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How to Read the IRS Form 990
& Find Out What it Means
2005 Form 990 Version
Written by Peter Swords, former Executive Director
of the Nonprofit Coordinating Committee of New York, with the assistance
of Victoria Bjorklund of Simpson Thacher & Bartlett and Jon
Small, Executive Director of NPCC; supported by a grant from the
Ford Foundation.
Introduction
There is information in the
Form 990 that you may find interesting and
helpful for learning about the nonprofit
organization that filed the Form 990. But
you need to know where to find this information
and how to interpret it. To help you do
this, we offer a list of the ten most significant
pieces of information that can be found in the
Form 990 and show you exactly where you can find
the information.
Of course, your particular
interest in the organization whose Form 990 you
are reviewing will influence what information you
may consider significant. For example, if
you are thinking of contributing to a nonprofit,
you may want to know what it does and how strong
it is financially (its ability to attract
resources, its level of reserves, etc.). If
you are a board member, you may be interested in
reviewing your own nonprofit’s Form 990 for
information that might prove embarrassing upon
inspection by the public. Some believe that
board members have a responsibility to review
their organization’s Form 990 before it is
filed.
Immediately below we list
the ten most important items we address along
with where they can be found on the Form
990. You can go directly to any particular
item by clicking on its line. (In some
cases an item refers to more than one part of the
Form 990. We indicate just the most
important part below.)
#1
Identity and Tax Status – Heading,
page 1
#2
How Much Income Did the Filer Receive and From
What Sources? – Part I, page 1
#3
How Did the Filer’s Total Expenses Break
Down Between Program, Management and Fundraising
Expenses? – Part I, page 1
#4
What Can You Tell From Net Assets? – Part I, page 1
#5
What Kinds of Programs Does the Filer Run and How
Much Does It Spend on Them? – Part III, page 3
#6
Who Are the Filer’s Board Members and How
Much Does Its Top Staff Get Paid? – Part V, pages 5 and 6
#7
Did the Filer Initiate Some New Activity, Change
Its Processes for Governing or Engage in Any
Excess Benefit Transactions ?– Part VI, pages 6 and 7
#8
Did the Filer Engage in Any Self-Dealing
Transactions During the Year? – Schedule A, Part III, page 2
#9 Is
the Filer a Private Foundation? – Schedule A, Part IV, page 2
#10
Does the Filer Lobby? – Schedule A, Part VI, page 5
Before discussing the ten
most significant facts that can be found in the
Form 990, we first provide some background
information on how to use this guide and then on
the Form 990 itself.
During the course of
discussing each of the ten items, there are
several links to more detailed explanations for
those who want to learn more about the subject.
The point for which further elaboration is
provided is underlined in blue. All the
reader needs to do to access the expanded
material is to click on the blue line. (We
refer to these instances of expanded material as
the “expansions.”) Having
considered the more detailed discussion provided
in an expansion, the reader can click on
"Back" at the top left hand corner of
her screen and she will be taken back to the main
text.
Now we provide a little background information
on the Form 990. The Form 990, entitled “Return of Organization
Exempt From Income Tax,” is a report that must be filed each
year with the Internal Revenue Service (IRS) by organizations exempt
from Federal income taxes under section 501 of the Internal Revenue
Code, and whose annual receipts are "normally" more than
$25,000 a year. It is an information return and not an income
tax return since the organizations that file it do not pay income
taxes (except, as explained below, in certain cases an organization
may have to pay an “unrelated business income tax”).
There are many different kinds of nonprofit
organizations that are exempt under section 501 of the Code.
Charitable organizations are the principal focus of this guide.
They are exempt from income taxation under section 501(c)(3) of
the Code and, in addition to being required to file the Form 990
itself, must also file Schedule A to Form 990. (Schedule A
need not be filed by most other organizations exempt under section
501, such as trade associations, social clubs and the like.) Generally, organizations are exempt under section 501(c)(3) if they
pursue charitable, educational or religious purposes.
An organization "normally" receives
more than $25,000 a year if its gross receipts for the immediately
preceding three tax years average $25,000 per year or more.
Organizations with gross receipts of less than $100,000 and total
assets less than $25,000 at the end of the year may file a short-form
Form 990 called Form 990-EZ. Organizations that are classified
as private foundations (generally organizations that receive funding
from a very few sources) are required to file a Form 990-PF. Generally churches are not required to file a Form 990 (although
some churches file voluntarily).
Today the Form 990, in
addition to being the main IRS reporting form for
nonprofits, is the basic component of the annual
report that must be filed with a large number of
state offices that regulate charitable
solicitation. Many states require
supplemental reports as well as the Form
990.
The Form 990 serves two
essential purposes. First, it provides
information that helps government agencies (the
IRS and state charity regulators) enforce the
laws that govern nonprofits. For example,
it helps government regulators learn whether
groups have been spending their funds in a way
that might cause them to lose their charitable
and tax-exempt status. Second, the Form 990
provides a great deal of financial information
about the filing organization’s financial
condition, about its financial strength or
weakness and about such things as the sources of
its income.
The Form 990 is a very
public document and it is becoming more
public. Today an organization’s Forms
990 for the past three years must be shown to
anyone who wants to see them. In addition,
copies of these forms must be given to anyone who
requests them (either in person or in writing)
and who pays a reasonable fee -- $1 for the first
page and 15 cents for every page thereafter and
postage, if applicable.
Furthermore, most Forms 990 beginning with the
year 1997 are being posted on the Internet by the
National Center for Charitable Statistics and
Guidestar, two nonprofit groups in the Washington
D.C., area. Finally, it is only a matter of
time before all charities will be required to
file their Forms 990 electronically. Thus,
virtually every Form 990 is or soon will be
accessible by anyone in the world.
We conclude this
introduction with three final points.
First, while much can be found out by examining
an organization’s Form 990 for one year, a
great deal more can be learned from looking at
its Forms 990 for three years. For example,
if an organization reports the receipt of a
considerable amount of income for three years
from a particular source, such as program service
revenue, it may be considered likely that the
organization will continue to receive funds from
this source in the future. This conclusion
could not be made with as much confidence on the
basis of one Form 990. (As noted above, an
organization’s Forms 990 for the past three
years must be shown to anyone who wants to see
them.)
