990 Schedule A Instructions for Schedule A (Form 990)

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2023

Instructions for Schedule A
(Form 990)

Department of the Treasury
Internal Revenue Service

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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) is used by an organization that files
Form 990, Return of Organization Exempt From Income Tax,
or Form 990-EZ, Short Form Return of Organization Exempt
From Income Tax, to provide the required information about
public charity status and public support.

Who Must File

An organization that answered “Yes” to Form 990, Part IV,
line 1, must complete and attach Schedule A (Form 990) to
Form 990. Any section 501(c)(3) organization (or
organization treated as such) that files a Form 990-EZ must
complete and attach this schedule to Form 990-EZ. These
include:
• Organizations that are described in section 501(c)(3) and
are public charities;
• Organizations that are described in sections 501(e),
501(f), 501(j), 501(k), or 501(n); and
• Nonexempt charitable trusts described in section
4947(a)(1) that aren’t treated as private foundations.

If an organization isn’t required to file Form 990 or 990-EZ
but chooses to do so, it must file a complete return and
provide all of the information requested, including the
required schedules.
Any organization that is exempt from tax under

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

public charity shouldn't file Form 990, Form 990-EZ,
or Schedule A (Form 990), but should file Form 990-PF,
Return of Private Foundation or Section 4947(a)(1) Trust
Treated as Private Foundation. See the instructions to Part I.

Accounting Method

When completing Schedule A (Form 990), the organization
must use the same accounting method it checked on Form
990, Part XII, line 1, or Form 990-EZ, line G. The organization
must use this accounting method in reporting all amounts on
Schedule A (Form 990), regardless of the accounting method
it used in completing Schedule A (Form 990) for prior years,
except that in Part V, Sections D and E, distributions must be
reported on the cash receipts and disbursements method.
Nov 14, 2023

If the accounting method the organization used in
completing the 2022 Schedule A (Form 990) was different
from the accounting method checked on the 2023 Form 990,
Part XII, line 1, or the 2023 Form 990-EZ, line G, the
organization shouldn't report in either Part II or Part III the
amounts reported in the applicable columns of the 2022
Schedule A (Form 990). Instead, the organization should
report all amounts in Part II or Part III using the accounting
method checked on the 2023 Form 990, Part XII, line 1, or the
2023 Form 990-EZ, line G.
If the organization changed its accounting method

TIP from a prior year, it should provide an explanation in

Schedule O (Form 990), Supplemental Information to
Form 990 or 990-EZ.

Example 1. An organization checks “Cash” on Form 990,
Part XII, line 1. It should report the amounts in Part II or Part III
using the cash method. If the organization filed a 2022
Schedule A (Form 990) using the cash method, it should
report in the 2019 through 2022 columns on the 2023
Schedule A (Form 990) the same amounts that it reported in
the 2019 through 2022 columns on the 2022 Schedule A
(Form 990).

Example 2. An organization checks “Accrual” on Form
990, Part XII, line 1. The organization reports grants on Form
990, Part VIII, line 1, in accordance with the Financial
Accounting Standards Board FASB ASC 958 (see the
instructions for Form 990, Part VIII, line 1). During the year,
the organization receives a grant to be paid in future years.
The organization should report the grant's present value on
the 2023 Schedule A (Form 990). The organization should
report accruals of present value increments to the unpaid
grant on Schedule A (Form 990) in future years.

Specific Instructions
Part I. Reason for Public Charity
Status
Lines 1–12 (in general)

Check only one of the boxes on lines 1 through 12 to indicate
the reason the organization is a public charity for the tax
year. The reason can be the same as stated in the
organization's tax-exempt determination letter from the IRS
(“exemption letter”) or subsequent IRS determination letter, or
it can be different. An organization that doesn't check any of
the boxes on lines 1 through 12 shouldn't file Form 990, Form
990-EZ, or Schedule A (Form 990) for the tax year, but
should file Form 990-PF instead.
If an organization believes there is more than one reason
why it is a public charity, it should check only one box but can
explain the other reasons it qualifies for public charity status
in Part VI. An organization that claims a public charity status

Cat. No. 11294Q

509(a)(3). Based on Rev. Proc. 2023-5, the organization
submitted a Form 8940 request to the IRS to change its
classification to public charity status under section 509(a)(2).
For the tax year, it meets the requirements of section 509(a)
(2). The organization received a determination letter that it
has been reclassified as a public charity under section 509(a)
(2). The organization should check the box on line 10 and
complete Part III.

other than section 170(b)(1)(A)(vi) can also demonstrate that
it qualifies under section 170(b)(1)(A)(vi) by completing Part
II; it may want to do so for purposes such as qualifying for the
first Special Rule in Schedule B (Form 990), Schedule of
Contributors, by meeting the 331/3% support test.
The IRS doesn't update its records on an organization's
public charity status based on a change the organization
makes on Schedule A (Form 990). Thus, an organization that
checks a public charity status different from the reason stated
in its exemption letter or subsequent determination letter,
although not required, may submit a request to the IRS
Exempt Organizations Determinations Office for a
determination letter confirming that it qualifies for the new
public charity status if the organization wants the IRS records
to reflect that new public charity status (also referred to as
“private foundation status”). See the Instructions for Form
8940, Request for Miscellaneous Determination. You must
complete and submit Form 8940 with payment of a user fee
through Pay.gov. The user fees are listed in Rev. Proc.
2023-5, 2023-1 I.R.B. 265 (updated annually).

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Example 5. The organization received an exemption
letter that it is a public charity under section 170(b)(1)(A)(vi).
For the tax year, it doesn't meet the requirements for public
charity status under section 170(b)(1)(A)(vi) or 509(a)(2), or
as a supporting organization under section 509(a)(3). Nor
does it meet the requirements for public charity status under
any other provision of the Internal Revenue Code. The
organization is a private foundation and shouldn't file Form
990, Form 990-EZ, or Schedule A (Form 990) for the tax year
but should file Form 990-PF instead.
Example 6. The organization received an exemption
letter that it is a supporting organization under section
509(a)(3). The letter doesn't state which type of supporting
organization it is. The organization should review the
instructions for lines 12a through 12d to determine which
type best describes the organization. The organization may
wish to file Form 8940 to request a determination of type.

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.

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.

An organization that doesn't know the public charity status
stated in its exemption letter or subsequent determination
letter should call the Exempt Organizations Customer
Account Services toll free at 877-829-5500 or write to:
Internal Revenue Service
TE/GE Customer Account Services
P.O. Box 2508
Cincinnati, OH 45201

See the following examples.
Example 1. The organization received an exemption
letter that it is a public charity under section 170(b)(1)(A)(vi).
For the tax year, it meets the requirements for public charity
status under section 170(b)(1)(A)(vi). The organization
should check the box on line 7 and complete Part II.
Example 2. The organization received an exemption
letter that it is a public charity under section
170(b)(1)(A)(vi). For the tax year, it doesn't meet the
requirements for public charity status under section
170(b)(1)(A)(vi). Instead, it meets the requirements for public
charity status under section 509(a)(2). The organization
should check the box on line 10 and complete Part III.

Line 2. Check the box for a school whose primary function
is the presentation of formal instruction, which regularly has a
faculty, a curriculum, an enrolled body of students, and a
place where educational activities are regularly conducted. A
private school must have a racially nondiscriminatory policy
toward its students. For details about these requirements,
see Schedule E (Form 990), Schools, and its related
instructions.

Example 3. The organization received an exemption
letter that it is a public charity under section 509(a)(2). For the
tax year, it doesn't meet the requirements for public charity
status under section 509(a)(2) or 170(b)(1)(A)(vi). Instead, it
meets the requirements for public charity status as a
supporting organization under section 509(a)(3). The
organization should:
1. Check the box for line 12 and either line 12a, 12b, 12c,
or 12d;
2. Complete line 12f;
3. Complete the table on line 12g; and
4. Complete Part IV and (if applicable) Part V.

An organization that checks the box on line 2 must

TIP also complete Schedule E (Form 990), Schools.

Line 3. Check the box for an organization whose main
purpose is to provide hospital or medical care. A
rehabilitation institution or an outpatient clinic can qualify as a
hospital if its principal purposes or functions are the providing
of hospital or medical care, but the term doesn't include
medical schools, medical research organizations,
convalescent homes, homes for children or the aged, or
vocational training institutions for handicapped individuals.

