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                                                                                                 Department of the Treasury
                                                                                                 Internal Revenue Service
2023

Instructions for Schedule A 

(Form 990)

Public Charity Status and Public Support

Section references are to the Internal Revenue Code unless         If the accounting method the organization used in 
otherwise noted.                                                completing the 2022 Schedule A (Form 990) was different 
                                                                from the accounting method checked on the 2023 Form 990, 
Future developments.  For the latest information about          Part XII, line 1, or the 2023 Form 990-EZ, line G, the 
developments related to Form 990 and its instructions, such     organization shouldn't report in either Part II or Part III the 
as legislation enacted after they were published, go to         amounts reported in the applicable columns of the 2022 
IRS.gov/Form990.                                                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 
General Instructions                                            2023 Form 990-EZ, line G.
Note. Terms in bold are defined in the Glossary of the                  If the organization changed its accounting method 
Instructions for Form 990, Return of Organization Exempt        TIP     from a prior year, it should provide an explanation in 
From Income Tax.                                                        Schedule O (Form 990), Supplemental Information to 
                                                                Form 990 or 990-EZ.
Purpose of Schedule
Schedule A (Form 990) is used by an organization that files        Example 1. An organization checks “Cash” on Form 990, 
Form 990, Return of Organization Exempt From Income Tax,        Part XII, line 1. It should report the amounts in Part II or Part III 
or Form 990-EZ, Short Form Return of Organization Exempt        using the cash method. If the organization filed a 2022 
From Income Tax, to provide the required information about      Schedule A (Form 990) using the cash method, it should 
public charity status and public support.                       report in the 2019 through 2022 columns on the 2023 
                                                                Schedule A (Form 990) the same amounts that it reported in 
Who Must File                                                   the 2019 through 2022 columns on the 2022 Schedule A 
An organization that answered “Yes” to Form 990, Part IV,       (Form 990).
line 1, must complete and attach Schedule A (Form 990) to          Example 2. An organization checks “Accrual” on Form 
Form 990. Any section 501(c)(3) organization (or                990, Part XII, line 1. The organization reports grants on Form 
organization treated as such) that files a Form 990-EZ must     990, Part VIII, line 1, in accordance with the Financial 
complete and attach this schedule to Form 990-EZ. These         Accounting Standards Board FASB ASC 958 (see the 
include:                                                        instructions for Form 990, Part VIII, line 1). During the year, 
• Organizations that are described in section 501(c)(3) and     the organization receives a grant to be paid in future years. 
are public charities;                                           The organization should report the grant's present value on 
• Organizations that are described in sections 501(e),          the 2023 Schedule A (Form 990). The organization should 
501(f), 501(j), 501(k), or 501(n); and                          report accruals of present value increments to the unpaid 
• Nonexempt charitable trusts described in section              grant on Schedule A (Form 990) in future years.
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        Specific Instructions
provide all of the information requested, including the 
                                                                Part I. Reason for Public Charity 
required schedules.
      Any organization that is exempt from tax under            Status
TIP   section 501(c)(3) but is a private foundation and not a 
      public charity shouldn't file Form 990, Form 990-EZ,      Lines 1–12 (in general)
or Schedule A (Form 990), but should file Form 990-PF,          Check only one of the boxes on lines 1 through 12 to indicate 
Return of Private Foundation or Section 4947(a)(1) Trust        the reason the organization is a public charity for the tax 
Treated as Private Foundation. See the instructions to Part I.  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 
Accounting Method
                                                                it can be different. An organization that doesn't check any of 
When completing Schedule A (Form 990), the organization         the boxes on lines 1 through 12 shouldn't file Form 990, Form 
must use the same accounting method it checked on Form          990-EZ, or Schedule A (Form 990) for the tax year, but 
990, Part XII, line 1, or Form 990-EZ, line G. The organization should file Form 990-PF instead.
must use this accounting method in reporting all amounts on 
Schedule A (Form 990), regardless of the accounting method         If an organization believes there is more than one reason 
it used in completing Schedule A (Form 990) for prior years,    why it is a public charity, it should check only one box but can 
except that in Part V, Sections D and E, distributions must be  explain the other reasons it qualifies for public charity status 
reported on the cash receipts and disbursements method.         in Part VI. An organization that claims a public charity status 

Nov 14, 2023                                             Cat. No. 11294Q



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other than section 170(b)(1)(A)(vi) can also demonstrate that           509(a)(3). Based on Rev. Proc. 2023-5, the organization 
it qualifies under section 170(b)(1)(A)(vi) by completing Part          submitted a Form 8940 request to the IRS to change its 
II; it may want to do so for purposes such as qualifying for the        classification to public charity status under section 509(a)(2). 
first Special Rule in Schedule B (Form 990), Schedule of                For the tax year, it meets the requirements of section 509(a)
Contributors, by meeting the 33 / % support test.1 3                    (2). The organization received a determination letter that it 
                                                                        has been reclassified as a public charity under section 509(a)
  The IRS doesn't update its records on an organization's               (2). The organization should check the box on line 10 and 
public charity status based on a change the organization                complete Part III.
makes on Schedule A (Form 990). Thus, an organization that 
checks a public charity status different from the reason stated         Example 5.          The organization received an exemption 
in its exemption letter or subsequent determination letter,             letter that it is a public charity under section 170(b)(1)(A)(vi). 
although not required, may submit a request to the IRS                  For the tax year, it doesn't meet the requirements for public 
Exempt Organizations Determinations Office for a                        charity status under section 170(b)(1)(A)(vi) or 509(a)(2), or 
determination letter confirming that it qualifies for the new           as a supporting organization under section 509(a)(3). Nor 
public charity status if the organization wants the IRS records         does it meet the requirements for public charity status under 
to reflect that new public charity status (also referred to as          any other provision of the Internal Revenue Code. The 
“private foundation status”). See the Instructions for Form             organization is a private foundation and shouldn't file Form 
8940, Request for Miscellaneous Determination. You must                 990, Form 990-EZ, or Schedule A (Form 990) for the tax year 
complete and submit Form 8940 with payment of a user fee                but should file Form 990-PF instead.
through Pay.gov. The user fees are listed in Rev. Proc.                 Example 6.          The organization received an exemption 
2023-5, 2023-1 I.R.B. 265 (updated annually).                           letter that it is a supporting organization under section 
                                                                        509(a)(3). The letter doesn't state which type of supporting 
  A subordinate organization of a group exemption that                  organization it is. The organization should review the 
is filing its own return, but hasn't received its own tax               instructions for lines 12a through 12d to determine which 
exemption determination letter from the IRS, should check               type best describes the organization. The organization may 
the public charity status box which most accurately describes           wish to file Form 8940 to request a determination of type.
its public charity status.
                                                                        Line 1. Check the box for a church, convention of churches, 
  An organization that doesn't know the public charity status           or association of churches. Pub. 1828, Tax Guide for 
stated in its exemption letter or subsequent determination              Churches and Religious Organizations, lists certain 
letter should call the Exempt Organizations Customer                    characteristics generally attributed to churches. These 
Account Services toll free at 877-829-5500 or write to:                 attributes of a church have been developed by the IRS and 
                                                                        by court decisions. They include: distinct legal existence, 
  Internal Revenue Service                                              recognized creed and form of worship, definite and distinct 
  TE/GE Customer Account Services                                       ecclesiastical government, formal code of doctrine and 
  P.O. Box 2508                                                         discipline, distinct religious history, membership not 
  Cincinnati, OH 45201                                                  associated with any other church or denomination, 
                                                                        organization of ordained ministers, ordained ministers 
See the following examples.                                             selected after completing prescribed courses of study, 
  Example 1.        The organization received an exemption              literature of its own, established places of worship, regular 
letter that it is a public charity under section 170(b)(1)(A)(vi).      congregations, regular religious services, Sunday schools for 
For the tax year, it meets the requirements for public charity          the religious instruction of the young, and schools for the 
status under section 170(b)(1)(A)(vi). The organization                 preparation of its ministers. The IRS generally uses a 
should check the box on line 7 and complete Part II.                    combination of these characteristics, together with other facts 
                                                                        and circumstances, to determine whether an organization is 
  Example 2.        The organization received an exemption              considered a church for federal tax purposes.
letter that it is a public charity under section
170(b)(1)(A)(vi). For the tax year, it doesn't meet the                 Line 2. Check the box for a school whose primary function 
requirements for public charity status under section                    is the presentation of formal instruction, which regularly has a 
170(b)(1)(A)(vi). Instead, it meets the requirements for public         faculty, a curriculum, an enrolled body of students, and a 
charity status under section 509(a)(2). The organization                place where educational activities are regularly conducted. A 
should check the box on line 10 and complete Part III.                  private school must have a racially nondiscriminatory policy 
  Example 3.        The organization received an exemption              toward its students. For details about these requirements, 
letter that it is a public charity under section 509(a)(2). For the     see Schedule E (Form 990), Schools, and its related 
tax year, it doesn't meet the requirements for public charity           instructions.
status under section 509(a)(2) or 170(b)(1)(A)(vi). Instead, it                 An organization that checks the box on line 2 must 
meets the requirements for public charity status as a                   TIP     also complete Schedule E (Form 990), Schools.
supporting organization under section 509(a)(3). The 
organization should:
                                                                        Line 3. Check the box for an organization whose main 
  1. Check the box for line 12 and either line 12a, 12b, 12c,           purpose is to provide hospital or medical care. A 
or 12d;                                                                 rehabilitation institution or an outpatient clinic can qualify as a 
  2. Complete line 12f;                                                 hospital if its principal purposes or functions are the providing 
  3. Complete the table on line 12g; and                                of hospital or medical care, but the term doesn't include 
                                                                        medical schools, medical research organizations, 
  4. Complete Part IV and (if applicable) Part V.                       convalescent homes, homes for children or the aged, or 
  Example 4.        The organization received an exemption              vocational training institutions for handicapped individuals.
letter that it is a supporting organization under section 