Second, a great deal of very valuable information
about the Form 990 can be found in the IRS’s “Instructions
for Form 990 and Form 990-EZ” and “Instructions for Schedule
A (Form 990).” These instructions, which provide general
information and elucidate what each line means, are clear and very
well done. They can be found, along with the current Form
990 and Schedule A, on the Web at http://www.irs.gov (run a search for Form 990 under the "Search
Forms & Publications" search feature).
Finally, we will be offering suggestions on
how information reported on the Form 990 might be interpreted.
These suggestions should be taken as just that – suggestions.
In many cases there will be other ways the data might be interpreted.
An interpretation of each particular Form 990’s data will depend
on the myriad of particular facts reported in each Form 990 and
on facts not reported for that year (e.g., fundraising costs incurred
in one year to raise funds in the year in question). Our suggestions
are offered to help you develop an aptitude for thinking about the
various ways the information contained in the Form 990 might be
interpreted.
For a more detailed exploration on the IRS Form
990, download Form 990: A Detailed Examination at NPCC's website
at www.npccny.org//More_990/990.htm.
We now canvass the ten most
significant items of information that can be
found on the Form 990 and show where they can be
found. (In the text that follows we refer to each
item as “Item #1”, “Item #
2,” etc.)
#1
Identity and Tax Status
At the top of page 1 of the
Form 990 there is a section of about seven lines
that elicits the name of the filing organization
and certain other information.
Item A shows whether the
filer is on a calendar fiscal year or some other
fiscal year. This can be important since
generally a Form 990 must be filed five and a
half months after the end of the filer’s
fiscal year and as you review a form you may wish
to know whether you have access to the most
current form.
Item B elicits whether the filer has changed
its address (discussed below) and whether the return is its initial
or final return. If the return is a filer’s initial return,
one will be on notice that it has a very short track record; if
it is the final return one will be on notice that the filer is terminating
operations.
Fundamental to your
examination of a Form 990 is to make sure you are
looking at the Form 990 that you set out to look
at. By looking at the address information
in the box (item C), you learn the name and
address of the filer. As there may be more
than one organization with the same name, you
have to make sure you have the Form 990 of the
organization you are interested in. There
is usually only one organization with a
particular name in a state, so the filer’s
address may provide the assurance you need.
If the filer has changed its address, it must
check the first box under item B. If you
still have doubts, item E reports the telephone
number of the filer and a call to it will almost
certainly clear the question up.
Item J shows what paragraph of section 501(c)
the filer is exempt under. You may believe that the filer
is exempt under section 501(c)(3) (the paragraph that exempts charitable,
educational and religious organizations), when in fact it may be
exempt under some other paragraph, such as section 501(c)(6) (which
exempts trade associations). There are 27 paragraphs under
subsection section 501(c), all indicating different types of organizations
that are exempt under section 501(a). If you were considering making
a contribution to the filer for whom you would expect to claim a
charitable contribution deduction under section 170 of the Code,
this information would be important to you, since, with few exceptions,
only contributions to section 501(c)(3) organizations are eligible
for the charitable-contribution deduction.
Sometimes one nonprofit
will file a group return for itself and its
affiliates. Item H provides information on
this subject.
Item F indicates what accounting method the
filer uses. In virtually every case it will either be the
cash or accrual method. It will be important for you in interpreting
a Form 990 to know what accounting method a filer used. For
example, if a filer used the cash method, it will not include accounts
receivable and other accrual items of income in Part I as income
or accounts payable and other accrual items of expenses in Parts
I and II as expenses, while these items would be included in income
and expenses if the filer used the accrual method.
Regarding item M, filers who receive during
the year $5,000 or more (in money or property) from any one contributor
must attach Schedule B (Schedule of Contributors) to their Form
990. This schedule includes information as to the identity of such
contributors and how much they gave. It is NOT open to the public
and thus cannot be accessed. However, item M at the top of page
1 of the Form 990 asks the filer to check a box if it is not required
to attach Schedule B. Thus, if the box is checked, it means that
the filer received no contribution from any one contributor of $5,000
or more. This information may be considered relevant in understanding
a filer's capacity to raise money from individuals.
(Check the Instructions for information on items
D, F, K and L.)
#2
How Much Income Did the Filer
Receive and From What Sources?
Part I (Revenue, Expenses and Changes in Net
Assets) on page 1 is divided into three sub-parts: “Revenue,”
“Expenses,” and “Net Assets.” The Revenue
sub-part reports a filer’s total revenue broken down among
some 13 different sources (e.g., contributions, fees for services
(called program service revenue on the Form 990), etc.). The
sum of these lines is totaled at Line 12 (Total revenue) at the
bottom of the Revenue subpart By going directly to Line 12, you
can find out how much total income the filer received during the
year. This will give you some idea of the size of the filer’s
operation. This may be misleading since in a banner year a
filer may have received a greater amount of income than it needed
to defray expenses for that year, or, as we shall see below, it
may have received income that is not attributable to the year.
Thus, in many cases the dimension of a filer’s activities may
be better reflected by considering its total expenses for the year.
This amount can be found at Line 17 (Total expenses) in the Expenses
subpart near the bottom of page 1. You might also look at
Line 90b on page 5, which indicates how many employees the filer
engages. Below is an example of Part I. We have highlighted
Line 17.
Example 1
As a preliminary point, we
believe a principal value of studying the
financial information found in the Form 990 is to
help you arrive at informed conclusions about the
filer’s ability to garner financial support
in the future and thus to be able to continue its
operations. Part I contains much financial
information that can help you with this effort.
Generally Line 12 may give
you an overall idea of the level of the
filer’s income generating potential for the
year being reported on. If you have access
to the filer’s Forms 990 for the past three
years and you observe that for each year its Line
12 is about at the same level, you might conclude
that it will be able to generate a similar amount
in the immediately ensuing period. If the
filer reports increasing amounts of revenue for
the three years, you might conclude its ability
to generate income is growing stronger. A
contrary conclusion may be reached if its total
revenue decreases across the three years.
As noted in the Introduction, these possible
interpretations may or may not be appropriate to
the actual situation of a particular filer.
You would need to know a great deal more about
the filer’s circumstances to be able to draw
firm conclusions.
Above we pointed out that the Revenue section
of Part 1 is broken down among 11 different sources of income (e.g.,
contributions, fees for services, dividends, etc.) You may
be able to reach some interesting conclusions about the nature of
a filer from examining the sources of its income and their relative
amounts. For example, some nonprofits may receive most of
their funds from gifts. This income would be reported on Line
1 (Contributions, gifts, grants and similar amounts received).