Example 4. The organization received an exemption
letter that it is a supporting organization under section
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Instructions for Schedule A (Form 990) 2023

Check the box on line 3 also for a cooperative hospital
service organization described in section 501(e).

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.

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

TIP Part I, is different from the definition for Schedule H

(Form 990), Hospitals. Accordingly, see Who Must
File in the Instructions for Schedule H (Form 990) about
whether the organization is also required to complete
Schedule H (Form 990).

Line 7. Check the box and complete Part II if the
organization meets one of the section 170(b)(1)(A)(vi) public
support tests. See the instructions for Part II regarding how
an organization can qualify as a publicly supported
organization under section 170(b)(1)(A)(vi).

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Line 4. Check the box for an organization whose principal
purpose or function is to engage in medical research, and
that is directly engaged in the continuous active conduct of
medical research in conjunction with a hospital. The hospital
must be described in section 501(c)(3) or operated by the
federal government, a state or its political subdivision, a U.S.
territory or its political subdivision, or the District of Columbia.
If the organization primarily gives funds to other
organizations (or grants and scholarships to individuals) for
them to do the research, the organization isn't a medical
research organization.
The organization isn't required to be an affiliate of the
hospital, but there must be a joint effort by the organization
and the hospital to maintain continuing close cooperation in
the active conduct of medical research.

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).

!

CAUTION

Line 9. Check the box if the organization is an agricultural
research organization described in section 170(b)(1)(A)(ix)
operated in conjunction with a land-grant college or university
or a non-land grant college of agriculture. Enter the name,
city, and state of the college or university. You don't have to
complete Part II.

The definition of medical research for Schedule A

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

Schedule H (Form 990), Hospitals. Accordingly,
research that is medical research for purposes of determining
whether an organization is a medical research organization
isn't necessarily medical research for Schedule H (Form 990)
reporting purposes.

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).

Assets test/expenditure test. An organization qualifies as
a medical research organization if its principal purpose is
medical research, and if it devotes more than half its assets,
or spends at least 3.5% of the fair market value of its
endowment, directly in conducting medical research. Either
test can be met based on a computation period consisting of
the immediately preceding tax year or the immediately
preceding 4 tax years.
If an organization doesn't satisfy either the assets test or
the expenditure test, it can still qualify as a medical research
organization based on the circumstances involved.
These tests are discussed in Regulations sections
1.170A-9(d)(2)(v) and (vi). Under these tests, value the
organization's assets as of any day in its tax year using the
same day every year, and value the endowment at fair market
value using commonly accepted valuation methods. See
Regulations section 2031.

Line 11. Check the box only if the organization has received
a ruling from the IRS that it is organized and operated
primarily to test for public safety.
Lines 12 and 12a–12d. If the organization is a supporting
organization, check the box for line 12 and then check the
appropriate box for line 12a, 12b, 12c, or 12d to indicate the
type of supporting organization it is. The organization must
also complete lines 12e and 12f, the table on line 12g, and
Part IV. If the organization is a Type III non-functionally
integrated supporting organization, it must also complete
Part V.
For more information about supporting organizations, see
Regulations section 1.509(a)-4 and sections 509(a)(3) and
509(f). For a brief overview of the requirements for
qualification as a supporting organization, and the different
types of supporting organizations, see Pub. 557, Tax-Exempt
Status for Your Organization, and visit IRS.gov/Charities-NonProfits/Section-509(a)(3)-Supporting-Organizations.
Use the information later to determine the supporting
organization's type. If the organization checks the box on
line 12e, the letter the organization received from the IRS
identifies its type. If the box checked on any of lines 12a
through 12d is different from the type stated in the letter (for
example, because the organization has made significant
changes to its structure or operations resulting in it no longer
qualifying as the type of supporting organization indicated in
its letter), provide an explanation in Part VI. If the organization
doesn't check the box on line 12e, it should check the box on
line 12a, 12b, 12c, or 12d that best describes the type of
supporting organization it is.

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.
Instructions for Schedule A (Form 990) 2023

A community trust claiming it qualifies as a public
charity should check the box on line 8 whether it is
structured as a corporation or as a trust.

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All supporting organizations, regardless of type, must
be responsive to the needs or demands of one or
CAUTION 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).

Line 12e. The organization's exemption letter or subsequent
determination letter may state the type of supporting
organization it is. If it does, check the box on this line. If the
letter doesn't state the type, or if the letter states Type III but
doesn't specify whether functionally integrated or
non-functionally integrated, leave this line blank.
A grantor to a section 509(a)(3) supporting organization,
acting in good faith, can rely on this letter in determining
whether the organization is a Type I, Type II, Type III
functionally integrated, or Type III non-functionally integrated
supporting organization until the IRS makes a public
announcement of the entity’s change in status. See Rev.
Proc. 2018-32, 2018-23 I.R.B. 739.

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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.

• Type I. A Type I supporting organization is operated,
supervised, or controlled by one or more publicly supported
organizations. If the organization otherwise qualifies as a
supporting organization and can answer “Yes” to the following
question, check the box for Type I.
Do the supported organizations have a substantial degree
of direction over the policies, programs, and activities of the
supporting organization, typically by ensuring that the
governing body, officers, or membership of the supported
organizations may regularly appoint or elect a majority of the
supporting organization's directors or trustees?
• Type II. A Type II supporting organization is supervised
or controlled in connection with one or more publicly
supported organizations. If the organization otherwise
qualifies as a supporting organization and can answer “Yes”
to the following question, check the box for Type II.
Do the same persons, such as directors, trustees, and
officers, supervise or control the supported organization(s)
and the supporting organization?
• Type III—Functionally integrated. Check this box if the
organization qualifies as a Type III functionally integrated
supporting organization by meeting the following
requirements.
1. The organization meets the notification requirement
described in Part IV, Section D, line 1;
2. The organization meets the responsiveness test (both
the relationship requirement and the significant voice
requirement) described in Part IV, Section D, lines 2 and 3;
and
3. The organization meets one of the alternative integral
part tests described in Part IV, Section E.
• Type III—Non-functionally integrated. Check this box if
the organization qualifies as a Type III non-functionally
integrated supporting organization by meeting the following
requirements.
1. The organization meets the notification requirement
described in Part IV, Section D, line 1;
2. The organization meets the responsiveness test (both
the relationship requirement and the significant voice
requirement) described in Part IV, Section D, lines 2 and 3;
and
3. The organization meets the integral part test by
meeting either (a) the distribution and attentiveness
requirements described in Part V, or (b) the alternative
integral part test for certain trusts in existence on November
20, 1970, described in Part V, line 1.

Line 12g. An organization checking a box on line 12a, 12b,
12c, or 12d must complete the table on line 12g.
• Columns (i) and (ii). Enter the name and employer
identification number (EIN) for each supported
organization counted on line 12f. If the organization had
more than five supported organizations during the tax year,
enter the additional organizations on duplicate pages of
Schedule A (Form 990), Part I. Use as many duplicate copies
as needed, and number each page.
• Column (iii). For each supported organization named in
column (i), enter the line number (from lines 1 through 10
above) that best describes the foundation status of the
supported organization.
Example 1. If the supported organization is a hospital,
then that is an organization described in section 170(b)(1)(A)
(iii), and you should enter “3” in column (iii).
Example 2. If the supported organization is a federal,
state, or local governmental unit, or foreign government, then
that is an organization described in section 170(b)(1)(A)(v),
and you should enter “6” in column (iii).

Example 3. If the supported organization is exempt under
section 501(c)(4), 501(c)(5), or 501(c)(6), but can be
supported by a supporting organization (see Regulations
section 1.509(a)-4(k)), enter the line number (from lines 1
through 10 above) that would describe the section 501(c)(4),
501(c)(5), or 501(c)(6) organization if it were a section 501(c)
(3) organization. Identify the specific code section (501(c)(4),
501(c)(5), or 501(c)(6)) for each such supported organization
in Part VI.

!

CAUTION

The only correct entry in column (iii) is a line number
(from lines 1 through 10) that corresponds to the
description of the supported organization.