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Check the box on line 3 also for a cooperative hospital                 Line 6. Only a federal, state, or local government or 
service organization described in section 501(e).                       governmental unit that has received an exemption letter 
        The definition of hospital for Schedule A (Form 990),           recognizing it as exempt from tax under section 501(c)(3) 
TIP     Part I, is different from the definition for Schedule H         should check this box. See Rev. Rul. 60-384, 1960-2 C.B. 
        (Form 990), Hospitals. Accordingly, see Who Must                172.
File in the Instructions for Schedule H (Form 990) about                Line 7. Check the box and complete Part II if the 
whether the organization is also required to complete                   organization meets one of the section 170(b)(1)(A)(vi) public 
Schedule H (Form 990).                                                  support tests. See the instructions for Part II regarding how 
                                                                        an organization can qualify as a publicly supported 
Line 4. Check the box for an organization whose principal               organization under section 170(b)(1)(A)(vi).
purpose or function is to engage in medical research, and 
that is directly engaged in the continuous active conduct of            Line 8. Check the box and complete Part II if the 
medical research in conjunction with a hospital. The hospital           organization is a community trust and meets a section
must be described in section 501(c)(3) or operated by the               170(b)(1)(A)(vi) public support test. A community trust is a 
federal government, a state or its political subdivision, a U.S.        charity that attracts large contributions for the benefit of a 
territory or its political subdivision, or the District of Columbia.    particular community or area, often initially from a small 
If the organization primarily gives funds to other                      number of donors, and is generally governed by 
organizations (or grants and scholarships to individuals) for           representatives of its particular community or area. See 
them to do the research, the organization isn't a medical               Regulations sections 1.170A-9(f)(10), (11), and (12).
research organization.                                                          A community trust claiming it qualifies as a public 
The organization isn't required to be an affiliate of the               !       charity should check the box on line 8 whether it is 
hospital, but there must be a joint effort by the organization          CAUTION structured as a corporation or as a trust.
and the hospital to maintain continuing close cooperation in 
the active conduct of medical research.                                 Line 9. Check the box if the organization is an agricultural 
                                                                        research organization described in section 170(b)(1)(A)(ix) 
        The definition of medical research for Schedule A               operated in conjunction with a land-grant college or university 
TIP     (Form 990), Part I, is different from the definition for        or a non-land grant college of agriculture. Enter the name, 
        Schedule H (Form 990), Hospitals. Accordingly,                  city, and state of the college or university. You don't have to 
research that is medical research for purposes of determining           complete Part II.
whether an organization is a medical research organization 
isn't necessarily medical research for Schedule H (Form 990)            Line 10. Check the box and complete Part III if the 
reporting purposes.                                                     organization meets both of the section 509(a)(2) support 
                                                                        tests. See the instructions for Part III regarding how an 
Assets test/expenditure test.  An organization qualifies as             organization can qualify as a publicly supported organization 
a medical research organization if its principal purpose is             under section 509(a)(2).
medical research, and if it devotes more than half its assets,          Line 11. Check the box only if the organization has received 
or spends at least 3.5% of the fair market value of its                 a ruling from the IRS that it is organized and operated 
endowment, directly in conducting medical research. Either              primarily to test for public safety.
test can be met based on a computation period consisting of 
the immediately preceding tax year or the immediately                   Lines 12 and 12a–12d.       If the organization is a supporting 
preceding 4 tax years.                                                  organization, check the box for line 12 and then check the 
                                                                        appropriate box for line 12a, 12b, 12c, or 12d to indicate the 
If an organization doesn't satisfy either the assets test or            type of supporting organization it is. The organization must 
the expenditure test, it can still qualify as a medical research        also complete lines 12e and 12f, the table on line 12g, and 
organization based on the circumstances involved.                       Part IV. If the organization is a Type III non-functionally 
These tests are discussed in Regulations sections                       integrated supporting organization, it must also complete
1.170A-9(d)(2)(v) and (vi). Under these tests, value the                Part V.
organization's assets as of any day in its tax year using the           For more information about supporting organizations, see 
same day every year, and value the endowment at fair market             Regulations section 1.509(a)-4 and sections 509(a)(3) and 
value using commonly accepted valuation methods. See                    509(f). For a brief overview of the requirements for 
Regulations section 2031.                                               qualification as a supporting organization, and the different 
Line 5. Check the box and complete Part II if the                       types of supporting organizations, see Pub. 557, Tax-Exempt 
organization receives and manages property for and expends              Status for Your Organization, and visit IRS.gov/Charities-Non-
funds to benefit a college or university that is owned or               Profits/Section-509(a)(3)-Supporting-Organizations.
operated by one or more states or political subdivisions. The           Use the information later to determine the supporting 
school must be an organization described in the instructions            organization's type. If the organization checks the box on 
for line 2.                                                             line 12e, the letter the organization received from the IRS 
Expending funds to benefit a college or university includes             identifies its type. If the box checked on any of lines 12a 
acquiring and maintaining the campus, its buildings and                 through 12d is different from the type stated in the letter (for 
equipment, granting scholarships and student loans, and                 example, because the organization has made significant 
making any other payments in connection with the normal                 changes to its structure or operations resulting in it no longer 
functions of colleges and universities.                                 qualifying as the type of supporting organization indicated in 
The organization must meet the same public support test                 its letter), provide an explanation in Part VI. If the organization 
described later for line 7. See Rev. Rul. 82-132, 1982-2 C.B.           doesn't check the box on line 12e, it should check the box on 
107.                                                                    line 12a, 12b, 12c, or 12d that best describes the type of 
                                                                        supporting organization it is.

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        All supporting organizations, regardless of type, must       Line 12e.  The organization's exemption letter or subsequent 
  !     be responsive to the needs or demands of one or              determination letter may state the type of supporting 
CAUTION more supported organizations, and must constitute 
                                                                     organization it is. If it does, check the box on this line. If the 
an integral part of, or maintain a significant involvement in,       letter doesn't state the type, or if the letter states Type III but 
the operations of one or more supported organizations.               doesn't specify whether functionally integrated or 
Although Type III supporting organizations have specific             non-functionally integrated, leave this line blank.
“responsiveness” and “integral part” tests that must be met, 
the relationship between a Type I or Type II supporting                 A grantor to a section 509(a)(3) supporting organization, 
organization and its supported organization(s) must also             acting in good faith, can rely on this letter in determining 
include these responsiveness and integral part                       whether the organization is a Type I Type II Type III , , 
characteristics. The ability of the supported organization(s) in     functionally integrated, or Type III non-functionally integrated 
a Type I or Type II relationship effectively to control the          supporting organization until the IRS makes a public 
supporting organization's board generally ensures that these         announcement of the entity’s change in status. See Rev. 
characteristics are present. If they aren't present, however,        Proc. 2018-32, 2018-23 I.R.B. 739.
don't check any box for lines 12a through 12d. For more              Line 12f.  A supporting organization must be organized and 
information, see Regulations sections 1.509(a)-4(f)(3) and           operated exclusively to support or benefit one or more 
(4).                                                                 specified publicly supported organizations. Please write in 
                                                                     the space provided the number of supported organizations. 
• Type I. A Type I supporting organization is operated,              Include all supported organizations that the organization was 
supervised, or controlled by one or more publicly supported          organized to support at any time during the tax year, whether 
organizations . If the organization otherwise qualifies as a         or not they actually received support during the tax year.
supporting organization and can answer “Yes” to the following 
question, check the box for Type I.                                  Line 12g.  An organization checking a box on line 12a, 12b, 
                                                                     12c, or 12d must complete the table on line 12g.
  Do the supported organizations have a substantial degree 
of direction over the policies, programs, and activities of the      •  Columns (i) and (ii). Enter the name and employer 
                                                                     identification number (EIN) for each supported 
supporting organization, typically by ensuring that the 
                                                                     organization counted on line 12f. If the organization had 
governing body, officers, or membership of the supported 
                                                                     more than five supported organizations during the tax year, 
organizations may regularly appoint or elect a majority of the 
                                                                     enter the additional organizations on duplicate pages of 
supporting organization's directors or trustees?
                                                                     Schedule A (Form 990), Part I. Use as many duplicate copies 
• Type II. A Type II supporting organization is supervised 
                                                                     as needed, and number each page.
or controlled in connection with one or more publicly 
supported organizations. If the organization otherwise               •  Column (iii). For each supported organization named in 
                                                                     column (i), enter the line number (from lines 1 through 10 
qualifies as a supporting organization and can answer “Yes” 
                                                                     above) that best describes the foundation status of the 
to the following question, check the box for Type II.
                                                                     supported organization.
  Do the same persons, such as directors, trustees, and 
officers, supervise or control the supported organization(s)            Example 1.   If the supported organization is a hospital, 
and the supporting organization?                                     then that is an organization described in section 170(b)(1)(A)
• Type III—Functionally integrated. Check this box if the            (iii), and you should enter “3” in column (iii).
organization qualifies as a Type III functionally integrated            Example 2.   If the supported organization is a federal, 
supporting organization by meeting the following                     state, or local governmental unit, or foreign government, then 
requirements.                                                        that is an organization described in section 170(b)(1)(A)(v), 
  1. The organization meets the notification requirement             and you should enter “6” in column (iii).
described in Part IV, Section D, line 1;                                Example 3.   If the supported organization is exempt under 
  2. The organization meets the responsiveness test (both            section 501(c)(4), 501(c)(5), or 501(c)(6), but can be 
the relationship requirement and the significant voice               supported by a supporting organization (see Regulations 
requirement) described in Part IV, Section D, lines 2 and 3;         section 1.509(a)-4(k)), enter the line number (from lines 1 
and                                                                  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. The organization meets one of the alternative integral 
                                                                     (3) organization. Identify the specific code section (501(c)(4), 
part tests described in Part IV, Section E.
                                                                     501(c)(5), or 501(c)(6)) for each such supported organization 
• Type III—Non-functionally integrated. Check this box if 
                                                                     in Part VI.
the organization qualifies as a Type III non-functionally 
integrated supporting organization by meeting the following                  The only correct entry in column (iii) is a line number 
requirements.                                                           !    (from lines 1 through 10) that corresponds to the 
  1. The organization meets the notification requirement             CAUTION description of the supported organization.
described in Part IV, Section D, line 1;                             •  Column (iv). Check “Yes” if the supported organization 
  2. The organization meets the responsiveness test (both            named in column (i) is specifically named as a supported 
the relationship requirement and the significant voice               organization in the organization's declaration of trust, articles 
requirement) described in Part IV, Section D, lines 2 and 3;         of incorporation, or other governing document. If the 
and                                                                  supported organization is not named in the organizing 
  3. The organization meets the integral part test by                documents, check “No” and explain why in Part VI.
meeting either (a) the distribution and attentiveness                •  Column (v). Enter the total amount of monetary support 
requirements described in Part V, or (b) the alternative             paid to, or for the benefit of, the supported organization 
integral part test for certain trusts in existence on November       named in column (i) during the tax year. Such monetary 
20, 1970, described in Part V, line 1.                               support may include making payments to or for the use of 
                                                                     individual members of the charitable class benefited by the 

