 501(c)(3) charitable
activity such as program-related
investing.
Enter the details of each organization
on a separate line of Part VI. If there are
more organizations to report in Part VI
than space available, use as many
duplicate copies of Part VI as needed,
and number each page.
Some of the information requested in
this part is derived from Schedule K-1
(Form 1065) issued to the organization. If
the Schedule K-1 is not available, provide
a reasonable estimate of the required
information.
Column (a) Name, address, and EIN.
Enter the unrelated partnership’s full legal
name, mailing address, and EIN.
Column (b) Primary activity. Briefly
describe the primary business activity
conducted, or product or service
provided, by the unrelated partnership.
Column (c) Legal domicile. List the
U.S. state (or U.S. possession) or
foreign country in which the unrelated
partnership is organized (the state or
foreign country whose law governs the
unrelated partnership’s internal affairs).
Column (d) Predominant income.
Classify the predominant type of income
as:
• Related;
• Unrelated; or

• Excluded from tax under section 512,

513, or 514.
In other words, enter one of the three
types of income listed above that is more
prevalent than the others. For
classification purposes, use the
definitions set forth in the instructions to
the Statement of Revenue in Form 990,
Part VIII, columns (B), (C), and (D).
Column (e) Section 501(c)(3) partners.
Check “Yes” if all the partners of the
unrelated partnership (or members of the
LLC) are section 501(c)(3) organizations
or governmental units (or wholly-owned
subsidiaries of either). Otherwise, check
“No.”
Column (f) Share of total income.
Enter the dollar amount of the filing
organization’s distributive share of the
related partnership’s total income, in
accordance with the organization’s profits
interest as specified by the partnership or
LLC agreement, for the related
partnership’s tax year ending with or
within the filing organization’s tax year.
Use the total amount reported by the
related partnership on Schedule K-1
(Form 1065) for the partnership’s tax year
ending with or within the filing
organization’s tax year (total of Schedule
K-1, Part III, lines 1 through 11 and line
18, tax-exempt income).
Column (g) Share of end-of-year
assets. Enter the dollar amount of the
filing organization’s distributive share of
the unrelated partnership’s total assets, in
accordance with the filing organization’s
capital interest as specified by the
partnership or LLC agreement, as of the
end of the unrelated partnership’s tax
year ending with or within the filing
organization’s tax year. Use the ending
capital account reported on Schedule K-1
(Form 1065) for the year ending with or
within the filing organization’s tax year.
Column (h) Disproportionate
allocations. Check “Yes” if the interest
of the filing organization as a partner of

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the partnership (or as a member of the
LLC) in any item of income, gain, loss,
deduction, or credit, or any right to
distributions was disproportionate to the
organization’s investment in such
partnership or LLC at any time during the
filing organization’s tax year. Otherwise,
check “No.”
Column (i) Code V — UBI amount in
box 20 of Schedule K-1 (Form 1065).
Enter the dollar amount, if any, listed as
the Code V amount (unrelated business
taxable income) in box 20 of Schedule
K-1 (Form 1065) received from the
unrelated partnership for the partnership’s
tax year ending with or within the filing
organization’s tax year. If no Code V
amount is listed in box 20, enter “N/A.”
Column (j) General or managing
partner. Check “Yes” if the filing
organization was at any time during its
tax year a general partner of an unrelated
limited partnership, or a managing partner
or managing member of an unrelated
general partnership, LLC, or other entity
taxable as a partnership. Otherwise,
check “No.”
Column (k) Percentage ownership.
Enter the filing organization’s percentage
interest in the profits or in the capital of
the related partnership, whichever is
greater.

Part VII. Supplemental
Information
Use Part VII if the organization needs
space to provide additional information in
response to questions in Schedule R
(Form 990). In Part VII, identify the
specific part and line number that each
response supports, in the order in which
those parts and lines appear on Schedule
R (Form 990). Part VII can be duplicated
if more space is needed.