In contrast, some nonprofits may receive most of their funds from
charging fees for services. This income would be reported
on Line 2 (Program service revenue). If the distinction between
what may be called donative nonprofits (those that rely primarily
on contributions) and what might be called entrepreneurial nonprofits
(those that rely primarily on charging for their services) is important
to you, learning about the relative amounts of the income that the
filer receives from these different sources will be significant.
Below is an example of a Part I which shows
that the filer received most of its income from program services
(Line 2) (viz., 70%). Note in contrast in Example 1,
above, the filer received most of its income from contributions
(Line 1) (i.e., over 90% of its total revenue came from contributions).
Example 2
Program service revenue
(Line 2) income may include income from an
unrelated business activity, that is, an activity
that is not related to the filer’s exempt
purposes (other than in providing income to
support such purposes). A considerable
amount of unrelated business activity may be
thought to reflect on the character of the
filer. A reader of the filer’s Form
990 can find out about unrelated business income
that the filer may have generated by examining
Part VII (Analysis of Income-Producing
Activities) on page 6 of the Form 990. Click
here for an Expansion that explains Part VII.
Line 2 income also includes
income from government contracts. (You need
to turn to Part VII on page 6 to learn about the
type of a filer’s program service
revenue.) A fair number of nonprofits get
nearly all their support from government
contracts. If this fact is important to
you, you can learn this from reviewing Part I
(and Part VII) of the Form 990.
Below, Example 3 shows a Part VII reporting
receipts of government contracts. (Example 3 is based on the figures
reported in Part I of Example 2 above.)
Example 3
Finally, it may be significant that a filer
gets most of its income from membership dues reported at Line 3
(Membership dues and assessments). Income reported on Line
3 is for dues that members pay in return for benefits they receive
from the filer. If the filer gets most of its income from
Line 3 membership dues, that may shed some light on the nature of
the filer.
In the preceding
paragraphs, we have suggested that by looking at
the sources of income a filer receives, something
may be learned about its character. Also of
importance is finding out about the filer’s
capacity to generate income. (As suggested
above, here it is important that you have Forms
990 covering more than one year.) To begin
with, it may be thought significant that the
filer acquires its income from a variety of
sources as this may suggest it is not
particularly dependent on any one source.
On the other hand, a steady flow of income for
several years from one particular source (say,
contributions or program service revenue) may
support an assumption that such income may
continue to be received in the future.
Similarly a steady source of income for several
years from dividends or rents may suggest
considerable investment assets and a stable
source of revenue. Finally, special
events income reported on Line 9 (Special events
and activities) may suggest the ability to bring
in a singular source of income to help support
the filer’s activities. Some may wish
to develop ratios showing the proportion of total
support provided by various particular sources of
support, such as the percent of total revenues
made up by contributions.
In addition to supporting
conclusions about a filer’s nature and
capacity to raise income, continued strong
support from contributions, program service
revenue and/or membership dues may be taken as
suggesting that there are those who believe that
the filer does important work and this may be
significant for you.
#3
How Did the Filer’s Total Expenses Break Down
Among Program, Management, and Fundraising Expenses?
Lines 13-17 of Part I on
page 1 constitute the Expenses section of Part
I. Line 17 reports total expenses. Except in the rare case that a filer reports
payments to affiliates (Line 16), total expenses
are the sum of program expenses (Line 13 (Program
services)), management expenses (Line 14
(Management and general)) and fundraising
expenses (Line 15 (Fundraising)).
We have already suggested that the total expenses
reported at Line 17 is a good way to get a quick idea of how extensive
a filer’s activities are. In addition, the Expenses section
of Part I permits the reader of the Form 990 to quickly find out
what proportions of total expenses are made up by the three functional
categories of expenses that are elicited by the form, namely, program
(Line 13), management (Line 14) and fundraising (Line 15) expenses.
Readers of the Form 990 may want to assure themselves that the filer
is spending most of its resources on program matters and not on
management or fundraising. By simply dividing a particular
functional expense total (say, program services) by total expenses,
one can learn what percent of total expenses have been spent on
that function. For example, in the example from a Form 990
set out below, program expenses make up 60% of total expenses ($1,200,000/$2,000,000
= 60%).
Example 4
Program services expenses
are those incurred to carry out the
organization’s mission. Thus, expenses
incurred by a social services organization in
paying its social workers for delivering services
to its clients would be program services
expenses. By like token, payments made by a
performing arts organization to produce a play
would be program services expenses. For a
501(c)(3) group, the activities that these
expenses support are usually the basis of the
organization’s tax exemption.
Management and general
expenses are those incurred in connection with
providing overall administration to an
organization. The IRS’s
"Instructions For Form 990"
(Instructions) note as management and general
activities such things as preparing for and
holding board meetings, working on office
management and personnel problems, and accounting
and investment activities. The Instructions
also make clear that, for example, the expenses
incurred in carrying out activities such as the
supervision of program services or fundraising
are included under those categories and are not
included under management and general.
Thus, for example, expenses incurred in preparing
for and attending a staff meeting called to plan
for a future program initiative or to assess
present program activities would be part of the
program services category (Line 13) and not the
management and general category (Line 14).
For many small organizations with small staffs,
it is likely that management and general expenses
will be low as most of management’s time of
these groups is spent on supervising the program
and fundraising and relatively little on overall
management activities.
Fundraising expenses are
pretty much self-defining. The Instructions
define this category as “ … the total
expenses incurred in soliciting contributions,
gifts, grants, etc.”
Many believe that
nonprofits should not spend an overly large part
of their resources on fundraising. If a
reader of the Form 990 is of this view, she might
look to see what percent of total expenses is
made up of fundraising expenses (Line 15 divided
by Line 17). For example, in Example 4 from
a Form 990 set out above, fundraising expenses
make up 30% of total expenses
($600,000/$2,000,000 = 30%). We suggest,
however, that care should be taken in
interpreting this “fundraising
ratio.” If, for instance, a group is
new or advancing an unpopular cause, it may need
to spend more on fundraising than a group that
has been around for some time or is doing
something recognized by all as useful.
These kinds of qualitative differences are not
elicited by the Form 990. Furthermore, a
group which spends a fair amount on fundraising
(and has a high “fundraising ratio”)
may, as a result of the increased revenue
resulting from such efforts, be able to do a lot
more than a group which spends very little on
fundraising (and has a low “fundraising
ratio”) and consequently generates less
income.