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supported organization (such as scholarships), and to 501(c)         admissions, merchandise, services, or the use of facilities in 
(3) public charities operated, supervised, or controlled             a related activity, report the membership fees on line 12. To 
directly by or in connection with the supported organization.        the extent that the membership fees are payments to 
See Regulations section 1.509(a)-4(e). If no monetary                purchase admissions, merchandise, services, or the use of 
support was provided during the tax year, enter “0”.                 facilities in an unrelated business activity, report the 
• Column (vi). In this column, the organization may (but             membership fees on line 9. See Regulations section 
isn't required to) provide an estimate of the fair market value      1.170A-9(f)(7)(iv). Include qualified sponsorship payments 
of goods, other property, services, and use of facilities that is    under section 513(i).
provided to or for the benefit of the supported organizations        Noncash contributions.  Use any reasonable method to 
during the tax year. Describe in Part VI any such goods, other       determine the value of noncash contributions reported on 
property, services, and use of facilities, whether or not an         line 1.
amount is reported for them in column (vi).                          Don't report any donations of services (such as the value 
                                                                     of donated advertising space or broadcast air time) or 
Part II. Support Schedule for 
                                                                     donations of use of materials, equipment, or facilities, on 
Organizations Described in Sections                                  line 1 as gifts, grants, or contributions. Donated services and 
                                                                     facilities from a governmental unit only are reported on 
170(b)(1)(A)(iv) and 170(b)(1)(A)(vi)                                line 3.
        If the organization checked a box in Part I, on line 5,      Loss on uncollectible pledge.      If an organization records 
                                                                     a loss on an uncollectible pledge that it reported on a prior 
CAUTION appropriate dollar amounts. Don't leave Part II blank 
    !   7, or 8, it should complete Part II and insert the           year's Schedule A (Form 990), it should deduct that loss from 
or report only zeros if the organization had any support during      the contribution amount for the year in which it originally 
the period. If the organization checks the box in Part II, on        counted that contribution as revenue. For example, if in the 
line 13, it should stop there and not complete the rest of Part      prior tax year the organization reported a pledged 
II.                                                                  contribution with a then-present value of $50,000 in Part II, 
                                                                     line 1, column (e), but learned during the current tax year that 
        If the organization checked a box in Part I, on line 5,      it wouldn't receive any of that pledged contribution, it should 
  TIP   7, or 8 and also checks the box in Part II, on line 18,      deduct the $50,000 from the amount reported in Part II, 
        the organization should complete Part III to determine       line 1, column (d), for the prior tax year.
if it qualifies as a publicly supported organization under           Support from a governmental unit.          Include on line 1 
section 509(a)(2). If it does qualify, the organization should       support received from a governmental unit. This includes 
instead check the box in Part I, on line 10.                         contributions, but not gross receipts from exercising or 
                                                                     performing the organization's tax-exempt purpose or 
Public Support Test. For an organization to qualify as a             function, which should be reported on line 12. An amount 
publicly supported organization under section 170(b)(1)(A)           received from a governmental unit is treated as gross 
(vi), either:                                                        receipts from exercising or performing the organization's 
• 33 / % or more of its total support must come from 1 3             tax-exempt purpose or function if the purpose of the payment 
governmental units, contributions from the general public,           is primarily to serve the direct and immediate needs of the 
and contributions or grants from other public charities; or          payor governmental unit, and is treated as a contribution, if 
• 10% or more of its total support must come from                    the purpose is primarily to provide a direct benefit to the 
governmental units, contributions from the general public,           public. For example, a payment to maintain library facilities 
and contributions or grants from other public charities and the      that are open to the public should be treated as a 
facts and circumstances indicate it is a publicly supported          contribution. See Regulations section 1.170A-9(f)(8) and 
organization.                                                        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 
Note. An organization won't meet either of these public              addressing the distinction between government payments 
support tests if almost all of its support comes from gross          that are contributions and government payments that are 
receipts from related activities and an insignificant amount of      gross receipts from activities related to the organization's 
its support comes from governmental units and                        tax-exempt purpose or function. Medicare and Medicaid 
contributions made directly or indirectly by the general             payments are treated as gross receipts from patients rather 
public.                                                              than as contributions from the government payor for 
    Public support is measured using a 5-year computation            purposes of the public support test. See Rev. Rul. 83-153, 
period that includes the current and 4 prior tax years               1983-2 C.B. 48.
(including short years). If the organization's current tax year 
                                                                            The Coronavirus Aid, Relief, and Economic Security 
or any of its 4 prior tax years were short years, explain in Part 
                                                                     TIP    Act (CARES Act) established the Paycheck 
VI.
                                                                            Protection Program (PPP) to provide loans to small 
    If the organization wasn't a section 501(c)(3) organization      businesses as a direct incentive to keep their workers on the 
for the entire 5-year period in Part II, report amounts only for     payroll. The loans are forgiven if all employee retention 
the years the organization was a section 501(c)(3)                   criteria are met and the funds are used for eligible expenses. 
organization.                                                        Amounts of PPP loans that are forgiven may be reported on 
Line 1. Don't include any “unusual grants.” See Unusual              line 1 as contributions from a governmental unit in the tax 
grants, later. Include membership fees only to the extent to         year when the amounts are forgiven or at such other time as 
which the fees are payments to provide support for the               provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.
organization rather than to purchase admissions,                     Unusual grants.   Unusual grants are generally substantial 
merchandise, services, or the use of facilities. To the extent       contributions and bequests from disinterested persons and 
that the membership fees are payments to purchase                    are:

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1. Attracted because of the organization's publicly                  revenue or assets on Form 990-EZ, explain in Part VI the 
supported nature,                                                    basis for characterizing such transfers as contributions but 
2. Unusual and unexpected because of the amount, and                 not as revenue or assets. For example, if an organization is a 
                                                                     community foundation that receives and holds a cash transfer 
3. Large enough to endanger the organization's status as             for another tax-exempt organization and reports contributions 
normally meeting either the 33 / % public support test or the 1 3
                                                                     of such property on Schedule A (Form 990), Part II, line 1, 
10%-facts-and-circumstances test.                                    without reporting it on Form 990 as revenue in Part VIII or 
For a list of other factors to be considered in determining          assets in Part X, explain the basis for characterizing the 
whether a grant is an unusual grant, see Regulations section         property as contributions but not as revenue or assets.
1.509(a)-3(c)(4).                                                    Line 2. Enter tax revenue levied for the organization's benefit 
An unusual grant is excluded even if the organization                by a governmental unit and either paid to the organization 
receives or accrues the funds over a period of years.                or expended on its behalf. Report this amount whether or not 
Don't report gross investment income items as unusual                the organization includes this amount as revenue on its 
grants. Instead, include all investment income on line 8.            financial statements or elsewhere on Form 990 or 990-EZ.
See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations                    Line 3. Enter the value of services or facilities furnished by a 
section 1.170A-9(f)(6)(ii); and Regulations sections                 governmental unit to the organization without charge. Don't 
1.509(a)-3(c)(3) and (4) for details about unusual grants.           include the value of services or facilities generally furnished 
Include in Part VI a list showing the amount, but not the            to the public without charge. For example, include the fair 
grantor, of each unusual grant actually received each year (if       rental value of office space furnished by a governmental unit 
the cash accounting method is used) or accrued each year (if         to the organization without charge but only if the 
the accrual accounting method is used).                              governmental unit doesn't generally furnish similar office 
                                                                     space to the public without charge. Report these amounts 
        Don't include the names of the grantors because Part         whether or not the organization includes these amounts as 
!       VI will be made available for public inspection.             revenue on its financial statements or elsewhere on Form 990 
CAUTION                                                              or 990-EZ.
Unusual grants recordkeeping.     An organization that 
received any unusual grants during the 5-year period should          Line 5. Enter in column (f) the portion of total contributions 
also keep for its records a list showing, for each year, the         by each individual, trust, or corporation included on line 1 for 
name of the contributor, the date and amount of the grant,           the years reported that exceeds 2% of the amount reported in 
and a brief description of the grant. If the organization used       line 11, column (f). In applying the 2% limitation, all 
the cash method for the applicable year, show only the               contributions made by a donor and by any person or persons 
amounts the organization actually received during that year. If      standing in a relationship to the donor that is described in 
the organization used the accrual method for the applicable          sections 4946(a)(1)(C) through (a)(1)(G) and the related 
year, show only the amounts the organization accrued for that        regulations (for example, spouses and certain other family 
year. An example of this list is given below.                        members, and entities where ownership or control interests 
                                                                     exceed a threshold level) will be treated as made by one 
        Don't file this list with the organization's Form 990 or     person. However, the 2% limitation doesn't apply to 
!       990-EZ because it may be made available for public           contributions from organizations qualifying as publicly 
CAUTION inspection.                                                  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 
Line 1. Example—List of unusual grants                               also qualify as publicly supported organizations under 
                                                                     section 170(b)(1)(A)(vi).
Year  2023                    Description 
                                                                     • Churches described in section 170(b)(1)(A)(i),
Name  Mr. Distinguished Donor Undeveloped land                      • Educational institutions described in section 170(b)(1)(A)
                                                                     (ii),
                                                                     • Hospitals described in section 170(b)(1)(A)(iii),
Date of Grant  January 15,                                          • Organizations operated for the benefit of a college or 
2023                                                                 university owned or operated by a governmental unit 
                                                                     described in section 170(b)(1)(A)(iv), and
Amount of Grant  $600,000                                             Agricultural research organizations described in section 
                                                                     •
                                                                     170(b)(1)(A)(ix).
Conservation easements and qualified conservation                      The organization should keep for its records a list showing 
contributions.  The organization must report any qualified           the name of and amount contributed by each donor (other 
conservation contributions and contributions of conservation         than a governmental unit or publicly supported 
easements consistently with how it reports revenue from              organization) whose total gifts during the years reported 
such contributions in its books, records, and financial              exceed 2% of the amount reported in line 11, column (f). An 
statements and in Form 990, Part VIII, Statement of Revenue.         example of this list is given later.
Reporting contributions not reported as revenue.          If the             Don't file this list with the organization's Form 990 or 
organization reports any contributions on line 1 of                    !     990-EZ because it may be made available for public 
Schedule A (Form 990), Part I, that it doesn't report on Form        CAUTION inspection.
990 as revenue in Part VIII or as assets in Part X, or as 

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Line 5. Example—List of donors other than governmental units and publicly supported organizations
Assumption: 2% of the amount on Schedule A (Form 990), Part II, line 11, column (f), is $12,000.
Contributors whose total gifts from 2018 through 2022 were in excess of the 2% limitation 
                       (a)         (b)                   (c)           (d)                                        (e)                     (f)       (g)
      Name             2019        2020                  2021          2022                                     2023                    Total       Excess 
                                                                                                                                                    contributions 
                                                                                                                                                    (column (f) 
                                                                                                                                                    minus the 2% 
                                                                                                                                                    limitation)
XYZ Foundation                                               $59,000                          $3,000                $18,000                 $80,000 $68,000 
Banana Office          $12,000                                                                $3,000                  $1,000                $16,000    $4,000 
Supply 
Plum Corporation                                             $15,000                        $15,000                                         $30,000 $18,000 
John Smith             $5,000      $5,000                     $5,000                          $1,000                                        $16,000    $4,000 
Sue Adams                          $10,000                                                  $10,000                 $10,000                 $30,000 $18,000 
Raisin Trade                                                 $20,000                          $7,000                                        $27,000 $15,000 
Assoc. 
Total. Add the items in column (g). Enter the total here and on Part II, column (f), line 5 . . . . . . . . . . . . . . . . . . . . . . . . . . . . $127,000 

Line 8. Include the gross income from interest, dividends,           • A trade or business in which substantially all work is 
payments with respect to securities loans (section 512(a)(5)),       performed by volunteers (such as book fairs and sales of gift 
rents, royalties, and income from similar sources. Don't             wrap paper). See section 513(a)(1).
include on this line payments that result from activities of the     • A trade or business carried on by the organization primarily 
organization that further its exempt purpose. Instead, report        for the convenience of its members, students, patients, 
these amounts on line 12.                                            officers, or employees. See section 513(a)(2).
                                                                     • A trade or business which is the selling of merchandise, 
Line 9. Enter the organization's net income from conducting          substantially all of which the organization received as gifts or 
unrelated business activities, whether or not the activities         contributions. See section 513(a)(3).
are regularly conducted as a trade or business. See sections         • “Qualified public entertainment activities” or “qualified 
512 and 513 and the applicable regulations. Include                  convention and trade show activities” of certain 
membership fees to the extent they are payments to                   organizations. See section 513(d).
purchase admissions, merchandise, services, or the use of            • Furnishing certain hospital services. See section 513(e).
facilities in an activity that is an unrelated business.             • A trade or business consisting of conducting bingo 
When calculating unrelated business taxable income                   games, but only if the conduct of such games is lawful. See 
(UBTI) for this purpose, an exempt organization with more            section 513(f).
than one unrelated trade or business may use either its UBTI         • Qualified pole rentals by a mutual or cooperative telephone 
calculated under section 512(a)(6) or its UBTI calculated in         or electric company. See section 513(g).
the aggregate. If a net loss results, enter “0” on this line.        • The distribution of certain low-cost articles incidental to the 
                                                                     solicitation of charitable contributions (except to the extent 
Line 10. Include all support as defined in section 509(d) that 
                                                                     such gross receipts are properly treated as charitable 
isn't included elsewhere in Part II. Explain in Part VI the 
                                                                     contributions reportable on line 1 rather than as proceeds of 
nature and source of each amount reported. Don't include 
                                                                     a sale or exchange), and exchange and rental of members 
gain or loss from amounts reportable on line 12 or from the 
                                                                     lists. See section 513(h).
sale of capital assets.
                                                                     Line 13.                     An organization that checks this box should stop 
Line 12. Enter the total amount of gross receipts the 
                                                                     here and shouldn't complete the rest of Part II. It shouldn't 
organization received from related activities for all years 
                                                                     make a public support computation on line 14 or 15 or check 
reported in Part II. The organization won't be treated as 
meeting the section 170(b)(1)(A)(vi), 33 / % public support 1 3      any of the boxes on lines 16 through 18.
test or the 10%-facts-and-circumstances public support test,           Example.                         An organization receives an exemption letter 
if almost all of its support consists of gross receipts from         from the IRS that it is exempt from tax under section
related activities and an insignificant amount of its support        501(c)(3) and qualifies as a public charity under section 
comes from governmental units and public contributions.              170(b)(1)(A)(vi) effective on its date of incorporation. When 
See Regulations section 1.170A-9(f)(7)(iii).                         the organization prepares Part II for each of its first 5 tax 
Include on line 12 gross receipts from admissions, sales of          years as a section 501(c)(3) organization, it should check the 
merchandise, performance of services, or furnishing of               box on line 13 and shouldn't complete the rest of Part II. 
facilities in any activity which isn't an unrelated trade or         When the organization prepares Part II for its sixth tax year 
business (within the meaning of section 513). See section            and subsequent years, it shouldn't check the box on line 13 
509(d)(2). Include membership fees to the extent they are            and should complete the rest of Part II.
payments to purchase admissions, merchandise, services, or 
the use of facilities in a related activity. For example, include 
on this line gross receipts from:

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      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, 
TIP   (3) organization should make the public support                 16a, 16b, 17a, or 17b, it doesn't qualify as a publicly 
      computations on a copy of Schedule A (Form 990)                 supported organization under section 170(b)(1)(A)(iv) or 
that it keeps for itself. An organization should carefully            170(b)(1)(A)(vi) for the 2023 tax year and should check the 
monitor its public support on an ongoing basis to ensure that         box on this line. If the organization doesn't qualify as a public 
it will meet a public support test in the sixth year and              charity under any of the boxes in Part I, lines 1 through 12, it 
succeeding years.                                                     is a private foundation as of the beginning of the 2023 tax 
                                                                      year for filing purposes and shouldn't file Form 990, Form 
Line 14. Round to the nearest hundredth decimal point in              990-EZ, or Schedule A (Form 990) for the 2023 tax year. 
reporting the percentage of public support. For example, if           Instead, the organization should file Form 990-PF and check 
the organization calculates its public support percentage as          Initial return of a former public charity on Form 990-PF, at the 
58.3456%, this percentage would be rounded to 58.35%                  top of page 1.
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           TIP tax year as a section 501(c)(3) organization, the 
the 2022 Schedule A (Form 990), Part II, line 14. Round to                organization should figure the public support 
the nearest hundredth decimal point in reporting the                  percentage on its Form 990 or 990-EZ for its first 5 tax years 
percentage of public support.                                         before it checks the box on line 18. If its public support 
Line 16a. If the organization didn't check the box on line 13,        percentage for its first 5 tax years is 33 / % or more, or if it 1 3
and line 14 is 33 / % or more, 1 3 check the box on this line         meets the 10%-facts-and-circumstances test for its first 5 tax 
and don't complete the rest of Part II. The organization              years, it will qualify as a public charity for its sixth tax year. If 
qualifies as a publicly supported organization for 2023 and           the organization qualifies under the 10% test, explain in Part 
2024.                                                                 VI.

Line 16b. If the organization didn't check a box on line 13 or            If the organization doesn't qualify as a publicly 
16a, and line 15 is 33 / % or more, 1 3 check the box on this         TIP supported organization under section 170(b)(1)(A)
line and don't complete the rest of Part II. The                          (vi), it can complete Part III to determine if it qualifies 
organization qualifies as a publicly supported organization for       as a publicly supported organization under section 509(a)(2).
2023.
Line 17a. If the organization didn't check a box on line 13,          Part III. Support Schedule for 
16a, or 16b, and line 14 is 10% or more, and if the 
organization meets the facts-and-circumstances test, check            Organizations Described in Section 
the box on this line and don't complete the rest of Part              509(a)(2)
II. The organization qualifies as a publicly supported 
organization for 2023 and 2024.                                           If an organization checked the box in Part I, for 
  If this box is checked, explain in Part VI how the                  TIP line 10, it should complete Part III and insert the 
organization meets the facts-and-circumstances test in                    appropriate dollar amounts. Don't leave Part III blank 
Regulations section 1.170A-9(f)(3). Include the following             or report only zeros if the organization had any support during 
information.                                                          the period. If the organization checks the box in Part III, for 
• Explain whether the organization maintains a continuous             line 14, it should stop there and not complete the rest of Part 
and bona fide program for solicitation of funds from the              III.
general public, community, membership group involved, 
governmental units, or other public charities.                            If the organization checked the box in Part I, for 
• List all other facts and circumstances, including the               TIP line 10, and also checks the box in Part III, for line 20, 
sources of support, whether the organization has a                        the organization should complete Part II to determine 
governing body that represents the broad interests of the             if it qualifies as a publicly supported organization under 
public, and whether the organization generally provides               section 170(b)(1)(A)(vi). If it does qualify, the organization 
facilities or services directly for the benefit of the general        should instead check the box in Part I, for line 5, 7, or 8, 
public on a continuing basis.                                         whichever applies.
• If the organization is a membership organization, explain 
                                                                      Public Support Test.    For an organization to qualify as a 
whether the solicitation for dues-paying members is designed 
                                                                      publicly supported organization under section 509(a)(2):
to enroll a substantial number of persons from the                                   1 3
community, whether dues for individual members have been              •   More than 33 / % of its support normally must come from 
                                                                      gifts, grants, contributions, membership fees, and gross 
fixed at rates designed to make membership available to a 
                                                                      receipts from admissions, sales of merchandise, 
broad cross-section of the interested public, and whether the 
                                                                      performance of services, or furnishing of facilities in an 
activities of the organization will likely appeal to persons 
                                                                      activity which isn't an unrelated trade or business under 
having some broad common interest or purpose.
                                                                      section 513; and
Line 17b. If the organization didn't check a box on line 13,          •   No more than 33 / % of its support normally must come 1 3
16a, 16b, or 17a, and line 15 is 10% or more, and if the              from gross investment income and net unrelated business 
organization meets the facts-and-circumstances test, check            income (less section 511 tax) from businesses acquired by 
the box on this line and don't complete the rest of Part              the organization after June 30, 1975.
II. The organization qualifies as a publicly supported                    Public support is measured using a 5-year computation 
organization for 2023. If this box is checked, explain in Part VI     period that includes the current and 4 prior tax years 
how the organization meets the facts-and-circumstances test           (including short years). If the organization's current tax year 
in Regulations section 1.170A-9(f)(3). Include the same               or any of its 4 prior tax years were short years, explain in Part 
information identified in the instructions for Line 17a, earlier.     VI.

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In Part III, if the organization wasn't a section 501(c)(3)         than as contributions from the government payor for 
organization for the entire 5-year period, report amounts only      purposes of the public support test. See Rev. Rul. 83-153, 
for the years the organization was a section 501(c)(3)              1983-2 C.B. 48.
organization.
                                                                            The Coronavirus Aid, Relief, and Economic Security 
Line 1. Don't include any “unusual grants.” See Unusual             TIP     Act (CARES Act) established the Paycheck 
grants, later. Include membership fees only to the extent to                Protection Program (PPP) to provide loans to small 
which the fees are payments to provide support for the              businesses as a direct incentive to keep their workers on the 
organization rather than to purchase admissions,                    payroll. The loans are forgiven if all employee retention 
merchandise, services, or the use of facilities. To the extent      criteria are met and the funds are used for eligible expenses. 
that the membership fees are payments to purchase                   Amounts of PPP loans that are forgiven may be reported on 
admissions, merchandise, services, or the use of facilities in      line 1 as contributions from a governmental unit in the tax 
a related activity, include the membership fees on line 2. See      year when the amounts are forgiven or at such other time as 
Regulations section 1.509(a)-3(h). To the extent that the           provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.
membership fees are payments to purchase admissions, 
merchandise, services, or the use of facilities in an activity      Unusual grants.    Unusual grants are generally substantial 
that isn't an unrelated business under section 513, report          contributions and bequests from disinterested persons and 
the membership fees on line 3. To the extent that the               are:
membership fees are payments to purchase admissions,                1. Attracted because of the organization's publicly 
merchandise, services, or the use of facilities in an activity      supported nature,
that is an unrelated business, report the net amount either on      2. Unusual and unexpected because of the amount, and
line 10b or 11, as appropriate.                                     3. Large enough to endanger the organization's status as 
Noncash contributions.  Use any reasonable method to                normally meeting the 33 / % public support test.1 3
determine the value of noncash contributions reported on 
line 1.                                                             For a list of other factors to be considered in determining 
Don't report any donations of services (such as the value           whether a grant is an unusual grant, see Regulations section 
of donated advertising space or broadcast air time) or              1.509(a)-3(c)(4).
donations of use of materials, equipment, or facilities on          An unusual grant is excluded even if the organization 
line 1 as gifts, grants, or contributions. Donated services and     receives or accrues the funds over a period of years.
facilities from a governmental unit are reported on line 5.         Don't report gross investment income items as unusual 
Loss on uncollectible pledge.      If an organization records       grants. Instead, include all investment income on line 10a.
a loss on an uncollectible pledge that it reported on a prior       See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations 
year's Schedule A (Form 990), it should deduct that loss from       section 1.170A-9(f)(6)(ii); and Regulations sections 
the contribution amount for the year in which it originally         1.509(a)-3(c)(3) and (4) for details about unusual grants.
counted that contribution as revenue. For example, if in the 
prior tax year the organization reported a pledged                  Include in Part VI a list showing the amount, but not the 
contribution with a then-present value of $50,000 in Part III,      grantor, of each unusual grant actually received each year (if 
line 1, column (e), but learned during the current tax year that    the cash accounting method is used) or accrued each year (if 
it wouldn't receive any of that pledged contribution, it should     the accrual accounting method is used).
deduct the $50,000 from the amount reported in Part III,                    Don't include the names of the grantors because Part 
line 1, column (d), for the prior tax year.                         !       VI will be made available for public inspection.
Support from a governmental unit.           Include on line 1       CAUTION
support received from a governmental unit. This includes            Unusual grants recordkeeping.       An organization that 
contributions, but not gross receipts from exercising or            received any unusual grants during the 5-year period, should 
performing the organization's tax-exempt purpose or                 also keep for its records a list showing, for each year, the 
function, which should be reported on line 2. Contributions         name of the contributor, the date and amount of the grant, 
are sometimes difficult to distinguish from such gross              and a brief description of the grant. If the organization used 
receipts—the label on the agreement isn't controlling. An           the cash method for the applicable year, show only amounts 
amount received from a governmental unit is treated as gross        the organization actually received during that year. If the 
receipts from exercising or performing the organization's           organization used the accrual method for the applicable year, 
tax-exempt purpose or function if the purpose of the payment        show only amounts the organization accrued for that year. An 
is primarily to serve the direct and immediate needs of the         example of this list is given below.
payor governmental unit. An amount is treated as a 
contribution if the purpose of the payment is primarily to                  Don't file this list with the organization's Form 990 or 
provide a direct benefit to the public. For example, if a state     !       990-EZ because it may be made available for public 
government agency pays an organization to operate an                CAUTION inspection.
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 