• Column (iv). Check “Yes” if the supported organization
named in column (i) is specifically named as a supported
organization in the organization's declaration of trust, articles
of incorporation, or other governing document. If the
supported organization is not named in the organizing
documents, check “No” and explain why in Part VI.
• Column (v). Enter the total amount of monetary support
paid to, or for the benefit of, the supported organization
named in column (i) during the tax year. Such monetary
support may include making payments to or for the use of
individual members of the charitable class benefited by the
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Instructions for Schedule A (Form 990) 2023

admissions, merchandise, services, or the use of facilities in
a related activity, report the membership fees on line 12. To
the extent that the membership fees are payments to
purchase admissions, merchandise, services, or the use of
facilities in an unrelated business activity, report the
membership fees on line 9. See Regulations section
1.170A-9(f)(7)(iv). Include qualified sponsorship payments
under section 513(i).
Noncash contributions. Use any reasonable method to
determine the value of noncash contributions reported on
line 1.
Don't report any donations of services (such as the value
of donated advertising space or broadcast air time) or
donations of use of materials, equipment, or facilities, on
line 1 as gifts, grants, or contributions. Donated services and
facilities from a governmental unit only are reported on
line 3.
Loss on uncollectible pledge. If an organization records
a loss on an uncollectible pledge that it reported on a prior
year's Schedule A (Form 990), it should deduct that loss from
the contribution amount for the year in which it originally
counted that contribution as revenue. For example, if in the
prior tax year the organization reported a pledged
contribution with a then-present value of $50,000 in Part II,
line 1, column (e), but learned during the current tax year that
it wouldn't receive any of that pledged contribution, it should
deduct the $50,000 from the amount reported in Part II,
line 1, column (d), for the prior tax year.
Support from a governmental unit. Include on line 1
support received from a governmental unit. This includes
contributions, but not gross receipts from exercising or
performing the organization's tax-exempt purpose or
function, which should be reported on line 12. An amount
received from a governmental unit is treated as gross
receipts from exercising or performing the organization's
tax-exempt purpose or function if the purpose of the payment
is primarily to serve the direct and immediate needs of the
payor governmental unit, and is treated as a contribution, if
the purpose is primarily to provide a direct benefit to the
public. For example, a payment to maintain library facilities
that are open to the public should be treated as a
contribution. See Regulations section 1.170A-9(f)(8) and
Rev. Rul. 81-276, 1981-2 C.B. 128. Refer to the instructions
for Form 990, Part VIII, lines 1e and 2, for more examples
addressing the distinction between government payments
that are contributions and government payments that are
gross receipts from activities related to the organization's
tax-exempt purpose or function. Medicare and Medicaid
payments are treated as gross receipts from patients rather
than as contributions from the government payor for
purposes of the public support test. See Rev. Rul. 83-153,
1983-2 C.B. 48.

supported organization (such as scholarships), and to 501(c)
(3) public charities operated, supervised, or controlled
directly by or in connection with the supported organization.
See Regulations section 1.509(a)-4(e). If no monetary
support was provided during the tax year, enter “0”.
• Column (vi). In this column, the organization may (but
isn't required to) provide an estimate of the fair market value
of goods, other property, services, and use of facilities that is
provided to or for the benefit of the supported organizations
during the tax year. Describe in Part VI any such goods, other
property, services, and use of facilities, whether or not an
amount is reported for them in column (vi).

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

If the organization checked a box in Part I, on line 5,
7, or 8, it should complete Part II and insert the
CAUTION appropriate dollar amounts. Don't leave Part II blank
or report only zeros if the organization had any support during
the period. If the organization checks the box in Part II, on
line 13, it should stop there and not complete the rest of Part
II.

!

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

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

the organization should complete Part III to determine
if it qualifies as a publicly supported organization under
section 509(a)(2). If it does qualify, the organization should
instead check the box in Part I, on line 10.

Public Support Test. For an organization to qualify as a
publicly supported organization under section 170(b)(1)(A)
(vi), either:
• 331/3% or more of its total support must come from
governmental units, contributions from the general public,
and contributions or grants from other public charities; or
• 10% or more of its total support must come from
governmental units, contributions from the general public,
and contributions or grants from other public charities and the
facts and circumstances indicate it is a publicly supported
organization.
Note. An organization won't meet either of these public
support tests if almost all of its support comes from gross
receipts from related activities and an insignificant amount of
its support comes from governmental units and
contributions made directly or indirectly by the general
public.
Public support is measured using a 5-year computation
period that includes the current and 4 prior tax years
(including short years). If the organization's current tax year
or any of its 4 prior tax years were short years, explain in Part
VI.
If the organization wasn't a section 501(c)(3) organization
for the entire 5-year period in Part II, report amounts only for
the years the organization was a section 501(c)(3)
organization.

The Coronavirus Aid, Relief, and Economic Security

TIP Act (CARES Act) established the Paycheck

Protection Program (PPP) to provide loans to small
businesses as a direct incentive to keep their workers on the
payroll. The loans are forgiven if all employee retention
criteria are met and the funds are used for eligible expenses.
Amounts of PPP loans that are forgiven may be reported on
line 1 as contributions from a governmental unit in the tax
year when the amounts are forgiven or at such other time as
provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.

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
Instructions for Schedule A (Form 990) 2023

Unusual grants. Unusual grants are generally substantial
contributions and bequests from disinterested persons and
are:
-5-

revenue or assets on Form 990-EZ, explain in Part VI the
basis for characterizing such transfers as contributions but
not as revenue or assets. For example, if an organization is a
community foundation that receives and holds a cash transfer
for another tax-exempt organization and reports contributions
of such property on Schedule A (Form 990), Part II, line 1,
without reporting it on Form 990 as revenue in Part VIII or
assets in Part X, explain the basis for characterizing the
property as contributions but not as revenue or assets.

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).

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!

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.

Don't include the names of the grantors because Part
VI will be made available for public inspection.

CAUTION

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.

!

CAUTION

Line 5. Enter in column (f) the portion of total contributions
by each individual, trust, or corporation included on line 1 for
the years reported that exceeds 2% of the amount reported in
line 11, column (f). In applying the 2% limitation, all
contributions made by a donor and by any person or persons
standing in a relationship to the donor that is described in
sections 4946(a)(1)(C) through (a)(1)(G) and the related
regulations (for example, spouses and certain other family
members, and entities where ownership or control interests
exceed a threshold level) will be treated as made by one
person. However, the 2% limitation doesn't apply to
contributions from organizations qualifying as publicly
supported organizations under section 170(b)(1)(A)(vi),
governmental units described in section 170(b)(1)(A)(v), and
other organizations, such as the following, but only if they
also qualify as publicly supported organizations under
section 170(b)(1)(A)(vi).
• Churches described in section 170(b)(1)(A)(i),
• Educational institutions described in section 170(b)(1)(A)
(ii),
• Hospitals described in section 170(b)(1)(A)(iii),
• Organizations operated for the benefit of a college or
university owned or operated by a governmental unit
described in section 170(b)(1)(A)(iv), and
• Agricultural research organizations described in section
170(b)(1)(A)(ix).
The organization should keep for its records a list showing
the name of and amount contributed by each donor (other
than a governmental unit or publicly supported
organization) whose total gifts during the years reported
exceed 2% of the amount reported in line 11, column (f). An
example of this list is given later.

Don't file this list with the organization's Form 990 or
990-EZ because it may be made available for public
inspection.

Line 1. Example—List of unusual grants

▶ 2023
Name ▶ Mr. Distinguished Donor
Date of Grant ▶ January 15,
Year

2023
Amount of Grant

Description
Undeveloped land

▶ $600,000

Conservation easements and qualified conservation
contributions. The organization must report any qualified
conservation contributions and contributions of conservation
easements consistently with how it reports revenue from
such contributions in its books, records, and financial
statements and in Form 990, Part VIII, Statement of Revenue.
Reporting contributions not reported as revenue. If the
organization reports any contributions on line 1 of
Schedule A (Form 990), Part I, that it doesn't report on Form
990 as revenue in Part VIII or as assets in Part X, or as

!

CAUTION

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Don't file this list with the organization's Form 990 or
990-EZ because it may be made available for public
inspection.

Instructions for Schedule A (Form 990) 2023

Line 5. Example—List of donors other than governmental units and publicly supported organizations
Assumption: 2% of the amount on Schedule A (Form 990), Part II, line 11, column (f), is $12,000.
Contributors whose total gifts from 2018 through 2022 were in excess of the 2% limitation
Name

(a)

(b)

(c)

(d)

(e)

(f)

(g)

2019

2020

2021

2022

2023

Total

Excess
contributions
(column (f)
minus the 2%
limitation)

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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 . . . . . . . . . . . . . . . . . . . . . . . . . . . .