The amounts reported at
Lines 13, 14, 15 and 17 are taken from Part II on
page 2 of the Form 990. Part II consists of
23 lines (Lines 22 – 44), which list various
“object” expenses and four columns of
“functional” expenses. Object
expenses include such things as compensation paid
to staff, amounts paid for telephone and travel,
etc. The four columns consist of the three
functional expense categories discussed above,
that is, program services (column (B)),
management and general (column (C)) and
fundraising (column (D)), and total expenses
(column (A)). Each amount reported as an
object expense is, depending on what it is spent
on, allocated amongst the three functional
expense columns ((except for Lines 22 (grants),
23 (assistance to individuals) and 24 (benefits
to members) which are to be reported only as a
program expenses). A reader may find it
useful to review the types of expenditures a
filer made during the year and what functional
expense category they were spent on. This
can be done by examining Part II.
A note on Line 16 (Payments
to affiliates). Certain kinds of payments
made to affiliated organizations, such as dues
paid by a local charity solely to support its
state or national parent, are reported at Line
16. As suggested above, this line is only
rarely applicable and usually shows zero.
#4
What Can You Tell From Net Assets?
We now come to the bottom of page 1, the four
lines that make up the Net Assets section of Part I. The first
line, Line 18 (Excess or deficit for the year), indicates whether
the filer operated at a surplus or deficit for the year being reported
on and the size of such surplus or deficit. This is of obvious
interest since on the face of it a surplus and its size may suggest
future financial health while a deficit and its size may suggest
future financial difficulty. We emphasize “may suggest”
since either a surplus or a deficit may reflect something unusual
for the year being reported on and have little bearing on the future.
Nevertheless, many will want to know whether the filer ended the
year in the red or the black. Of course, if you have access
to three or more years of the filer’s Forms 990 and they indicate
a trend of surpluses or deficits, this may be more significant as
a predictor of the filer’s future financial condition. (We return to this point below.)
Line 19 (Net assets at the beginning of year)
and Line 21 (Net assets at end of year) are of obvious interest
as they indicate the amount of assets over all liabilities (i.e.,
net assets) that the filer holds or what the filer’s net worth
is at the beginning (Line 19) and end (Line 21) of the year.
(We discuss Line 20 at the end of this Item.) In the usual
case where Line 20 reports zero, Line 21, logically enough, is the
combination of Lines 19 and 18, i.e., the net assets on hand at
the beginning of the year plus the surplus reported at Line 18 (or
less the deficit reported at Line 18) equals the net assets on hand
at the end of the year. This can be seen below in the excerpt
of the Net Assets section. The amount reported at Line 21
is the same as the amount reported at Line 73(B) on Part IV. Below
we set out an example of the Net Assets section of a Form 990 based
on the figures shown in Example 1 above.
Example 5
Net assets provide some
indication of the level of resources the filer
has to help support its activities in the
future. Very generally it might be expected
that a filer with a small amount of net assets at
the end of the year would be quite dependent on a
reliable and timely receipt of income in the
ensuing period to be able to continue
activities. Likewise, in a very general
sense, it might be expected that a filer with a
large amount of net assets at the end of the
year, relative to its expenditures for the year
being reported on, would begin the next period in
a strong financial position and be able to endure
a time of income shortfalls and still continue
its activities.
What has just been
suggested should, as noted, be taken as a very
general first approach. It is often the
case that some of the net assets on hand at the
end of the year may not be easily drawn down to
meet a filer’s needs or obligations.
For example, some assets may consist of
restricted endowments or if the filer owns a
building that is central to its operations (e.g.,
a school building), it may not, as suggested, be
possible to sell the building to produce cash to
meet needs without virtually destroying the
ability of the filer to carry out its
(educational) goals. Consequently, as
discussed below, net assets need to be analyzed
to determine what portion of such assets are
practically available to help the filer meet its
future needs.
In making reference to
meeting the filer’s needs, we primarily
refer to its near-term needs and by this we have
in mind its needs for the next year or so. Obviously, in the longer-term future, if the
filer became financially destitute and needed to
liquidate any assets to satisfy its creditors,
most of the assets that we are suggesting are not
available to meet near-term needs might well be
accessible to satisfy creditor demands.
To conduct the analysis
just suggested, it is necessary to turn to Part
IV (Balance Sheets) of the filer’s Form
990. Part IV is found on page 3 and
constitutes the filer’s balance sheet.
It is divided into three sections: Assets (Lines
45 – 59), Liabilities (Lines 60 – 66)
and Net Assets (Lines 67 – 74). Line
73 reports net assets; Line 73(A) reports net
assets on hand at the beginning of the year and
Line 73(B) (as noted above) those on hand at the
end of the year. Line 73(B) (as also noted
above) is identical to Line 21. The amount
reported at Lines 21 and 73(B), the filer’s
net assets on hand at the end of the year, is the
amount we want to analyze to determine how much
of this amount might be available to meet the
needs of the filer in the near-term future.
To begin, we suggest that you should find out
how much the filer reports on Line 69(B) as permanently restricted
net assets held at the end of the year. Permanently restricted
assets are assets that have been given with restrictions that they
be preserved and not sold. One example would be an endowment
gift that stipulates that the principal of the gift is to be permanently
held and that only the income that the principal generates may be
currently used. Another example would be a gift of a work
of art or real estate with a restriction that it be held permanently
and not sold. These permanently restricted assets therefore
cannot be used to meet the general near-term needs of the filer. They should therefore be subtracted from Line 21 (and line 73(B))
to get a more reliable sense of how much of total net assets are
available to meet near-term needs.
Next, it might be instructive to look at the
amount of net assets that are reported on Line 68(B) (temporarily
restricted [net assets]). These are assets that have been
given with restrictions that they be used in a later period, or
for a specified purpose or both. A typical example might be
a grant from a foundation with a stipulation that the funds be used
over several years (a multi-year grant) to support a particular
program. A careful reader of the Form 990 might decide to
take the amount reported at Line 68(B) into account in evaluating
how much of total net assets are available to meet the filer’s
near-term needs. For example, some part of the amount
listed at Line 68(B) may not be available for spending until some
time in the future or might be restricted to a particular program
which might not be part of the filer’s core or general program.
As to the later type of restriction, if the reader of the filer’s
Form 990 was primarily interested in the filer’s ability to
continue its core program, these assets would not be available for
such needs. Thus, as just mentioned, it might be decided to
take the amounts listed at Line 68(B) into account in assessing
how much of a filer’s total net assets are available to meet
near-term needs.