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

Disqualified Person         (a) 2019            (b) 2020         (c) 2021       (d) 2022        (e) 2023           (f) Total 
David Smith                    $7,000            $6,000                                         $2,000             $15,000 
Anne Parker                                                      $5,000         $7,000          $4,000              $16,000 
Total                          $7,000            $6,000          $5,000         $7,000          $6,000             $31,000 

Line 1. Example—List of unusual grants                           •    A trade or business consisting of conducting bingo 
                                                                 games, but only if the conduct of such games is lawful. See 
Year  2023                    Description                       section 513(f).
                                                                 •    Qualified pole rentals by a mutual or cooperative telephone 
Name  Mr. Distinguished Donor Undeveloped land                  or electric company. See section 513(g).
                                                                 •    The distribution of certain low-cost articles incidental to the 
Date of Grant  January 15,                                      solicitation of charitable contributions (except to the extent 
2023                                                             such gross receipts are properly treated as charitable 
                                                                 contributions reportable on line 1 rather than as proceeds of 
Amount of Grant  $600,000                                       a sale or exchange), and exchange and rental of members 
                                                                 lists. See section 513(h).
Conservation easements and qualified conservation                     While the activity of soliciting and receiving qualified 
contributions.  The organization must report any qualified       sponsorship payments is also excluded from unrelated 
conservation contributions and contributions of conservation     business (see section 513(i)), the qualified sponsorship 
easements consistently with how it reports revenue from          payments themselves are treated as charitable contributions 
such contributions in its books, records, and financial          reportable on line 1.
statements and in Form 990, Part VIII, Statement of Revenue.     Line 4.  Enter tax revenue levied for the organization's benefit 
Reporting contributions not reported as revenue.         If the  by a governmental unit and either paid to the organization 
organization reports any contributions on Schedule A (Form       or expended on its behalf. Report this amount whether or not 
990), Part III, line 1, that it doesn't report on Form 990, as   the organization includes this amount as revenue on its 
revenue in Part VIII or as assets in Part X, or as revenue or    financial statements or elsewhere on Form 990 or 990-EZ.
assets on Form 990-EZ, explain in Part VI the basis for          Line 5.  Enter the value of services or facilities furnished by a 
characterizing such transfers as contributions but not as        governmental unit to the organization without charge. Don't 
revenue or assets. For example, if an organization is a          include the value of services or facilities generally furnished 
community foundation that receives and holds a cash transfer     to the public without charge. For example, include the fair 
for another tax-exempt organization and reports contributions    rental value of office space furnished by a governmental unit 
of such property on Schedule A (Form 990), Part III, line 1,     to the organization without charge, but only if the 
without reporting it on Form 990, as revenue in Part VIII or     governmental unit doesn't generally furnish similar office 
assets in Part X, explain the basis for characterizing the       space to the public without charge. Report these amounts 
property as contributions but not as revenue or assets.          whether or not the organization includes these amounts as 
Line 2. Include gross receipts from admissions,                  revenue on its financial statements or elsewhere on Form 990 
merchandise sold, services performed, or facilities furnished    or 990-EZ.
in any activity that is related to the organization's tax-exempt Line 7a. Enter the amounts that are included on lines 1, 2, 
purpose (such as charitable, educational, etc.).                 and 3 that the organization received from disqualified 
  To the extent that membership fees are payments to             persons. See the definition of disqualified person in the 
purchase admissions, merchandise, services, or the use of        Glossary of the Instructions for Form 990.
facilities in a related activity, include the membership fees on      For amounts included on lines 1, 2, and 3 that were 
this line 2. See Regulations section 1.509(a)-3(h).              received from a disqualified person, the organization should 
Line 3. Include gross receipts from activities that aren't an    keep for its records a list showing the name of, and total 
unrelated trade or business under section 513, such as:          amounts received in each year from, each disqualified 
• A trade or business in which substantially all work is         person. Enter the total of such amounts for each year on 
performed by volunteers (such as book fairs and sales of gift    line 7a. See an example of this list above.
wrap paper). See section 513(a)(1).
• A trade or business carried on by the organization primarily            Don't file this list with the organization's Form 990 or 
for the convenience of its members, students, patients,               !   990-EZ because it may be made available for public 
officers, or employees. See section 513(a)(2).                   CAUTION  inspection.
• A trade or business that is the selling of merchandise, 
                                                                 Line 7b.  For any gross receipts included on lines 2 and 3 
substantially all of which the organization received as gifts or 
                                                                 from related activities received from a person or from a 
contributions. See section 513(a)(3).
                                                                 bureau or similar agency of a governmental unit, other than 
• “Qualified public entertainment activities” or “qualified 
                                                                 from a disqualified person, that exceed the greater of 
convention and trade show activities” of certain 
                                                                 $5,000 or 1% of the amount on line 13 for the applicable year, 
organizations. See section 513(d).
                                                                 enter the excess on line 7b. The organization should keep for 
• Furnishing certain hospital services. See section 513(e).
                                                                 its records a list showing, for each year, the name of the 
                                                                 person or government agency, the amount received during 

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

        (a) Name            (b) Amount received in        (c) 1% of amount on                 (d) Enter the larger of         (e) 2023 excess 
                                    2023                      line 13 in 2023                   column (c) or $5,000          (column (b) minus 
                                                                                                                              column (d)) 
Word Processing, Inc.               $25,000                         $2,000                                $5,000              $20,000 
Enter on Schedule A (Form 990), column (e), line 7b     . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $20,000 

the applicable year, the larger of $5,000 or 1% of the amount                   Example.        An organization receives an exemption letter 
on line 13 for the applicable year, and the excess, if any. See             from the IRS that it is exempt from tax under section
an example of this list above.                                              501(c)(3) and qualifies as a public charity under section 
                                                                            509(a)(2) effective on its date of incorporation. When the 
        Don't file this list with the organization's Form 990 or 
                                                                            organization prepares Part III for its first 5 tax years, it should 
!       990-EZ because it may be made available for public                  check the box on line 14 and shouldn't complete the rest of 
CAUTION inspection.
                                                                            Part III. When the organization prepares Part III for its sixth 
                                                                            tax year and subsequent years, it shouldn't check the box on 
Line 10a. Include the gross income from interest, dividends,                line 14 and should complete the rest of Part III.
payments received on securities loans (section 512(a)(5)), 
rents, royalties, and income from similar sources. Don't                                An organization in its first 5 years as a section 501(c)
include on this line payments that result from activities of the              TIP       (3) organization should make the public support and 
organization that further its exempt purpose. Instead, report                           investment income computations on a copy of 
these amounts on line 2.                                                    Schedule A (Form 990) that it keeps for itself. An organization 
                                                                            should carefully monitor its public support on an ongoing 
Line 10b. Enter the excess of the organization's unrelated                  basis to ensure that it will meet the public support tests in the 
business taxable income (UBTI) (as defined in section                       sixth year and succeeding years.
512) from trades or businesses that it acquired or 
commenced after June 30, 1975, over the amount of tax                       Line 15.      Round to the nearest hundredth decimal point in 
imposed on this income under section 511. Include                           reporting the percentage of public support. For example, if 
membership fees to the extent they are payments to                          the organization calculates its public support percentage as 
purchase admissions, merchandise, services, or the use of                   58.3456%, this percentage would be rounded to 58.35% 
facilities in an unrelated business activity that is a trade or             when reported on line 15.
business that was acquired or commenced after June 30, 
1975.                                                                       Line 16.      For 2023, enter the public support percentage from 
                                                                            2022 Schedule A (Form 990), Part III, line 15. Round to the 
When calculating UBTI for this purpose, an exempt                           nearest hundredth decimal point in reporting the percentage 
organization with more than one unrelated trade or business                 of public support.
may use either its UBTI calculated under section 512(a)(6) or 
its UBTI calculated in the aggregate.                                       Line 17.      Round to the nearest whole percentage.
Line 11. Enter the organization's net income from                           Line 18.      For 2023, enter the investment income percentage 
conducting unrelated business activities not included on                    from the 2022 Schedule A (Form 990), Part III, line 17. Round 
line 10b, whether or not the activities are regularly conducted             to the nearest whole percentage.
as a trade or business. Don't include net income from                       Line 19a.       If the organization didn't check the box on line 14, 
conducting trades or businesses acquired or commenced by                    line 15 is more than 33 / %, and line 17 isn't more than 1 3
the organization prior to July 1, 1975. See sections 512, 513,              33 / %, 1 3 check the box on this line and don't complete 
and 514, and the applicable regulations. Include membership                 the rest of this schedule. The organization qualifies as a 
fees to the extent they are payments to purchase admissions,                publicly supported organization for 2023 and 2024.
merchandise, services, or the use of facilities in an activity 
that is an unrelated business not included on line 10b.                     Line 19b.       If the organization didn't check the box on line 14 
When calculating UBTI for this purpose, an exempt                           or 19a, line 16 is more than 33 / %, and line 18 isn't more 1 3
organization with more than one unrelated trade or business                 than 33 / %, 1 3    check the box on this line and don't 
may use either its UBTI calculated under section 512(a)(6) or               complete the rest of this schedule. The organization 
its UBTI calculated in the aggregate. If a net loss results,                qualifies as a publicly supported organization for 2023.
enter “0” on this line.                                                     Line 20.      If the organization didn't check the box on line 14, 
Line 12. Include all support as defined in section 509(d) that              19a, or 19b, it doesn't qualify as a publicly supported 
isn't included elsewhere in Part III. Explain in Part VI the                organization under section 509(a)(2) for the 2023 tax year 
nature and source of each amount reported. Don't include                    and should check the box on this line. If the organization 
gain or loss from the sale of capital assets.                               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 
Line 14. An organization that checks this box should stop                   private foundation for filing purposes as of the beginning of 
here and shouldn't complete the rest of Part III. It shouldn't              the tax year and shouldn't file Form 990, Form 990-EZ, or 
make a public support computation on line 15 or 16 or an                    Schedule A (Form 990) for the 2023 tax year. Instead, the 
investment income computation on line 17 or 18, or check                    organization should file Form 990-PF, and check Initial return 
any of the boxes for line 19 or 20.                                         of a former public charity on Form 990-PF, at the top of 
                                                                            page 1.