• 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 8. Include the gross income from interest, dividends,
payments with respect to securities loans (section 512(a)(5)),
rents, royalties, and income from similar sources. Don't
include on this line payments that result from activities of the
organization that further its exempt purpose. Instead, report
these amounts on line 12.
Line 9. Enter the organization's net income from conducting
unrelated business activities, whether or not the activities
are regularly conducted as a trade or business. See sections
512 and 513 and the applicable regulations. Include
membership fees to the extent they are payments to
purchase admissions, merchandise, services, or the use of
facilities in an activity that is an unrelated business.
When calculating unrelated business taxable income
(UBTI) for this purpose, an exempt organization with more
than one unrelated trade or business may use either its UBTI
calculated under section 512(a)(6) or its UBTI calculated in
the aggregate. If a net loss results, enter “0” on this line.

Line 10. Include all support as defined in section 509(d) that
isn't included elsewhere in Part II. Explain in Part VI the
nature and source of each amount reported. Don't include
gain or loss from amounts reportable on line 12 or from the
sale of capital assets.

Line 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.

Line 12. Enter the total amount of gross receipts the
organization received from related activities for all years
reported in Part II. The organization won't be treated as
meeting the section 170(b)(1)(A)(vi), 331/3% public support
test or the 10%-facts-and-circumstances public support test,
if almost all of its support consists of gross receipts from
related activities and an insignificant amount of its support
comes from governmental units and public contributions.
See Regulations section 1.170A-9(f)(7)(iii).
Include on line 12 gross receipts from admissions, sales of
merchandise, performance of services, or furnishing of
facilities in any activity which isn't an unrelated trade or
business (within the meaning of section 513). See section
509(d)(2). Include membership fees to the extent they are
payments to purchase admissions, merchandise, services, or
the use of facilities in a related activity. For example, include
on this line gross receipts from:
Instructions for Schedule A (Form 990) 2023

$127,000

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.

-7-

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

Line 18. If the organization didn't check a box on line 13,
16a, 16b, 17a, or 17b, it doesn't qualify as a publicly
supported organization under section 170(b)(1)(A)(iv) or
170(b)(1)(A)(vi) for the 2023 tax year and should check the
box on this line. If the organization doesn't qualify as a public
charity under any of the boxes in Part I, lines 1 through 12, it
is a private foundation as of the beginning of the 2023 tax
year for filing purposes and shouldn't file Form 990, Form
990-EZ, or Schedule A (Form 990) for the 2023 tax year.
Instead, the organization should file Form 990-PF and check
Initial return of a former public charity on Form 990-PF, at the
top of page 1.

TIP (3) organization should make the public support

computations on a copy of Schedule A (Form 990)
that it keeps for itself. An organization should carefully
monitor its public support on an ongoing basis to ensure that
it will meet a public support test in the sixth year and
succeeding years.

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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.

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

Line 15. For 2023, enter the public support percentage from
the 2022 Schedule A (Form 990), Part II, line 14. Round to
the nearest hundredth decimal point in reporting the
percentage of public support.

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

organization should figure the public support
percentage on its Form 990 or 990-EZ for its first 5 tax years
before it checks the box on line 18. If its public support
percentage for its first 5 tax years is 331/3% or more, or if it
meets the 10%-facts-and-circumstances test for its first 5 tax
years, it will qualify as a public charity for its sixth tax year. If
the organization qualifies under the 10% test, explain in Part
VI.

Line 16a. If the organization didn't check the box on line 13,
and line 14 is 331/3% or more, check the box on this line
and don't complete the rest of Part II. The organization
qualifies as a publicly supported organization for 2023 and
2024.

Line 16b. If the organization didn't check a box on line 13 or
16a, and line 15 is 331/3% or more, check the box on this
line and don't complete the rest of Part II. The
organization qualifies as a publicly supported organization for
2023.

If the organization doesn't qualify as a publicly

TIP 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)

Line 17a. If the organization didn't check a box on line 13,
16a, or 16b, and line 14 is 10% or more, and if the
organization meets the facts-and-circumstances test, check
the box on this line and don't complete the rest of Part
II. The organization qualifies as a publicly supported
organization for 2023 and 2024.
If this box is checked, explain in Part VI how the
organization meets the facts-and-circumstances test in
Regulations section 1.170A-9(f)(3). Include the following
information.
• Explain whether the organization maintains a continuous
and bona fide program for solicitation of funds from the
general public, community, membership group involved,
governmental units, or other public charities.
• List all other facts and circumstances, including the
sources of support, whether the organization has a
governing body that represents the broad interests of the
public, and whether the organization generally provides
facilities or services directly for the benefit of the general
public on a continuing basis.
• If the organization is a membership organization, explain
whether the solicitation for dues-paying members is designed
to enroll a substantial number of persons from the
community, whether dues for individual members have been
fixed at rates designed to make membership available to a
broad cross-section of the interested public, and whether the
activities of the organization will likely appeal to persons
having some broad common interest or purpose.

If an organization checked the box in Part I, for

TIP line 10, it should complete Part III and insert the

appropriate dollar amounts. Don't leave Part III blank
or report only zeros if the organization had any support during
the period. If the organization checks the box in Part III, for
line 14, it should stop there and not complete the rest of Part
III.
If the organization checked the box in Part I, for

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

the organization should complete Part II to determine
if it qualifies as a publicly supported organization under
section 170(b)(1)(A)(vi). If it does qualify, the organization
should instead check the box in Part I, for line 5, 7, or 8,
whichever applies.
Public Support Test. For an organization to qualify as a
publicly supported organization under section 509(a)(2):
• More than 331/3% of its support normally must come from
gifts, grants, contributions, membership fees, and gross
receipts from admissions, sales of merchandise,
performance of services, or furnishing of facilities in an
activity which isn't an unrelated trade or business under
section 513; and
• No more than 331/3% of its support normally must come
from gross investment income and net unrelated business
income (less section 511 tax) from businesses acquired by
the organization after June 30, 1975.
Public support is measured using a 5-year computation
period that includes the current and 4 prior tax years
(including short years). If the organization's current tax year
or any of its 4 prior tax years were short years, explain in Part
VI.

Line 17b. If the organization didn't check a box on line 13,
16a, 16b, or 17a, and line 15 is 10% or more, and if the
organization meets the facts-and-circumstances test, check
the box on this line and don't complete the rest of Part
II. The organization qualifies as a publicly supported
organization for 2023. If this box is checked, explain in Part VI
how the organization meets the facts-and-circumstances test
in Regulations section 1.170A-9(f)(3). Include the same
information identified in the instructions for Line 17a, earlier.
-8-

Instructions for Schedule A (Form 990) 2023

than as contributions from the government payor for
purposes of the public support test. See Rev. Rul. 83-153,
1983-2 C.B. 48.

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.

The Coronavirus Aid, Relief, and Economic Security

Line 1. Don't include any “unusual grants.” See Unusual
grants, later. Include membership fees only to the extent to
which the fees are payments to provide support for the
organization rather than to purchase admissions,
merchandise, services, or the use of facilities. To the extent
that the membership fees are payments to purchase
admissions, merchandise, services, or the use of facilities in
a related activity, include the membership fees on line 2. See
Regulations section 1.509(a)-3(h). To the extent that the
membership fees are payments to purchase admissions,
merchandise, services, or the use of facilities in an activity
that isn't an unrelated business under section 513, report
the membership fees on line 3. To the extent that the
membership fees are payments to purchase admissions,
merchandise, services, or the use of facilities in an activity
that is an unrelated business, report the net amount either on
line 10b or 11, as appropriate.
Noncash contributions. Use any reasonable method to
determine the value of noncash contributions reported on
line 1.
Don't report any donations of services (such as the value
of donated advertising space or broadcast air time) or
donations of use of materials, equipment, or facilities on
line 1 as gifts, grants, or contributions. Donated services and
facilities from a governmental unit are reported on line 5.
Loss on uncollectible pledge. If an organization records
a loss on an uncollectible pledge that it reported on a prior
year's Schedule A (Form 990), it should deduct that loss from
the contribution amount for the year in which it originally
counted that contribution as revenue. For example, if in the
prior tax year the organization reported a pledged
contribution with a then-present value of $50,000 in Part III,
line 1, column (e), but learned during the current tax year that
it wouldn't receive any of that pledged contribution, it should
deduct the $50,000 from the amount reported in Part III,
line 1, column (d), for the prior tax year.
Support from a governmental unit. Include on line 1
support received from a governmental unit. This includes
contributions, but not gross receipts from exercising or
performing the organization's tax-exempt purpose or
function, which should be reported on line 2. Contributions
are sometimes difficult to distinguish from such gross
receipts—the label on the agreement isn't controlling. An
amount received from a governmental unit is treated as gross
receipts from exercising or performing the organization's
tax-exempt purpose or function if the purpose of the payment
is primarily to serve the direct and immediate needs of the
payor governmental unit. An amount is treated as a
contribution if the purpose of the payment is primarily to
provide a direct benefit to the public. For example, if a state
government agency pays an organization to operate an
institute to train agency employees in the principles of
management and administration, the funds received should
be included on line 2 as gross receipts. See Regulations
section 1.509(a)-3(g). Refer to the instructions for Form 990,
Part VIII, lines 1e and 2, for more examples addressing the
distinction between government payments that are
contributions and government payments that are gross
receipts from activities related to the organization's
tax-exempt purpose or function. Medicare and Medicaid
payments are treated as gross receipts from patients rather