If one subtracts the sum of
permanently restricted and temporarily restricted
net assets, from total net assets, you are left
with unrestricted net assets which is the amount
reported at Line 67 (unrestricted [net
assets]). Line 67(A) reports the
unrestricted net assets on hand at the beginning
of the year and Line 67(B) those on hand at the
end of the year. Line 67(B), unrestricted
net assets on hand at the end of the year, is a
good place to look to get a general idea of the
level of assets available to the filer to meet
near-term needs. Of course, as suggested
above, some or all of a filer’s temporarily
restricted net assets may be available for
near-term use, although the exact amount of such
assets available for these purposes may not be
known.
Below is an example (based on Example 1) of
the Net Assets section of Part IV reporting unrestricted, temporarily
restricted and permanently restricted net assets. (The example
assumes the filer reported no liabilities.) Note that it is
the amount reported at Line 67(B), namely, $580,000, that would
be the amount that one should consider as likely to be available
to meet the filer’s near-term needs and not the total net assets
of $1,680,000 reported at Line 73(B) and Line 21.
Example 6
Finally, as mentioned
above, a careful reader of the Form 990 will also
want to look at the Assets section of Part IV to
find out whether any of the assets held by the
filer might be difficult to readily convert to
cash (i.e., might not be easily
liquidated). The Assets section of Part IV
lists assets roughly in order (Lines 45 –
58) of their relative availability for use.
For example, Line 45 reports cash and Line 57
reports the value of buildings and similar assets
held by the filer. A building, whether it
is a permanently restricted asset or an
unrestricted asset, may as a practical matter be
difficult to liquidate. The same may be
said about certain investments the filer holds,
such as investments in land or buildings
(reported at Line 55). So in assessing a
filer’s net assets to determine their
availability to meet near-term needs, it may be
desirable to review the kinds and relative
amounts of assets that the filer reports in the
Assets section (Lines 45 - 59) of Part IV.
We conclude our discussion of the Net Assets
section of Part I by returning to a point made above and briefly
consider the effect that recurring deficits may have on a filer’s
net asset position. In most cases repeated deficits will cause
a reduction in unrestricted net assets. This reduction may
not be reflected in total net assets since, for example, in some
instances a filer may have received a contribution to its permanently
restricted net assets (Line 69) (such as a gift to an endowment
fund) so that its total net assets (Lines 21 and 73(B)) may not
decrease or may even increase. Often, however, this will not
be an issue since many filers will have only unrestricted net assets
(i.e., they will not have any temporarily or permanently restricted
net assets). In any event, as suggested above, a reader of the Form
990 can learn about the impact of a deficit on the filer’s
ability to meet the near-term needs of its core program by going
directly to Line 67 – unrestricted net assets -- and calculating
the reduction in unrestricted net assets from the beginning of the
year to the end of the year (Line 67(B) – Line 67(A)
= reduction in unrestricted net assets). If it is observed
that, as a result of the recurring deficits, the level of a filer’s
unrestricted net assets is declining in a significant way, it may
reasonably be concluded that the filer’s financial position
is weakening, and, depending on the relationship between the most
recent yearly deficits and the amount of the filer’s unrestricted
net assets, it may be weakening significantly. For example,
if a reader of three consecutive Forms 990 of a filer observes that
the filer had $750,000 of unrestricted net assets at the start of
the period being examined (Line 67(A) of the first year’s Form
990) and sustained deficits in the neighborhood of $200,000 for
each of the three years, so that the filer’s unrestricted net
assets had diminished to about $150,000 at the end of the period
being examined (Line 67(B) of the last year’s Form 990), there
would be reason for serious concern about the filer’s future
financial health. On the other hand, if the deficits ran at
about the level of $50,000 a year, while this may be taken as an
indication of some problems, they would clearly not be as serious
as in the first case.
A note on Line 20 (Other
changes in net assets or fund balances). In
some instances, there will be changes between an
organization’s net assets at the start and
end of the year that cannot be accounted for by
the amount on Line 18. They would include
such items as adjustments of earlier years’
activities and, not uncommonly for those groups
that hold securities as assets, unrealized gains
or losses on investments carried at market
value. The net of these changes is entered
at Line 20. If a filer reports on Line 20,
it must attach a schedule.
#5
What Kinds of Programs Does the
Filer Run and
How Much Does It Spend on Them?
Part III on page 2 of the
Form 990 elicits information on what a filer
does. The filer is required to state the
organization’s primary purpose on a very
short line near the top of this part. Then
for each program it conducts the filer is to
describe, on several lines provided for this,
each such program’s purpose, stating the
outputs of the program, such as number of clients
served, publications issued, and students
taught. In a column to the right of this
description, the filer is to list the total of
program expenses for each such program.
Four subparts (a-d) are provided for four
programs. A fifth subpart or line (e)
instructs the filer to attach a schedule for
other programs. A final subpart or line (f)
requires the filer to report the total of program
expenses, the sum of the expenses for each of the
particular programs reported above, which should
be identical to the amount reported at Lines 13
and 44(B). The 2005 Form 990 now asks whether the amount spent includes foreign grants. Here is Part III.
A careful filer, in
describing its programs, should be able to
provide a fairly good idea of its activities,
and, by comparing the relative amounts spent on
each program, one may derive some sense of their
relative importance. This is the only part
of the Form 990 where you can pick up descriptive
data about a filer’s activities and this
qualitative information can be helpful for
putting all the numbers in the Form 990 in
context. One should be aware, however, that
this information cannot reveal whether the filer
is doing its work effectively and efficiently or
achieving satisfactory ultimate outcomes.
#6
Who are the Filer’s Board
Members and How Much
Does its Top Staff Get Paid?
Part V-A (Current Officers,
Directors, Trustees, and Key Employees) and V-B (Former Officers, Directors, Trustees, and Key Employees That Received Compensation...) on pages 5 and 6
of the Form 990 contains information of
considerable interest. The name of each
board member is listed. (The address of each
board member is also given, but in many cases the
address will be the same as the address of the
filer). If the board member receives any
compensation for her or his duties, the amounts
are reported here. Of course, most board
members do not receive compensation for their
work as board members. Here is Part V-A and V-B.
If the reader of a Form 990
knows something about some or all of a
filer’s board members, their identity can be
significant information since the quality of an
organization’s board members may reflect on
the organization itself. Even if the reader
knows little about the board members, if it
appears from their last names for instance that
several or many board members are from the same
family, this may be significant to a
reader. For example, a group which is
essentially directed by a single family may be of
a different nature than one that has broad public
representation. Finally, the number of
people on the board of the filer may be of
interest.