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        If Form 990 or 990-EZ is for the organization's sixth           Regulations section 1.509(a)-4(k) and the instructions for 
TIP     tax year as a section 501(c)(3) organization and it             Part III. If the organization supports a section 501(c)(4), (5),
        checked the box on line 20, it should figure the public         or (6) organization, check “Yes” for line 3a.
support percentage and the investment income percentage 
                                                                        Line 3b. If the organization confirmed that the supported 
on its Form 990 for its first 5 tax years. If its public support 
percentage for its first 5 tax years is more than 33 / % and 1 3        organization qualified under section 501(c)(4), (5), or (6) and 
                                                                        met the section 509(a)(2) public support test for its most 
the investment income percentage for its first 5 tax years isn't 
more than 33 / %, it will qualify as a public charity for its sixth 1 3 recent tax year, check “Yes” and describe in Part VI how the 
                                                                        organization made this determination. For example, the 
tax year. If the organization qualifies in this manner, explain in 
                                                                        organization may ask its section 501(c)(4), (5), or (6) 
Part VI.
                                                                        supported organization to furnish a copy of its IRS 
        If the organization doesn't qualify as a publicly               determination letter and to complete annually a pro forma 
TIP     supported organization under section 509(a)(2), it              Schedule A (Form 990), Part III, and keep the letter and 
        can complete Part II to determine if the organization           support calculation in the supporting organization’s files.
qualifies as a publicly supported organization under section                 If the supporting organization doesn't annually confirm that 
170(b)(1)(A)(vi).                                                       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 
Part IV. Supporting Organizations
                                                                        section 509(a)(2) if it were described in section 501(c)(3) 
Complete the sections of Part IV that correspond below with             during the tax year.
the type of supporting organization indicated on line 12a, 
12b, 12c, or 12d of Part I.                                             Line 3c. Support given to a supported section 501(c)(4), (5), 
•  Type I: Sections A and B;                                            or (6) organization must be used solely for charitable 
•  Type II: Sections A and C;                                           purposes. If the supporting organization has put into place 
•  Type III Functionally Integrated: Sections A, D, and E; and          measures to ensure that such support is used solely for 
•  Type III Non-Functionally Integrated: Sections A and D,              charitable purposes, check “Yes” and describe those 
and Part V.                                                             measures in Part VI. If not, check “No” and describe in Part VI 
                                                                        how the supporting organization ensured during the tax year 
Section A. All Supporting Organizations                                 that its assets were used solely for charitable purposes.
Line 1. The organization's articles of incorporation or trust           Line 4a. A supporting organization can't qualify for Type III 
instrument must designate the publicly supported                        status in the tax year if any supported organization wasn't 
organization(s) on whose behalf the supporting organization             organized in the United States.
is operated. The articles of a Type I or Type II supporting             Lines 4b and 4c.  A supporting organization must exercise 
organization may designate its supported organization(s)                control and discretion over funds granted to an organization 
either by class or purpose or by name. The articles of a Type           that isn't exempt under section 501(c)(3). See Rev. Rul. 
III supporting organization must designate the supported                68-489, 1968-2 C.B. 210. Also, a domestic charity must 
organization(s) by name, unless a historic and continuing               generally exercise control and discretion over funds granted 
relationship exists between the organizations.                          to a foreign organization. See Rev. Rul. 63-252, 1963-2 C.B. 
   Check “Yes” only if the organization supports no                     101, and Rev. Rul. 66-79, 1966-1 C.B. 48.
organization other than those listed by name in its governing                Explain in Part VI how the organization retained such 
instrument. If the organization supports any organization not           control and discretion despite being controlled or supervised 
specifically listed, check “No” and describe in Part VI how the         by or in connection with such foreign supported 
supported organizations are designated. If designated by                organization(s). Also, explain what controls the organization 
class or purpose, describe the class or purpose. If the                 used to ensure that all support to the foreign supported 
organization and its supported organization(s) have a historic          organization(s) was used exclusively for charitable, 
and continuing relationship, explain that relationship. If              educational, etc., purposes described in section 170(c)(2)(B) 
support of one or more organizations is subject to certain              if the foreign supported organization doesn't have an IRS 
future contingencies, explain those contingencies, and                  determination under sections 501(c)(3) and 509(a)(1) or (2).
explain what organizations will be supported or benefited if 
those contingencies occur.                                              Line 5.  Supporting organizations may add, substitute, or 
                                                                        remove supported organizations only in certain limited 
Line 2. If the organization supported any domestic or foreign           situations. See Regulations section 1.509(a)-4(d). Generally, 
organization (other than an organization described in section           a Type I or Type II supporting organization may add or 
501(c)(4), (5), or (6)) that didn't have an IRS determination of        substitute particular supported organizations within the class 
status under section 509(a)(1) or (2), check “Yes” and explain          or classes designated in its articles, but may not add or 
in Part VI how the organization determined that the supported           substitute supported organizations outside of the designated 
organization was described in section 509(a)(1) or (2) and              class(es). A Type III supporting organization, which must 
why the supported organization doesn't have such an IRS                 specify its supported organizations by name, may only 
determination (for example, because it has applied for but not          substitute supported organizations if such substitution is 
yet received such a determination, or it isn't required to obtain       conditioned upon the occurrence of an event that is beyond 
recognition of its public charity status because it is a church,        the control of the supporting organization (such as a 
a state university, or described in section 4948(b)).                   supported organization’s lapse into private foundation 
Line 3a.  A supporting organization may support an                      status).
organization described in section 501(c)(4), (5), or (6), if the             If the organization has added, substituted, or removed any 
supported organization satisfies the public support tests               supported organization during the tax year, check “Yes” and 
applicable to a section 509(a)(2) organization. See                     provide detail in Part VI, including (i) the names and EINs of 