TIP Act (CARES Act) established the Paycheck

Protection Program (PPP) to provide loans to small
businesses as a direct incentive to keep their workers on the
payroll. The loans are forgiven if all employee retention
criteria are met and the funds are used for eligible expenses.
Amounts of PPP loans that are forgiven may be reported on
line 1 as contributions from a governmental unit in the tax
year when the amounts are forgiven or at such other time as
provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.

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Instructions for Schedule A (Form 990) 2023

Unusual grants. Unusual grants are generally substantial
contributions and bequests from disinterested persons and
are:
1. Attracted because of the organization's publicly
supported nature,
2. Unusual and unexpected because of the amount, and
3. Large enough to endanger the organization's status as
normally meeting the 331/3% public support test.

For a list of other factors to be considered in determining
whether a grant is an unusual grant, see Regulations section
1.509(a)-3(c)(4).
An unusual grant is excluded even if the organization
receives or accrues the funds over a period of years.
Don't report gross investment income items as unusual
grants. Instead, include all investment income on line 10a.
See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations
section 1.170A-9(f)(6)(ii); and Regulations sections
1.509(a)-3(c)(3) and (4) for details about unusual grants.
Include in Part VI a list showing the amount, but not the
grantor, of each unusual grant actually received each year (if
the cash accounting method is used) or accrued each year (if
the accrual accounting method is used).

!

Don't include the names of the grantors because Part
VI will be made available for public inspection.

CAUTION

Unusual grants recordkeeping. An organization that
received any unusual grants during the 5-year period, should
also keep for its records a list showing, for each year, the
name of the contributor, the date and amount of the grant,
and a brief description of the grant. If the organization used
the cash method for the applicable year, show only amounts
the organization actually received during that year. If the
organization used the accrual method for the applicable year,
show only amounts the organization accrued for that year. An
example of this list is given below.

!

CAUTION

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Don't file this list with the organization's Form 990 or
990-EZ because it may be made available for public
inspection.

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

(a) 2019

(b) 2020

$7,000

$6,000

Anne Parker
Total

$7,000

$6,000

(c) 2021

(d) 2022

$5,000

$7,000

$5,000

$7,000

(e) 2023

(f) Total

$2,000

$15,000

$4,000

$16,000

$6,000

$31,000

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• 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 1. Example—List of unusual grants

▶ 2023
Name ▶ Mr. Distinguished Donor
Date of Grant ▶ January 15,
Year

2023

Amount of Grant

Description

Undeveloped land

▶ $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.

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.

Reporting contributions not reported as revenue. If the
organization reports any contributions on Schedule A (Form
990), Part III, line 1, that it doesn't report on Form 990, as
revenue in Part VIII or as assets in Part X, or as revenue or
assets on Form 990-EZ, explain in Part VI the basis for
characterizing such transfers as contributions but not as
revenue or assets. For example, if an organization is a
community foundation that receives and holds a cash transfer
for another tax-exempt organization and reports contributions
of such property on Schedule A (Form 990), Part III, line 1,
without reporting it on Form 990, as revenue in Part VIII or
assets in Part X, explain the basis for characterizing the
property as contributions but not as revenue or assets.

Line 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 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 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.

Line 3. Include gross receipts from activities that aren't an
unrelated trade or business under section 513, such as:
• A trade or business in which substantially all work is
performed by volunteers (such as book fairs and sales of gift
wrap paper). See section 513(a)(1).
• A trade or business carried on by the organization primarily
for the convenience of its members, students, patients,
officers, or employees. See section 513(a)(2).
• A trade or business that is the selling of merchandise,
substantially all of which the organization received as gifts or
contributions. See section 513(a)(3).
• “Qualified public entertainment activities” or “qualified
convention and trade show activities” of certain
organizations. See section 513(d).
• Furnishing certain hospital services. See section 513(e).

!

CAUTION

Don't file this list with the organization's Form 990 or
990-EZ because it may be made available for public
inspection.

Line 7b. For any gross receipts included on lines 2 and 3
from related activities received from a person or from a
bureau or similar agency of a governmental unit, other than
from a disqualified person, that exceed the greater of
$5,000 or 1% of the amount on line 13 for the applicable year,
enter the excess on line 7b. The organization should keep for
its records a list showing, for each year, the name of the
person or government agency, the amount received during
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Instructions for Schedule A (Form 990) 2023

Line 7b. Example—List of amounts received from other than disqualified persons
Year 2023
(a) Name

Word Processing, Inc.

(b) Amount received in
2023

(c) 1% of amount on
line 13 in 2023

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

(e) 2023 excess
(column (b) minus
column (d))

$25,000

$2,000

$5,000

$20,000

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Enter on Schedule A (Form 990), column (e), line 7b

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

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.

!

CAUTION

Example. An organization receives an exemption letter
from the IRS that it is exempt from tax under section
501(c)(3) and qualifies as a public charity under section
509(a)(2) effective on its date of incorporation. When the
organization prepares Part III for its first 5 tax years, it should
check the box on line 14 and shouldn't complete the rest of
Part III. When the organization prepares Part III for its sixth
tax year and subsequent years, it shouldn't check the box on
line 14 and should complete the rest of Part III.

Don't file this list with the organization's Form 990 or
990-EZ because it may be made available for public
inspection.

Line 10a. Include the gross income from interest, dividends,
payments received on securities loans (section 512(a)(5)),
rents, royalties, and income from similar sources. Don't
include on this line payments that result from activities of the
organization that further its exempt purpose. Instead, report
these amounts on line 2.

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

TIP (3) organization should make the public support and

investment income computations on a copy of
Schedule A (Form 990) that it keeps for itself. An organization
should carefully monitor its public support on an ongoing
basis to ensure that it will meet the public support tests in the
sixth year and succeeding years.

Line 10b. Enter the excess of the organization's unrelated
business taxable income (UBTI) (as defined in section
512) from trades or businesses that it acquired or
commenced after June 30, 1975, over the amount of tax
imposed on this income under section 511. Include
membership fees to the extent they are payments to
purchase admissions, merchandise, services, or the use of
facilities in an unrelated business activity that is a trade or
business that was acquired or commenced after June 30,
1975.
When calculating UBTI for this purpose, an exempt
organization with more than one unrelated trade or business
may use either its UBTI calculated under section 512(a)(6) or
its UBTI calculated in the aggregate.

Line 15. Round to the nearest hundredth decimal point in
reporting the percentage of public support. For example, if
the organization calculates its public support percentage as
58.3456%, this percentage would be rounded to 58.35%
when reported on line 15.

Line 16. For 2023, enter the public support percentage from
2022 Schedule A (Form 990), Part III, line 15. Round to the
nearest hundredth decimal point in reporting the percentage
of public support.
Line 17. Round to the nearest whole percentage.
Line 18. For 2023, enter the investment income percentage
from the 2022 Schedule A (Form 990), Part III, line 17. Round
to the nearest whole percentage.

Line 11. Enter the organization's net income from
conducting unrelated business activities not included on
line 10b, whether or not the activities are regularly conducted
as a trade or business. Don't include net income from
conducting trades or businesses acquired or commenced by
the organization prior to July 1, 1975. See sections 512, 513,
and 514, and the applicable regulations. Include membership
fees to the extent they are payments to purchase admissions,
merchandise, services, or the use of facilities in an activity
that is an unrelated business not included on line 10b.
When calculating UBTI for this purpose, an exempt
organization with more than one unrelated trade or business
may use either its UBTI calculated under section 512(a)(6) or
its UBTI calculated in the aggregate. If a net loss results,
enter “0” on this line.