Part V also elicits compensation information
about the filer’s top management officials. Part V-A elicits
the names, addresses and compensation information of key employees.
Key employees are defined by the Instructions as including a filer’s
“chief management and administration officials” including
the filer’s “chief financial officer and the officer in
charge of administration or program operations ... if they have
authority to control the organization’s activities, its finances
or both.” While the term “key employees” is
somewhat imprecise, it clearly includes an organization’s executive
director and its chief financial officer, if such person has control
over the organization’s finances independent of the executive
director. Part I of Schedule A elicits compensation of the
five highest paid employees who are paid more than $50,000 that
are not listed in Part V. (Schedule A, as noted in the Introduction,
is a six page supplementary information return that is filed along
with the Form 990 by most organizations exempt under section 501(c)(3).)
Thus, the Form 990 and Schedule A will report on the salaries of
at least the top six managers of the filer, assuming that there
are five employees after the key employees listed at Part V who
make more than $50,000. In some cases, where, for example,
more than one key employee is listed on Part V, a higher number
will be reported. We believe that for most filers this provides
ample information about the compensation of a filer’s top management.
Part V-A of the Form 990 and Part I of Schedule
A require that the full compensation be given for each individual
listed. For both Part V-A and Part I of Schedule A, column (C)
calls for an individual’s basic compensation; column (D) for
deferred compensation and employee benefits; and column (E) for
expense account and other allowances. A compensation package
often includes many elements (base salary, bonuses, deferred compensation,
benefits, etc.). These parts of the Form 990 have been drawn
so as to pick up a person’s entire compensation package. Thus, if the Form 990 has been filled out correctly, it will all
be there.
Together, these two parts report about the salaries
of a good number of the filer’s highest paid staff members.
This information may be of considerable interest. A reader
may, for example, want to learn what persons in top management positions
are being paid in organizations similar to one she is interested
in (e.g., one she works for or serves on the board of). Or
a reader may draw some very preliminary conclusions about the quality
of a filer’s management from the level of salaries that are
being paid. Or a reader may have ideas about how much it is
appropriate for a nonprofit group to pay top management officials
and want to compare a filer’s compensation arrangements with
what she believes are appropriate levels of compensation.
She may conclude that such payments by the filer are too high or
too low by her standards. Finally, a reader may discover
that the compensation reported as being paid to a particular employee
is not what he believes the filer in fact paid the employee or that
the compensation of the employee about whom the reader is concerned
is omitted from the Form 990. This omission may raise questions
in the reader’s mind.
In cases where a filer may have paid certain
employees (among whom key employees would be included) compensation
at unreasonably high levels, the payments might be found to be “excess
benefit transactions” under section 4958 of the Code.
This would result in a tax being imposed on the employees who received
the unreasonably high compensation (and in some cases upon the board
members who approved the payments). As noted below in Item
#7, Line 89b in Part VI on page 5 asks whether the filer engaged
in any section 4958 excess benefit transactions during the year.
If the filer answers “Yes,” it is to attach a statement
explaining each transaction. Where a filer answers Line 89b
“Yes,” a reader of its Form 990 may wish to find out as
much as she can about the transaction. Click here for an Expansion
on section 4958.
Sometimes a top management
official will receive some of her salary from an
organization other than the filer, which other
organization is related to the filer.
Knowing about such arrangements may be important
for someone focusing on compensation. Line 75, which has been expanded in the 2005 Form 990, provides such information.
Line 75a requires you to list the number of directors permitted to vote at your board meetings. Line 75b asks whether any directors or key employees listed in Part V-A are related to each other through family or business relationships. If the question is answered “Yes,” a statement explaining the relationship(s) must be attached.
Lines 75b and c and also refer to the highest compensated employees and professional and other independent contractors listed in Schedule A. So, for example, if a board member is related to one of the highest compensated employees or independent contractors listed in Schedule A, Line 75b must be answered “Yes.”
Line 75c asks whether any officer or key employee, etc., (plus highest compensated employees or highest compensated professional and other independent contractors listed in Schedule A Parts I, II-A or II-B) received compensation from any other organizations that are related to the filer (in ways defined in the instructions). It makes no mention of aggregated amounts being received from the filer and all related organizations. Nor does it contain the $10,000 floor. You have to go to the instructions to find out that Line 75c only kicks in if the key employee, etc., received aggregate compensation amounts of $50,000 or more (as compared to $100,000) from the filer and all related organizations. The instructions mention nothing about a $10,000 ceiling, i.e., the requirement that the key employee, etc., was provided with more than $10,000 by related organizations. Presumably if he or she received the aggregate of $50,000 or more from the filer and related organizations, then any amount from a related organization would trigger the need to answer Line 75c, “Yes.”
Finally, and significantly, Line 75d asks whether the organization has a written conflict of interest policy.
Some may be interested in
learning of the comparative compensation levels
paid to various staff members (e.g., top
management salaries as compared to those
employees working at the lowest salaries).
The Form 990 does not provide any direct
information on this subject, but some very rough
sense of such differences may be gathered by
comparing the average salary of the filer’s
total staff to the salary levels reported at Part
V-A and Part I of Schedule A. A roughly
approximate idea of the average compensation of
the whole staff can be derived by dividing the
sum of Lines 25(A), 26(A), 27(A) and 28(A), which
report total compensation paid to staff, by the
total number of employees reported on Line
90b. Some insight on this question may also
be drawn from the bottom of Part I of Schedule A
which asks for the total number of employees paid
over $50,000.
Finally, a reader of the
Form 990 may be interested in knowing about any
relatively large payments made to those who serve
as independent contractors to the filer, such as
professional fundraisers or lawyers. Part
II of Schedule A (Compensation of the Five
Highest paid Independent Contractors for
Professional Services) on page 1 of Schedule A
requires the filer to list the five highest paid
independent contractors (whether individuals or
firms) who received over $50,000 for the
year.
With the 2005 Form 990, Part II has been split into two parts. Part II-A asks for compensation information paid to the five highest paid independent contractors for professional services who receive more than $50,000 for the year being reported on. This includes fees paid to attorneys, accountants, auditors and professional fundraisers. Part II-B asks for the same information for independent contractors other than those who provide professional services. The old Part II asked only about independent contractors for professional services. Both Parts II-A and B also ask for the total number of independent contractors receiving over $50,000 who are not listed, that is, those who receive over $50,000 but are not among the five highest paid.
