Instructions for S Instructions for Schedule A (Form 990 or Form 990-EZ), P

2019

Instructions for Schedule A
(Form 990 or 990-EZ)

Department of the Treasury
Internal Revenue Service

Public Charity Status and Public Support
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 or 990-EZ) 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 or
990-EZ) 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

TIP from tax under section 501(c)(3)

but is a private foundation and
not a public charity shouldn't file Form
Oct 23, 2019

990, Form 990-EZ, or Schedule A (Form
990 or 990-EZ), but should file Form
990-PF, Return of Private Foundation or
Section 4947(a)(1) Trust Treated as
Private Foundation. See instructions to
Part I.

Accounting Method

When completing Schedule A (Form
990 or 990-EZ), 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 or 990-EZ), regardless of the
accounting method it used in
completing Schedule A (Form 990 or
990-EZ) for prior years, except that in
Part V, Sections D and E, distributions
must be reported on the cash receipts
and disbursements method.
If the accounting method the
organization used in completing the
2018 Schedule A (Form 990 or 990-EZ)
was different from the accounting
method checked on the 2019 Form 990,
Part XII, line 1, or the 2019 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 2018 Schedule A (Form
990 or 990-EZ). Instead, the
organization should report all amounts
in Part II or Part III using the accounting
method checked on the 2019 Form 990,
Part XII, line 1, or the 2019 Form
990-EZ, line G.
If the organization changed its

TIP accounting method from a prior

year, it should provide an
explanation in Schedule O (Form 990 or
990-EZ), 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 2018 Schedule A
(Form 990 or 990-EZ) using the cash
method, it should report in the 2015
through 2018 columns on the 2019
Schedule A (Form 990 or 990-EZ) the
Cat. No. 11294Q

same amounts that it reported in the
2015 through 2018 columns on the
2018 Schedule A (Form 990 or 990-EZ).
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 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 2019 Schedule A
(Form 990 or 990-EZ). The organization
should report accruals of present value
increments to the unpaid grant on
Schedule A (Form 990 or 990-EZ) 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
or 990-EZ) 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 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, 990-EZ, or

990-PF), Schedule of Contributors, by
meeting the 331/3% support test.

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

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 or 990-EZ). 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 Form 8940,
Request for Miscellaneous
Determination, for instructions. A $400
user fee must be submitted with such a
request. See Appendix A of Rev. Proc.
2019-5 I.R.B. 1, 81.

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 lines 12e and 12f;
3. Complete the table on line 12g;
and
4. Complete Part IV and (if
applicable) Part V.

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
1-877-829-5500 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

Example 4. The organization
received an exemption letter that it is a
supporting organization under
section 509(a)(3). Based on Rev. Proc.
2019-5, 2019-1 I.R.B. 230, 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 or 990-EZ) 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–12d to
determine which type best describes
the organization. The organization may
wish to file Form 8940 to request a
determination of type.
-2-

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 or 990-EZ),
Schools, and its related instructions.
An organization that checks the

TIP box on line 2 must also

complete Schedule E (Form
990 or 990-EZ), 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.
Check the box on line 3 also for a
cooperative hospital service
organization described in section
501(e).

Instructions for Schedule A (Form 990 or 990-EZ)

The definition of hospital for

TIP Schedule A (Form 990 or

990-EZ), 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 also is 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.
possession 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

TIP research for Schedule A (Form

990 or 990-EZ), 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 20.2031.
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.
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 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
CAUTION 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.

Instructions for Schedule A (Form 990 or 990-EZ)

-3-

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-Non-Profits/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.
All supporting organizations,
regardless of type, must be
CAUTION 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 relationship
requirement and 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.
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. 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, Part I.
-4-

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
CAUTION 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.
• 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 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

Instructions for Schedule A (Form 990 or 990-EZ)

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).

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.

Part II. Support Schedule
for Organizations
Described in Sections
170(b)(1)(A)(iv) and
170(b)(1)(A)(vi)

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, 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).

If the organization checked a
box in Part I, on line 5, 7, or 8, it
CAUTION 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

TIP 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
agencies, 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 agencies,
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

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, 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

Instructions for Schedule A (Form 990 or 990-EZ)

-5-

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.
Unusual grants. Unusual grants
generally are 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 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
CAUTION 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
CAUTION 990-EZ because it may be
made available for public inspection.

!

Line 1. Example—List of unusual
grants

▶ 2019
Name ▶ Mr.

Description

Year

Undeveloped land

Distinguished Donor

▶

Date of Grant
January 15, 2019

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 or 990-EZ), Part
I, 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 or 990-EZ), 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 on
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 section 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);
-6-

• 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 on
line 11, column (f). An example of this
list is given later.
Don't file this list with the
organization's Form 990 or
CAUTION 990-EZ because it may be
made available for public inspection.

!