Line 19a. If the organization didn't check the box on line 14,
line 15 is more than 331/3%, and line 17 isn't more than
331/3%, check the box on this line and don't complete
the rest of this schedule. The organization qualifies as a
publicly supported organization for 2023 and 2024.
Line 19b. If the organization didn't check the box on line 14
or 19a, line 16 is more than 331/3%, and line 18 isn't more
than 331/3%, check the box on this line and don't
complete the rest of this schedule. The organization
qualifies as a publicly supported organization for 2023.
Line 20. If the organization didn't check the box on line 14,
19a, or 19b, it doesn't qualify as a publicly supported
organization under section 509(a)(2) for the 2023 tax year
and should check the box on this line. If the organization
doesn't qualify as a public charity under any of the boxes on
Schedule A (Form 990), Part I, lines 1 through 12, it is a
private foundation for filing purposes as of the beginning of
the tax year and shouldn't file Form 990, Form 990-EZ, or
Schedule A (Form 990) for the 2023 tax year. Instead, the
organization should file Form 990-PF, and check Initial return
of a former public charity on Form 990-PF, at the top of
page 1.

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.
Instructions for Schedule A (Form 990) 2023

$20,000

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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.

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

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

checked the box on line 20, it should figure the public
support percentage and the investment income percentage
on its Form 990 for its first 5 tax years. If its public support
percentage for its first 5 tax years is more than 331/3% and
the investment income percentage for its first 5 tax years isn't
more than 331/3%, it will qualify as a public charity for its sixth
tax year. If the organization qualifies in this manner, explain in
Part VI.

Line 3b. If the organization confirmed that the supported
organization qualified under section 501(c)(4), (5), or (6) and
met the section 509(a)(2) public support test for its most
recent tax year, check “Yes” and describe in Part VI how the
organization made this determination. For example, the
organization may ask its section 501(c)(4), (5), or (6)
supported organization to furnish a copy of its IRS
determination letter and to complete annually a pro forma
Schedule A (Form 990), Part III, and keep the letter and
support calculation in the supporting organization’s files.
If the supporting organization doesn't annually confirm that
its supported organization satisfies the section 509(a)(2)
public support test, it must explain in Part VI how it knows that
the supported organization would’ve been described in
section 509(a)(2) if it were described in section 501(c)(3)
during the tax year.

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If the organization doesn't qualify as a publicly

TIP 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.

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.

Section A. All Supporting Organizations

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.

Line 1. The organization's articles of incorporation or trust
instrument must designate the publicly supported
organization(s) on whose behalf the supporting organization
is operated. The articles of a Type I or Type II supporting
organization may designate its supported organization(s)
either by class or purpose or by name. The articles of a Type
III supporting organization must designate the supported
organization(s) by name, unless a historic and continuing
relationship exists between the organizations.
Check “Yes” only if the organization supports no
organization other than those listed by name in its governing
instrument. If the organization supports any organization not
specifically listed, check “No” and describe in Part VI how the
supported organizations are designated. If designated by
class or purpose, describe the class or purpose. If the
organization and its supported organization(s) have a historic
and continuing relationship, explain that relationship. If
support of one or more organizations is subject to certain
future contingencies, explain those contingencies, and
explain what organizations will be supported or benefited if
those contingencies occur.

Lines 4b and 4c. A supporting organization must exercise
control and discretion over funds granted to an organization
that isn't exempt under section 501(c)(3). See Rev. Rul.
68-489, 1968-2 C.B. 210. Also, a domestic charity must
generally exercise control and discretion over funds granted
to a foreign organization. See Rev. Rul. 63-252, 1963-2 C.B.
101, and Rev. Rul. 66-79, 1966-1 C.B. 48.
Explain in Part VI how the organization retained such
control and discretion despite being controlled or supervised
by or in connection with such foreign supported
organization(s). Also, explain what controls the organization
used to ensure that all support to the foreign supported
organization(s) was used exclusively for charitable,
educational, etc., purposes described in section 170(c)(2)(B)
if the foreign supported organization doesn't have an IRS
determination under sections 501(c)(3) and 509(a)(1) or (2).

Line 5. Supporting organizations may add, substitute, or
remove supported organizations only in certain limited
situations. See Regulations section 1.509(a)-4(d). Generally,
a Type I or Type II supporting organization may add or
substitute particular supported organizations within the class
or classes designated in its articles, but may not add or
substitute supported organizations outside of the designated
class(es). A Type III supporting organization, which must
specify its supported organizations by name, may only
substitute supported organizations if such substitution is
conditioned upon the occurrence of an event that is beyond
the control of the supporting organization (such as a
supported organization’s lapse into private foundation
status).
If the organization has added, substituted, or removed any
supported organization during the tax year, check “Yes” and
provide detail in Part VI, including (i) the names and EINs of

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
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Instructions for Schedule A (Form 990) 2023

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).

the organizations added, substituted, or removed; (ii) the
reasons for each addition, substitution, or removal; (iii) the
authority under the organization’s organizing document for
each addition, substitution, or removal; and (iv) an
explanation of how the action was accomplished (such as by
amendment to the organizing document substituting a new
supported organization).

Section B. Type I Supporting Organizations
Line 1. A Type I supporting organization must be operated,
supervised, or controlled by one or more of its supported
organizations (the “controlling supported organizations”).
This means that the controlling supported organizations must
have a substantial degree of direction over the policies,
programs, and activities of the supporting organization, and
the supporting organization in turn must be responsive to the
needs or demands of the controlling supported
organizations, and must constitute an integral part of, or
maintain a significant involvement in, the operations of the
controlling supported organizations. This relationship is most
clearly established when one or more supported
organizations (through their officers, directors, trustees, or
membership) have the unconditional power to remove and
replace at least a majority of the supporting organization’s
directors or trustees at any time. The relationship is also
commonly established when one or more supported
organizations have the power to appoint or elect at least a
majority of the supporting organization’s directors or trustees
at regular intervals. However, there may be other ways to
establish this relationship. If the organization relies on other
ways to establish the relationship, check “No” and describe in
Part VI how the necessary relationship is established.

Line 6. A supporting organization must engage solely in
activities that support or benefit its supported organization(s).
In addition to making grants and providing services and
facilities directly to its supported organization(s), a supporting
organization may also generally make grants or provide
services or facilities to (1) individual members of the
charitable class benefited by its supported organization(s), or
(2) other supporting organizations that also support or benefit
its supported organization(s). See Regulations section
1.509(a)-4(e). If the organization made any grants or
provided any benefits to any other organization or individual,
check “Yes” and provide detail in Part VI.

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Lines 7 and 8. Under section 4958(c)(3), any grant, loan,
compensation, or other similar payment provided by a
supporting organization to a substantial contributor (defined
in section 4958(c)(3)(C)), to a family member (defined in
section 4958(f)(4)), and to a 35% controlled entity of such
persons, is considered a per se excess benefit in its entirety,
regardless of the fairness or reasonableness of the payment,
and is subject to tax under section 4958(a). The same is true
of any loan by a supporting organization to a disqualified
person under section 4958 (other than loans to certain
exempt organizations). If the organization made any such
payment or loan during the tax year, check “Yes” and report
the transaction on Schedule L (Form 990), Transactions With
Interested Persons, Part I. For more information on excess
benefit transactions generally, see the Instructions for
Schedule L (Form 990).

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

Section C. Type II Supporting Organizations

Line 1. A Type II supporting organization must be
supervised or controlled in connection with its supported
organization(s). This means that there must be common
supervision or control by the persons supervising or
controlling both the supporting organization and the
supported organization(s) to ensure that the supporting
organization will be responsive to the needs and
requirements of the supported organization(s). This
relationship is most clearly established when the same
persons serve as all or a majority of the directors or trustees
of all of the organizations involved. However, there may be
other ways to establish this relationship. If the organization
relies on other than overlap of at least a majority of directors
or trustees of all organizations involved, check “No” and
describe in Part VI how the necessary relationship is
established.