#7
Did the Filer Initiate Some New
Activity, Change Its Processes for Governing or
Engage in Any Excess Benefit Transactions?
Part VI (Other Information) on page 5 of the
Form 990 elicits information on a number of topics mostly by asking
questions that are to be answered "Yes" or "No." For this item we review the most important of these questions.
Line 76 asks in effect whether the filer made
any significant changes in the kind of activities it conducts to
further its exempt purposes. If the filer answers “Yes” to this question, it must file an attachment with the Form 990 describing
any such new activity. A significant change in
a filer’s activities will be of prime importance to most readers
of the Form 990.
Line 77 asks a similar question about any changes
in a filer’s governing documents. This would include
amending a filer’s certificate of incorporation to allow it
to engage in a new activity. A change in the filer’s
by-laws (e.g., changing the number of board members or the quorum
requirements) would be another example. If the filer answers
the question "Yes," it must attach a conformed copy of
the changes. Again, plans to commence new activities are of
obvious interest and modifications in how an organization governs
itself may signal an important change in the nature of the organization
or perhaps some internal conflict that the reader of the filer’s
Form 990 may want to find out about.
There are certain transactions that an organization
may engage in with its staff or board members which involve improper
payments. They are called excess benefit transactions.
Click here for the Expansion
on section 4958. As noted in Items #6 and #8, Line 89, among
other things, asks whether the filer engaged in any excess benefit
transactions during the year being reported on. If the filer
answers this question “Yes,” it must attach a statement
explaining each such transaction. Information about any improper
transactions that the filer may have engaged in should be of interest
to any reader of its Form 990.
We will now very briefly discuss some of the
other questions found in Part VI that may be of interest.
Two questions ask about the filer’s relationships, if any,
with other organizations (Lines 80 and 88). Line 79 asks whether
the filer dissolved or made a substantial contraction during the
year. Line 82 asks whether the filer received any donated
services during the year. Two questions inquire about the
filer’s political activities (Lines 81 and 89).
Finally, Line 90a asks the filer to list all
the states in which it files the Form 990. About 35 states
now require organizations that solicit contributions within such
states to annually file their Form 990 with them. Thus, if
a reader of the filer’s Form 990 is interested in the filer’s
solicitation activity, the answer to this question will be of interest.
As noted above, Line 90b elicits information about the size of the
filer’s staff. Line 91 elicits information about who
the filer’s books are in care of and how such person may be
reached. This will be important to those who may want to find
out information about the filer that is not contained in its Form
990.
#8
Did the Filer Engage in any
Self-Dealing
Transactions During the Year?
The IRS and state charity
bureaus are the government agencies that provide
general regulatory oversight over the nonprofit
and tax-exempt sector. A primary concern of
these agencies is to assure that nonprofit
organizations are not used by those who control
them to improperly transfer their assets to
private interests in circumstances in which these
assets should have been used to further the
exempt purposes of the organizations. An
example of such a transaction might be the sale
by a board member of property he owns to the
nonprofit organization on whose board he sits at
a price in excess of its fair market value. Another example might be the furnishing of
services to a board member without charge or at a
price below their market value.
These transactions may be
generally described as self-dealing. (Thus,
a board member in effect deals with himself when
his board buys from him.) Line 2 of Part
III (Statement About Activities) on page 2
of Schedule A elicits information about these
transactions. Such transgressions should be
of interest not only to government regulators but
also to anyone who is concerned about these
groups’ well-being or is interested in
helping them. Such persons will want to
know whether any corrupt practices have
occurred. Many of these transactions will
be excess benefit transactions under section 4958
of the Code. Click here for the Expansion on
section 4958.
In cases where the
transaction involves simply the improper transfer
of a filer’s assets to individuals for no
apparent reason (e.g., looting or quasi-looting),
such as the sheer siphoning off of a filer’s
funds to an executive director without anyone
knowing about it, the transaction may not be
strictly considered an instance of
self-dealing. It is, of course,
nevertheless improper and such transactions are
also picked up by the Line 2 questions.
Line 2 asks a series of
questions about transactions between the filer
and directors, key employees and others who might
control the filer, which transactions might be
instances of self-dealing or similar
transactions. For example, Line 2a asks in
effect whether any sale, exchange or leasing of
property occurred between the filer and a board
member, key employee, etc. There are five
such questions (Lines 2a-e). They are to be
answered “Yes” or “No.”
If the answer to any question is “Yes,”
the filer is required to attach a detailed
statement explaining the transactions. Line
2 is set out below:
Of course, in many
instances a self-dealing transaction between a
board member, etc., will be for the benefit of
the filer. For example, a board member of
the filer may sell property to the filer at a
price below its fair market value. Thus,
just because a Line 2 question is answered
“Yes,” it does not mean that the filer
engaged in an improper act. Before reaching
any conclusions about the filer’s behavior,
a careful reader will review the filer’s
attachment that relates to the question. It
is likely that the transaction will be explained
there to the satisfaction of the reader.
If no explanation is provided or if the explanation
appears evasive, a red flag may be raised in the reader’s mind
and she might wish to find out more about the transaction from the
filer. If the filer engaged in a self-dealing transaction
knowing it was improper, it is unlikely that it would answer the
relevant Line 2 question “Yes” for to do so would be tantamount
to admitting it had done something improper. In some cases,
a reader of the filer’s Form 990 may know of a self-dealing
transaction from sources outside of the Form 990. If such
a reader observes that the filer answered the relevant Line 2 question
“No,” she will be alerted to a problem and may wish to
explore the matter further with the filer, or the IRS or the relevant
state Attorney General. Click here for
an Expansion on Line 2
#9
Is the Filer a Private Foundation?
All section 501(c)(3) nonprofits are either
private foundations or non-private foundations. The term “private
foundation” is a technical term and relates to the kind of
nonprofit an organization is and the nature of its support and not
to the fact it is a philanthropy. (We will refer to a non-private
foundation as a “public charity.”) This distinction
between private foundation and public charity is important since,
from a nonprofit’s standpoint, it is undesirable to be a private
foundation. For example, there are some significant limits
on making contributions to private foundations, and private foundations
are generally prohibited from doing any lobbying and must pay a
small excise tax. Click here for an expansion on private foundations.