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.
Net income and net losses from all of
the organization's unrelated business
activities should be aggregated. 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

Instructions for Schedule A (Form 990 or 990-EZ)

Line 5. Example—List of donors other than governmental units and publicly supported organizations
Assumption: 2% of the amount on Schedule A (Form 990 or 990-EZ), Part II, line 11, column (f) is $12,000
Contributors whose total gifts from 2015 through 2019 were in excess of the 2% limitation
Name

(a)

(b)

(c)

(d)

(e)

(f)

(g)

2015

2016

2017

2018

2019

Total

Excess
contributions
(col. (f) minus
the 2%
limitation)

XYZ Foundation
Banana Office
Supply

$59,000
$12,000

Plum Corporation
John Smith
Sue Adams

$5,000

$5,000

$18,000

$80,000

$68,000

$3,000

$1,000

$16,000

$4,000

$15,000

$15,000

$30,000

$18,000

$5,000

$1,000

$16,000

$4,000

$30,000

$18,000

$27,000

$15,000

$10,000

Raisin Trade
Assoc.

$3,000

$10,000
$20,000

$7,000

$10,000

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

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.
An organization in its first 5

TIP years as a section 501(c)(3)

organization should make the
public support computations on a copy
of Schedule A that it keeps for itself. An
organization should carefully monitor its

Instructions for Schedule A (Form 990 or 990-EZ)

-7-

$127,000

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 2019, enter the public
support percentage from the 2018
Schedule A (Form 990 or 990-EZ), 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 2019
and 2020.
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 2019.
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 2019 and
2020.
If this box is checked, explain in Part
IV 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 which 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 2019. 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.
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 2019 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 2019 tax year for
filing purposes and shouldn't file Form
990, Form 990-EZ, or Schedule A (Form
990 or 990-EZ) for the 2019 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

TIP organization's sixth tax year as

a section 501(c)(3)
organization, the organization should
compute 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

TIP 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

TIP 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,
on line 14, it should stop there and not
complete the rest of Part III.
If the organization checked the

TIP 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
-8-

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.
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, it should deduct

Instructions for Schedule A (Form 990 or 990-EZ)

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.

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
1.509(a)-3(c)(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
CAUTION 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
later.
Don't file this list with the
organization's Form 990 or
CAUTION 990-EZ because it may be
made available for public inspection.

!

Unusual grants. Unusual grants
generally are 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
Instructions for Schedule A (Form 990 or 990-EZ)

Line 1. Example—List of unusual
grants

▶ 2019
Name ▶ Mr.

Description

Year

Undeveloped land

Distinguished Donor

▶

Date of Grant
January 15, 2019

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 or 990-EZ), 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 or 990-EZ), 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

-9-

Line 7a. Example—List of amounts received from disqualified persons
Disqualified Person
David Smith

(a) 2015

(b) 2016

$7,000

$6,000

Anne Parker
Total

$7,000

$6,000

(c) 2017

(d) 2018

$5,000

$7,000

$5,000

$7,000

(e) 2019

(f) Total

$2,000

$15,000

$4,000

$16,000

$6,000

$31,000

Line 7b. Example—List of amounts received from other than disqualified persons
Year 2019
(a) Name

Word Processing, Inc.

(b) Amount received in
2019

(c) 1% of amount on
line 13 in 2019

(d) Enter the larger of
column (c) or $5,000

(e) 2019 excess
(column (b) minus
column (d))

$25,000

$2,000

$5,000

$20,000

Enter on Schedule A, column (e), line 7b

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).
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
CAUTION 990-EZ because it may be
made available for public inspection.

!

-10-

$20,000

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 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
CAUTION 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 (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

Instructions for Schedule A (Form 990 or 990-EZ)

business that was acquired or
commenced after June 30, 1975.
Net income and net losses from all of
these trades or businesses should be
aggregated. If a net loss results, enter
“0” on this line. See Regulations section
1.509(a)-3(a)(3).
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.
Net income and net losses from all of
the organization's unrelated business
activities should be aggregated. 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.
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

TIP 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 or 990-EZ) 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 2019, enter the public
support percentage from the 2018
Schedule A (Form 990 or 990-EZ), 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 2019, enter the investment
income percentage from the 2018
Schedule A (Form 990 or 990-EZ), 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
2019 and 2020.
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 2019.
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 2019 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 or 990-EZ), 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 or
990-EZ) for the 2019 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

TIP organization's sixth tax year as

a section 501(c)(3) organization
and it checked the box on line 20, it
should compute the public support

Instructions for Schedule A (Form 990 or 990-EZ)

-11-

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

TIP 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 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
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, 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 have
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 generally must
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 which 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 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,
-12-

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 generally may
also 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 or 990-EZ),
Transactions With Interested Persons,
Part I. For more information on excess
benefit transactions generally, see the
Instructions for Schedule L.
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 in
lines 9b or 9c, or derives personal
benefit from any such assets, provide
detail in Part VI.

Instructions for Schedule A (Form 990 or 990-EZ)

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 generally are also 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.