Line 9. A supporting organization may not be controlled by
disqualified persons, as defined in section 4946. Section
509(a)(1) or (2) organizations, and foundation managers who
are disqualified persons only as a result of being foundation
managers, aren't treated as disqualified persons for this
purpose. Impermissible control may be direct or indirect. If a
disqualified person holds any of the interests described on
line 9b or 9c, or derives personal benefit from any such
assets, provide detail in Part VI.
Line 10. Under section 4943(f), a Type II supporting
organization that accepts a contribution from a person who
controls the governing body of a supported organization (or
from a family member of such person, or from a 35%
controlled entity of such person) is subject to the excess
business holdings tax under section 4943. All Type III
non-functionally integrated supporting organizations are also
generally subject to the tax. For more information about
excess business holdings, see the Instructions for Form
4720, Return of Certain Excise Taxes Under Chapters 41 and
42 of the Internal Revenue Code.

Section D. All Type III Supporting Organizations
Line 1. A Type III supporting organization must supply
annually a written notice, addressed to a principal officer of
each supported organization, which includes the following.
1. A description of the type and amount of all support the
supporting organization provided to the supported
organization during the supporting organization’s tax year
preceding the tax year in which the notice is provided.
2. A copy of the supporting organization’s most recently
filed Form 990 (the supporting organization may redact the
names and addresses of contributors).
3. A copy of the supporting organization’s updated
governing documents (including articles of organization,

Line 11. Section 509(f)(2) prohibits Type I and Type III
supporting organizations from accepting a gift or contribution
from certain persons associated with a supported
organization of such supporting organization. Specifically, if a
Type I or Type III supporting organization accepts a
contribution after August 16, 2006, from a person who
controls the governing body of a supported organization (or
from a family member of such person, or from a 35%
controlled entity of such person), then the supporting
Instructions for Schedule A (Form 990) 2023

-13-

Support of governmental entity. A Type III supporting
organization meets the integral part test for a functionally
integrated supporting organization if it (1) supports at least
one supported organization that is a governmental entity to
which the supporting organization is responsive (as
discussed in the instructions for Section D, Lines 2 and 3,
earlier), and (2) engages in activities for or on behalf of such
governmental supported organization that performs the
functions or carries out the purposes of such governmental
supported organization and that, but for the involvement of
the supporting organization, would normally be engaged in
by the governmental supported organization itself. See
Notice 2014-4. A Type III supporting organization that claims
to meet the integral part test for a functionally integrated
supporting organization by supporting a governmental entity
must describe in Part VI how it met these requirements for the
tax year.

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.

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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).

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.

In the case of a supporting organization that supported a
supported organization before November 20, 1970,
additional facts and circumstances such as a historic and
continuing relationship between the organizations may also
be taken into account in considering the responsiveness test.
If the organization has an adequate relationship with at
least one supported organization only by means of a “close
and continuous working relationship” or a “historic and
continuing relationship,” then in Part VI explain the
relationship and how it has been maintained. Also, all Type III
supporting organizations that claim to meet the significant
voice test must describe in Part VI the voice or role of the
supported organization(s) in directing the supporting
organization’s use of its income or assets.

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.

Section E. Type III Functionally Integrated
Supporting Organizations
Line 1. A Type III supporting organization must constitute an
integral part of one or more of its supported organizations by
maintaining significant involvement in its operations and
providing support on which the supported organization is
dependent. To satisfy this requirement as a Type III
functionally integrated supporting organization, an
organization may (a) pass an Activities Test (see the
instructions for Line 2, later), (b) be the parent of its
supported organizations (see the instructions for Line 3,
later), or (c) support one or more governmental entities (see
Support of governmental entity, later). If the organization
can't satisfy any of these tests, it may still qualify as a Type III
non-functionally integrated supporting organization (see Part
V, later).

Part V. Type III Non-Functionally
Integrated 509(a)(3) Supporting
Organizations

A Type III supporting organization (other than a Type III
functionally integrated supporting organization) must
generally satisfy a distribution requirement described in
Regulations section 1.509(a)-4(i)(5)(ii) along with an
attentiveness requirement described in Regulations section
1.509(a)-4(i)(5)(iii) to meet the integral part test for a Type III
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Instructions for Schedule A (Form 990) 2023

relationship. To satisfy the distribution requirement, the
organization must make a minimum amount (distributable
amount) of distributions to or for the use of one or more
supported organizations. Carryovers of excess distributions
from certain prior years may be used for this purpose.

Adjusted basis. The adjusted basis for purposes of
determining gain from the sale or other disposition of
property is the greater of:
1. The fair market value of such property on August 17,
2006, plus or minus all adjustments thereafter and before the
date of disposition under sections 1011–1023, if the property
was held continuously from August 17, 2006, to the date of
disposition.
2. The adjusted basis under sections 1011–1023, without
regard to section 362(c). If assets acquired before August 17,
2006, were subject to depreciation or depletion, to determine
the adjustments to basis between the date of acquisition and
August 17, 2006, straight-line depreciation or cost depletion
must be taken into account. Any other adjustments that
would’ve been made during such period (such as a change in
useful life based upon additional data or a change in facts)
must also be taken into account.

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.

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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.

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.

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.

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.

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.

Instructions for Schedule A (Form 990) 2023

Line 5. The deduction for depreciation under section 167 is
allowed, but only on the basis of the straight-line method. The
deduction for depletion under section 611 is allowed, but
without regard to section 613 (percentage depletion).
Lines 6 and 7. No deduction is allowed except ordinary and
necessary expenses paid or incurred for the production or
collection of gross income, or for the management,
conservation, or maintenance of property held for the
production of income. Such expenses may include operating
expenses such as compensation of officers and employees,
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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.

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.

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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).

Line 1b. Figure cash balances on a monthly basis by
averaging the amount of cash on hand on the first and last
days of each month. Include all cash balances and amounts,
even if they may be used for charitable purposes (see the
instructions for Line 4, later) or set aside and taken as a
distribution (see the instructions for Section D, Line 5, later).

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.

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.

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.

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.

Dual-use property. When property is used for both
charitable and other purposes, the property is considered
used entirely for charitable purposes if 95% or more of its
total use is for that purpose. If less than 95% of its total use is
for charitable purposes, a reasonable allocation must be
made between charitable and noncharitable use.

5-year valuation for real estate. A written, certified, and
independent appraisal of the fair market value of any real
estate, including any improvements, may be determined on a
5-year basis by a qualified person. The qualified person may
not be a disqualified person with respect to the supporting
organization or an employee of the supporting organization.
Commonly accepted valuation methods must be used in
making the real estate appraisal. A valuation based on
acceptable methods of valuing property for federal estate tax
purposes will be considered acceptable.

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
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Instructions for Schedule A (Form 990) 2023

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.

The real estate appraisal must include a closing statement
that, in the appraiser's opinion, the appraised assets were
valued according to valuation principles regularly employed
in making appraisals of such property, using all reasonable
valuation methods. The supporting organization must keep a
copy of the independent appraisal for its records. If a
valuation is reasonable, the organization may use it for the
tax year for which the valuation is made and for each of the 4
following tax years.
Any valuation of real estate by a certified independent
appraisal may be replaced during the 5-year period by a
subsequent 5-year certified independent appraisal or by an
annual valuation, as described earlier. The most recent
valuation should be used to figure the organization's
minimum asset amount.
If the valuation is made according to the above rules, the
IRS will continue to accept it during the 5-year period for
which it applies even if the actual fair market value of the real
estate changes during the period.

Line 7. Enter the amount of recoveries (if any) reportable on
Section A, line 2.

Section C. Distributable Amount

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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.

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.

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).

In the case of securities, there are certain limitations on
the size of the reduction in value that can be claimed. The
organization may reduce the fair market value of securities
only to the extent that it can establish that the securities could
only be liquidated in a reasonable period of time at a price
less than the fair market value because:
• The securities are such a large block that liquidation would
depress the market,
• The securities are in a closely held corporation, or
• The sale would result in a forced or distress sale.
Any reduction in value of securities may not exceed 10% of
the fair market value (determined without regard to any
reduction in value).

Line 1. Report amounts paid to supported organizations to
accomplish their exempt purposes. Distributions furthering
the “exempt” purposes of supported organizations not
described in section 501(c)(3) refer solely to distributions for
section 501(c)(3) purposes.
Line 2. Report amounts paid to perform any activity that
directly furthers exempt purposes of supported organizations
and that would otherwise normally be engaged in by the
supported organizations, but only to the extent that expenses
from the activity exceed income from the activity. See the
Schedule A (Form 990), Part IV, Section E, Line 2,
instructions on “direct furtherance” activities.