The distinction can also be
significant for those who wish to find out about
nonprofits. For most section 501(c)(3)
nonprofits, the fact that they have qualified as
public charities means that they receive support
(mostly financial) from a wide, or at least
fairly wide, range of sources and government
agencies. And, as suggested earlier, groups
that receive financial support from many sources
are usually thought well of by many people and
this is surely something important to know about
a nonprofit that one is evaluating. Furthermore, the fact that many support a group
usually means that a good number are to some
degree monitoring its activities and this may
provide comfort to those considering supporting
the organization.
Thus, a reader of the Form 990 may want to know
whether the filer is a private foundation or public charity.
This information can be found in Schedule A at Part IV on page 2
and Part IV-A on page 3. Part IV asks whether the filer is not a private foundation. It provides a number of lines
(Lines 5 –14) with brief descriptions of entities, each of
which is not a private foundation. The filer is instructed
to check the box that applies to it. By reviewing Part IV,
one can determine whether the filer is a public charity, and, if
so, what kind of public charity it is.
Here we set out Part IV
Generally, there are three types of pubic charities
(i.e., non-private foundations). First, there are those entities
that are public charities because of their very nature and that
do not have to show a wide base of public support, such as churches
(Line 5), schools (Line 6) and hospitals (Line 7). Second,
there are those groups that are not per se public charities
but are public charities because they do receive broad public
support (Lines 11a and 12). Finally, there are those groups
that may not receive wide public support but are supporting organizations
to groups that are included in the first two categories of public
charities (Line 13). (Part IV also lists (Lines 8, 9, 10 and
11b) several other kinds of groups (e.g., a government unit, community
trust, etc.) that are not private foundations. Because they
are fairly uncommon, to save time we will not cover them. Information
can be found about these groups in the Instructions to Part IV.)
Most filers are the second type of public charity,
namely, those that receive broad public support. For a group
to qualify as a public charity, a fair amount of its support must
be “public support.” The question of what constitutes
public support is quite complicated in its details. For our
purposes, we need only provide a general idea of what the term means.
There are two kinds of public charities that qualify under this
category. For one kind (which is described under section 509(a)(2)
of the Code), public support includes contributions from individuals,
grants for government agencies and exempt function income.
(Exempt function income includes such items as tuition or ticket
sales). For the other kind (which is described under section
509(a)(1) of the Code), public support includes contributions from
individuals and grants from government agencies but not exempt function
income. In both cases, for contributions to qualify as pubic
support, they cannot be too large. These rules are elaborated
upon in the Expansion. Click here for the Expansion on private foundations.
Part IV-A of Schedule A is
where a filer shows the nature and amount of its
support. It does so for the past four
years. The key line to look at is Line 26f
that shows the public support fraction for the
past four years. The public support
fraction is the percentage of a filer’s
total support made up by public support.
Generally, the public support fraction must be
more than a third for a group to qualify as a
public charity (although in some cases it can be
lower). Obviously, the higher the public
support fraction or percentage, the broader the
support the filer has received and, consistent
with what was said above about the depth of an
organization’s support, this fraction may be
of real interest to the reader of the Form
990. (For those who want to derive more
from Part IV-A, the Instructions provide a good
guide.)
#10
Does the Filer Lobby?
A number of nonprofit
groups advocate for changes in public policy and
as part of their advocacy efforts engage in
lobbying. The term “lobbying”
refers to attempts to influence legislators (or
those who work with them) to support or oppose
the enactment of some legislation. It may
be done by directly contacting legislators
(direct lobbying) or by asking others to contact
them (grass roots lobbying). Organizations
exempt under section 501(c)(3) are permitted to
engage in some lobbying, but if they do too much
they may jeopardize their tax-exemption.
Line 1 of Schedule A’s Part III (Statement
of Activities) asks whether the filer attempted
to influence national, state or local legislation
(i.e., did it attempt to lobby). If the
filer answers “Yes,” it must report the
total of expenses incurred in connection with its
lobbying activities and complete the relevant
section of Part VI of Schedule A.
Thus, if a reader of a
filer’s Form 990 wanted to know whether the
filer engaged in any lobbying, she could find
this out by reviewing these parts of Schedule
A. There are several reasons why a reader
may be interested in learning whether a filer has
engaged in lobbying activity. The reader
may think, for example, that groups like the
filer ought not only to help people but in
addition should advocate for changes that will
address the problems that caused its clients to
need help. Or a reader might have different
ideas and believe that groups like the filer
ought to stay completely clear of the political
process and thus not engage in lobbying
activity. In some cases a filer may be a
group that advocates for a position or positions
with which the reader disagrees. She may
then want to know the extent of its lobbying
activity.
As suggested, Line 1 to Schedule A’s Part
III will indicate whether the filer engaged in any lobbying and
if so how much it spent on such activities. More can be learned
by examining Part VI on page 5 of Schedule A. Organizations
complete Part VI-A (Lobbying Expenditures by Electing Public Charities)
if they have chosen under section 501(h) to have the question of
whether they have engaged in a permissible amount of lobbying decided
by how much they spend on lobbying. Groups who have not so
chosen complete Part VI-B (Lobbying Expenditures by Nonelecting
Public Charities). Click here for
an Expansion on the section 501(h) election.
For those filers who have completed Part VIA, a reader, by examining
this part, can learn the total amount the filer spent on lobbying
(Line 38) and of this total amount, how much was spent on grassroots
lobbying (Line 36) and how much on direct lobbying (Line 37).
As noted, organizations that have not chosen
to have the question of whether they have engaged in a permissible
amount of lobbying decided by how much they spend on lobbying must
complete Part VI-B. By examining this part a reader can learn
a fair amount about the filer’s lobbying activities, including
detailed descriptions of such activities. This kind of descriptive
information is not required by those who complete Part VIA Those
who complete Part VI-B also must report a fair amount about their
lobbying expenditures.
If, as sometimes happens,
Part VI is left blank or incomplete or is
incorrectly completed, a reader may infer from
this that the filer may be trying to hide
something or that the filer does not know how to
complete Part VI or did not make the effort
required to complete it accurately. She may
make whatever inferences and draw whatever
conclusions she thinks appropriate from any of
these findings.
Copyright © 2006
Nonprofit Coordinating Committee of New York, Inc.
1350 Broaday, Suite 1801
New York, NY 10018
212-502-4191
www.npccny.org
How to Read the IRS Form 990 & Find Out What it Means can be accessed online at www.npccny.org/Form_990/990.htm
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