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 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 persons),
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 C. Type II Supporting
Organizations

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

Line 2. The supporting organization
may benefit organizations that don't
participate in the control relationship
described in line 1, but only if such
activity carries out the purposes of the
controlling supported 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).

Instructions for Schedule A (Form 990 or 990-EZ)

-13-

3. A copy of the supporting
organization’s updated governing
documents (including articles of
organization, 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 had 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 was 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
Organization
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 instructions
for Line 2, later), (b) be the parent of its
supported organizations (see
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 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
-14-

supporting organization) generally must
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 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.

Instructions for Schedule A (Form 990 or 990-EZ)

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 have
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

Instructions for Schedule A (Form 990 or 990-EZ)

-15-

property held for the production of
income. Such expenses may include
operating expenses such as
compensation of officers and
employees, 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 non-charitable 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. Compute 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
instructions for Line 4, later) or set aside
and taken as a distribution (see
instructions for Line 5, Section D, 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
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on acceptable methods of valuing
property for federal estate tax purposes
will be considered acceptable.
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
compute 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

Instructions for Schedule A (Form 990 or 990-EZ)

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 in 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, 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.

Instructions for Schedule A (Form 990 or 990-EZ)

-17-

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
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
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the rules for qualifying 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, 2016, and
through its following 2017 tax year
meets the requirements of Regulations
section 1.509(a)-4(i)(3)(iii) as in effect
prior to December 28, 2016. Under
transition rules, X is deemed to meet its
distribution requirement for 2017, but its
distributable amount is calculated in the
ordinary manner to determine its excess
distributions. For 2017, 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 2018, X had a distributable amount
of $95,000 and distributions of $85,000.
X first applied its 2017 excess
distributions carryover of $20,000 to the
2018 distributable amount of $95,000.
Then, X applied $75,000 of its 2018
distributions of $85,000 to the remaining
2018 distributable amount. Accordingly,
X has excess distributions of $10,000
from 2018 (2018 distributions of
$85,000 minus $75,000 applied to the
2018 distributable amount), which it
may carry over to 2019. For 2019, X has
a distributable amount of $100,000 and
distributions of $150,000. X applies the
$10,000 excess distribution carryover
from 2018 to the 2019 distributable
amount. Then, X applies $90,000 of its
2019 distributions to the remaining 2019
distributable amount. Section E will
show $0 carryovers for 2017 and 2018
(because the excess carryovers for
each of those years were previously
applied). In addition, Section E will show
excess distributions of $60,000 in 2019
(2019 distributions of $150,000 minus
$90,000 applied to the 2019
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, 2016,
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 2017
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 2017 tax
year. Y's distributable amount was
$120,000 for 2017. Y made distributions

Instructions for Schedule A (Form 990 or 990-EZ)

of that amount and had no excess
distributions to carry over to 2018. Y
calculated that its distributable amount
was $150,000 for 2018 and made
distributions of exactly that amount in
2018. Early in its 2019 tax year, Y
discovers that its distributable amount
for 2018 actually was $200,000. Within
180 days, Y makes a $110,000
distribution ($50,000 to cover the
underdistribution for 2018 and $60,000
as part of its 2019 distributions). Later in
the 2019 tax year, Y makes additional
distributions totaling $200,000. Y’s
distributable amount in the 2019 tax
year is $190,000. In its 2019 Form 990,
Y claims reasonable cause for the 2018
underdistribution due to a clerical error.
Under these circumstances, Y first
applies $50,000 of its 2019 distributions
of $310,000 to the 2018
underdistribution of $50,000 ($200,000
minus $150,000), then applies
$190,000 of its remaining 2019
distributions of $260,000 ($310,000
minus $50,000) to satisfy its 2019
distributable amount. Y’s remaining
$70,000 of distributions in 2019
($310,000, minus $50,000 allocated to
2018, and minus $190,000 allocable to
2019) are excess distributions that may
be carried over to future years.
Line 1. Report the distributable amount
for 2019 from Section C, line 6.
Line 2. An organization that is treated
as a non-functionally integrated Type III
supporting organization for the first time
in its 2018 tax year will have a
distributable amount of zero during the
2018 tax year.
If the organization had any
underdistributions for a prior tax year
(2017 or 2018), 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 2018 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.

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 amount notwithstanding
the unforeseen events or
circumstances, or within 180 days after
the clerical error or incorrect valuation
was or should have been discovered.

Excess distributions can't be carried
over for more than 5 tax years and thus
are forfeited if not used in the fifth year
of carryover. Such amounts are set forth
in line 3i (not applicable to the 2019
return).

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.

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

Instructions for Schedule A (Form 990 or 990-EZ)

-19-

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
or 990-EZ). Identify the specific part and
line number that the response supports,
in the order in which they appear on
Schedule A (Form 990 or 990-EZ). Part
VI can be duplicated if more space is
needed.
Don't include in Part VI the
names of any donors, grantors,
CAUTION or contributors because Part VI
will be made available for public
inspection.

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