Line 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
Instructions for Schedule A (Form 990) 2023

Line 3. Report reasonable and necessary administrative
expenses paid to accomplish exempt purposes of supported
organizations. Don't include expenses incurred in the
production of investment income.
Line 4. Report amounts paid to acquire exempt-use assets.
Such assets must be used (or held for use) to carry out the
exempt purposes of the supported organizations. The assets
may be used or held by either the supporting organization or
one or more supported organizations; if the latter, the
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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.

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.

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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.

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.

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.

Section E. Distribution Allocations

Section E determines whether the distributable amount for
the current tax year (and any underdistribution for reasonable
cause in a prior year) is satisfied through current-year
distributions and carryovers of prior-year excess distributions.
Section E also determines carryovers of excess distributions
to future years. Several lines in Section E aren't yet applicable
during the phase-in period of the new regulations for Type III
non-functionally integrated supporting organizations. Those
lines are grayed out.
In applying distributions, there are three basic steps.
1. First, apply distributions to eliminate any
underdistribution for reasonable cause in a prior tax year.
2. Second, apply distributions to satisfy the distributable
amount for the current year.
3. Third, carry over to future years any remaining excess
distributions.

Apply the oldest distributions first. Carryovers of excess
distributions from prior years are always applied in full before
current-year distributions (unlike the rules for qualifying
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Instructions for Schedule A (Form 990) 2023

distributions by private foundations), and older carryovers are
applied before newer carryovers. Excess distributions of a
given year can't be carried over for more than 5 years.

Line 2. An organization that is treated as a Type III
non-functionally integrated supporting organization for the
first time in its 2022 tax year will have a distributable amount
of zero during the 2022 tax year.
If the organization had any underdistributions for a prior
tax year (2021 or 2022), then it didn't qualify as a Type III
non-functionally integrated supporting organization in that tax
year and subsequent years (and would be classified as a
private foundation unless it met the requirements of another
public charity status) unless it met the requirements of the
reasonable cause exception or the judicial proceeding
exception discussed in the instructions for Lines 5 and 6,
later. If the organization met either of these exceptions,
explain in detail in Part VI how the organization met the
requirements for the exception.

Example 1. X is a Type III non-functionally integrated
supporting organization that for its tax year including
December 28, 2020, and through its following 2021 tax year
meets the requirements of Regulations section 1.509(a)-4(i)
(3)(iii) as in effect prior to December 28, 2020. Under
transition rules, X is deemed to meet its distribution
requirement for 2021, but its distributable amount is
calculated in the ordinary manner to determine its excess
distributions. For 2021, X had a distributable amount, as
ordinarily determined, of $80,000 and distributions of
$100,000. Accordingly, X had excess distributions of
$20,000. For 2022, X had a distributable amount of $95,000
and distributions of $85,000. X first applied its 2021 excess
distributions carryover of $20,000 to the 2022 distributable
amount of $95,000. Then, X applied $75,000 of its 2022
distributions of $85,000 to the remaining 2022 distributable
amount. Accordingly, X has excess distributions of $10,000
from 2022 (2022 distributions of $85,000 minus $75,000
applied to the 2022 distributable amount), which it may carry
over to 2023. For 2023, X has a distributable amount of
$100,000 and distributions of $150,000. X applies the
$10,000 excess distribution carryover from 2022 to the 2023
distributable amount. Then, X applies $90,000 of its 2023
distributions to the remaining 2023 distributable amount.
Section E will show $0 carryovers for 2021 and 2022
(because the excess carryovers for each of those years were
previously applied). In addition, Section E will show excess
distributions of $60,000 in 2023 (2023 distributions of
$150,000 minus $90,000 applied to the 2023 distributable
amount), which it may carry over in the next 5 tax years until
applied.

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Line 3. On lines 3d and 3e, enter the amounts reported on
lines 8d and 8e, respectively, from the organization's return
for the 2022 tax year. The sum of the amounts on lines 3d
and 3e is also reported on line 3f. The amount reported on
line 3f is then applied in the following priority.
1. First to any prior-year underdistributions on line 3g,
2. Second (if any remaining amount) to the current-year
distributable amount on line 3h, and
3. Third (if any remaining amount) on line 3j for carryover
to future years.
Excess distributions can't be carried over for more than 5 tax
years immediately following the tax year in which the excess
amount is created, and thus are forfeited if not used in the
fifth year of carryover. Such amounts are set forth on line 3i
(not applicable to the 2023 tax return).

Line 4. Apply the current-year distributions (from Section D,
line 7) in the same order of priority as described in the
instructions for Line 3 to any prior-year underdistributions
(line 4a) and current-year distributable amount (line 4b)
remaining after applying carryovers on line 3. Any remaining
distributions are reported on line 4c for carryover to future
years.

Example 2. Y is a Type III supporting organization that for
its tax year including December 28, 2020, meets the
requirements of Regulations section 1.509(a)-4(i)(3)(iii) as in
effect prior to such date, but doesn't meet such requirements
in its following 2021 tax year (because of underdistributions
for which the prior regulation didn't expressly provide a
reasonable cause exception). Therefore, Y didn't benefit from
the transition rule for its 2021 tax year. Y's distributable
amount was $120,000 for 2021. Y made distributions of that
amount and had no excess distributions to carry over to
2022. Y calculated that its distributable amount was
$150,000 for 2022 and made distributions of exactly that
amount in 2022. Early in its 2023 tax year, Y discovers that its
distributable amount for 2022 actually was $200,000. Within
180 days, Y makes a $110,000 distribution ($50,000 to cover
the underdistribution for 2022 and $60,000 as part of its 2023
distributions). Later in the 2023 tax year, Y makes additional
distributions totaling $200,000. Y’s distributable amount in
the 2023 tax year is $190,000. In its 2023 Form 990, Y claims
reasonable cause for the 2022 underdistribution due to a
clerical error. Under these circumstances, Y first applies
$50,000 of its 2023 distributions of $310,000 to the 2022
underdistribution of $50,000 ($200,000 minus $150,000),
then applies $190,000 of its remaining 2023 distributions of
$260,000 ($310,000 minus $50,000) to satisfy its 2023
distributable amount. Y’s remaining $70,000 of distributions
in 2023 ($310,000, minus $50,000 allocated to 2022, and
minus $190,000 allocable to 2023) are excess distributions
that may be carried over to future years.

Lines 5 and 6. If the current-year distributable amount is
greater than the sum of the excess distributions carryover
from the prior year plus the current-year distributions, then
the organization doesn't meet the distribution requirement
and can't qualify as a Type III non-functionally integrated
supporting organization for the tax year, unless an exception
applies. If the organization doesn't qualify as a supporting
organization or otherwise as a public charity for the tax year,
then it is a private foundation and must file Form 990-PF for
the tax year and subsequent years until private foundation
status is terminated under section 507. If either the
reasonable cause or judicial proceeding exception applies,
then explain in detail in Part VI how the organization met the
requirements for the exception.
Reasonable cause exception. An organization that fails
to distribute its distributable amount won't be classified as a
private foundation for the year of the failure if the organization
establishes to the satisfaction of the IRS that:
1. The failure was due to unforeseen events or
circumstances beyond its control, a clerical error, or an
incorrect valuation of assets;
2. The failure was due to reasonable cause and not to
willful neglect; and
3. The distribution requirement is met within 180 days
after the organization is first able to distribute its distributable

Line 1. Report the distributable amount for 2023 from
Section C, line 6.
Instructions for Schedule A (Form 990) 2023

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

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.

Amounts paid to meet a distribution requirement of a prior tax
year can't also be counted toward the distribution
requirement for the tax year in which paid.
Judicial proceeding exception. An organization is
excused from meeting the distribution requirements to the
extent of a conflicting mandatory provision in its governing
instrument, if a judicial proceeding is pending to reform a
governing instrument that prohibits compliance, under the
circumstances set forth in Regulations section 1.509(a)-4(i)
(11)(ii)(E).

Part VI. Supplemental Information

Use Part VI to provide narrative information required by these
instructions or to supplement responses to questions on
Schedule A (Form 990). Identify the specific part and line
number that the response supports, in the order in which they
appear on Schedule A (Form 990). Part VI can be duplicated
if more space is needed.

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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

CAUTION

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Don't include in Part VI the names of any donors,
grantors, or contributors because Part VI will be
made available for public inspection.

Instructions for Schedule A (Form 990) 2023