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the organizations added, substituted, or removed; (ii) the           organization loses its status as a supporting organization. 
reasons for each addition, substitution, or removal; (iii) the       Such supporting organization must file Form 990-PF unless it 
authority under the organization’s organizing document for           qualifies as a public charity under section 509(a)(1) or (2).
each addition, substitution, or removal; and (iv) an 
explanation of how the action was accomplished (such as by           Section B. Type I Supporting Organizations
amendment to the organizing document substituting a new              Line 1. A Type I supporting organization must be operated, 
supported organization).                                             supervised, or controlled by one or more of its supported 
Line 6. A supporting organization must engage solely in              organizations (the “controlling supported organizations”). 
activities that support or benefit its supported organization(s).    This means that the controlling supported organizations must 
In addition to making grants and providing services and              have a substantial degree of direction over the policies, 
facilities directly to its supported organization(s), a supporting   programs, and activities of the supporting organization, and 
organization may also generally make grants or provide               the supporting organization in turn must be responsive to the 
services or facilities to (1) individual members of the              needs or demands of the controlling supported 
charitable class benefited by its supported organization(s), or      organizations, and must constitute an integral part of, or 
(2) other supporting organizations that also support or benefit      maintain a significant involvement in, the operations of the 
its supported organization(s). See Regulations section               controlling supported organizations. This relationship is most 
1.509(a)-4(e). If the organization made any grants or                clearly established when one or more supported 
provided any benefits to any other organization or individual,       organizations (through their officers, directors, trustees, or 
check “Yes” and provide detail in Part VI.                           membership) have the unconditional power to remove and 
                                                                     replace at least a majority of the supporting organization’s 
Lines 7 and 8. Under section 4958(c)(3), any grant, loan, 
                                                                     directors or trustees at any time. The relationship is also 
compensation, or other similar payment provided by a 
                                                                     commonly established when one or more supported 
supporting organization to a substantial contributor (defined 
                                                                     organizations have the power to appoint or elect at least a 
in section 4958(c)(3)(C)), to a family member (defined in 
                                                                     majority of the supporting organization’s directors or trustees 
section 4958(f)(4)), and to a 35% controlled entity of such 
                                                                     at regular intervals. However, there may be other ways to 
persons, is considered a per se excess benefit in its entirety, 
                                                                     establish this relationship. If the organization relies on other 
regardless of the fairness or reasonableness of the payment, 
                                                                     ways to establish the relationship, check “No” and describe in 
and is subject to tax under section 4958(a). The same is true 
                                                                     Part VI how the necessary relationship is established.
of any loan by a supporting organization to a disqualified 
person under section 4958 (other than loans to certain               Line 2. The supporting organization may benefit 
exempt organizations). If the organization made any such             organizations that don't participate in the control relationship 
payment or loan during the tax year, check “Yes” and report          described on line 1, but only if such activity carries out the 
the transaction on Schedule L (Form 990), Transactions With          purposes of the controlling supported organizations.
Interested Persons, Part I. For more information on excess 
benefit transactions generally, see the Instructions for             Section C. Type II Supporting Organizations
Schedule L (Form 990).                                               Line 1. A Type II supporting organization must be 
Line 9. A supporting organization may not be controlled by           supervised or controlled in connection with its supported 
disqualified persons, as defined in section 4946. Section            organization(s). This means that there must be common 
509(a)(1) or (2) organizations, and foundation managers who          supervision or control by the persons supervising or 
are disqualified persons only as a result of being foundation        controlling both the supporting organization and the 
managers, aren't treated as disqualified persons for this            supported organization(s) to ensure that the supporting 
purpose. Impermissible control may be direct or indirect. If a       organization will be responsive to the needs and 
disqualified person holds any of the interests described on          requirements of the supported organization(s). This 
line 9b or 9c, or derives personal benefit from any such             relationship is most clearly established when the same 
assets, provide detail in Part VI.                                   persons serve as all or a majority of the directors or trustees 
                                                                     of all of the organizations involved. However, there may be 
Line 10. Under section 4943(f), a Type II supporting                 other ways to establish this relationship. If the organization 
organization that accepts a contribution from a person who           relies on other than overlap of at least a majority of directors 
controls the governing body of a supported organization (or          or trustees of all organizations involved, check “No” and 
from a family member of such person, or from a 35%                   describe in Part VI how the necessary relationship is 
controlled entity of such person) is subject to the excess           established.
business holdings tax under section 4943. All Type III 
non-functionally integrated supporting organizations are also        Section D. All Type III Supporting Organizations
generally subject to the tax. For more information about 
excess business holdings, see the Instructions for Form              Line 1. A Type III supporting organization must supply 
4720, Return of Certain Excise Taxes Under Chapters 41 and           annually a written notice, addressed to a principal officer of 
42 of the Internal Revenue Code.                                     each supported organization, which includes the following.
Line 11. Section 509(f)(2) prohibits Type I and Type III             1. A description of the type and amount of all support the 
supporting organizations from accepting a gift or contribution       supporting organization provided to the supported 
from certain persons associated with a supported                     organization during the supporting organization’s tax year 
organization of such supporting organization. Specifically, if a     preceding the tax year in which the notice is provided.
Type I or Type III supporting organization accepts a                 2. A copy of the supporting organization’s most recently 
contribution after August 16, 2006, from a person who                filed Form 990 (the supporting organization may redact the 
controls the governing body of a supported organization (or          names and addresses of contributors).
from a family member of such person, or from a 35%                   3. A copy of the supporting organization’s updated 
controlled entity of such person), then the supporting               governing documents (including articles of organization, 

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bylaws, and any amendments), to the extent not previously                 Support of governmental entity. A Type III supporting 
provided.                                                            organization meets the integral part test for a functionally 
                                                                     integrated supporting organization if it (1) supports at least 
See Regulations section 1.509(a)-4(i)(2). The notice must be         one supported organization that is a governmental entity to 
submitted by the last day of the fifth month of the supporting       which the supporting organization is responsive (as 
organization's tax year being reported (May 31 for                   discussed in the instructions for Section D, Lines 2 and 3, 
calendar-year filers). An organization that doesn't timely           earlier), and (2) engages in activities for or on behalf of such 
submit the required information in the required manner               governmental supported organization that performs the 
doesn't qualify as a Type III supporting organization for the        functions or carries out the purposes of such governmental 
tax year in which it fails to timely submit.                         supported organization and that, but for the involvement of 
 State whether during the tax year being reported the                the supporting organization, would normally be engaged in 
organization provided a timely notice with the required              by the governmental supported organization itself. See 
information in the required manner.                                  Notice 2014-4. A Type III supporting organization that claims 
Lines 2 and 3.  A Type III supporting organization must be           to meet the integral part test for a functionally integrated 
responsive to the needs or demands of a supported                    supporting organization by supporting a governmental entity 
organization. An organization meets this responsiveness test         must describe in Part VI how it met these requirements for the 
with regard to a particular supported organization if:               tax year.
 1. The supported organization has an adequate                       Line 2. Activities Test. To meet the activities test of a Type 
relationship with the supporting organization because:               III functionally integrated supporting organization, 
 a. The supported organization regularly appoints or                 substantially all of the supporting organization’s activities 
 elects (whether or not during the tax year) at least one            must (1) directly further the exempt purposes of the 
 officer, director, or trustee of the supporting organization;       supported organization(s) to which the supporting 
 b. At least one member of the governing body of the                 organization was responsive, and (2) be activities that such 
 supported organization also serves as an officer, director,         supported organization(s) would normally be engaged in but 
 or trustee of the supporting organization; or                       for the supporting organization’s involvement.
 c. The officers, directors, or trustees of the supporting                Direct furtherance. Substantially all of the supporting 
 organization and of the supported organization maintain a           organization’s activities must be “direct furtherance” 
 close and continuous working relationship; and                      activities. Direct furtherance activities are conducted by the 
                                                                     supporting organization itself, rather than by a supported 
 2. Because of this relationship, the supported                      organization. Holding title to exempt-use assets and 
organization has a significant voice in the supporting               managing them are direct furtherance activities. Fundraising, 
organization’s investment policies, timing of grants, manner         investing and managing non-exempt-use assets, 
of making grants, selection of grant recipients, and other use       grant-making to organizations, and grant-making to 
of income or assets (the “significant voice” test).                  individuals (unless it meets the requirements of Regulations 
 In the case of a supporting organization that supported a           section 1.509(a)-4(i)(4)(ii)(D)) aren't direct furtherance 
supported organization before November 20, 1970,                     activities.
additional facts and circumstances such as a historic and                 But for. In addition, the direct furtherance activities must 
continuing relationship between the organizations may also           be activities in which, but for the supporting organization’s 
be taken into account in considering the responsiveness test.        involvement, the supported organization would normally be 
 If the organization has an adequate relationship with at            involved.
least one supported organization only by means of a “close                Examples include holding and managing facilities used by 
and continuous working relationship” or a “historic and              a church for its religious purposes, operating a food pantry for 
continuing relationship,” then in Part VI explain the                a group of churches that normally would operate food 
relationship and how it has been maintained. Also, all Type III      pantries themselves, and maintaining local parks for a 
supporting organizations that claim to meet the significant          community foundation that otherwise would maintain those 
voice test must describe in Part VI the voice or role of the         parks. See Regulations section 1.509(a)-4(i)(4)(v) for more 
supported organization(s) in directing the supporting                detailed examples.
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 
Section E. Type III Functionally Integrated 
                                                                     organization must (1) have the power to appoint or elect, 
Supporting Organizations                                             directly or indirectly, a majority of the officers, directors, or 
Line 1. A Type III supporting organization must constitute an        trustees of every supported organization; and (2) exercise a 
integral part of one or more of its supported organizations by       substantial degree of direction over the policies, programs, 
maintaining significant involvement in its operations and            and activities of every supported organization.
providing support on which the supported organization is 
dependent. To satisfy this requirement as a Type III                 Part V. Type III Non-Functionally 
functionally integrated supporting organization, an                  Integrated 509(a)(3) Supporting 
organization may (a) pass an Activities Test (see the 
instructions for Line 2, later), (b) be the parent of its            Organizations
supported organizations (see the instructions for Line 3,            A Type III supporting organization (other than a Type III 
later), or (c) support one or more governmental entities (see        functionally integrated supporting organization) must 
Support of governmental entity, later). If the organization          generally satisfy a distribution requirement described in 
can't satisfy any of these tests, it may still qualify as a Type III Regulations section 1.509(a)-4(i)(5)(ii) along with an 
non-functionally integrated supporting organization (see Part        attentiveness requirement described in Regulations section 
V, later).                                                           1.509(a)-4(i)(5)(iii) to meet the integral part test for a Type III 

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relationship. To satisfy the distribution requirement, the          Adjusted basis. The adjusted basis for purposes of 
organization must make a minimum amount (distributable              determining gain from the sale or other disposition of 
amount) of distributions to or for the use of one or more           property is the greater of:
supported organizations. Carryovers of excess distributions 
from certain prior years may be used for this purpose.                1. The fair market value of such property on August 17, 
                                                                    2006, plus or minus all adjustments thereafter and before the 
Sections A through E of Part V show whether the                     date of disposition under sections 1011–1023, if the property 
organization has satisfied its distribution and attentiveness       was held continuously from August 17, 2006, to the date of 
requirements for its tax year. Sections A and B determine the       disposition.
organization’s adjusted net income and minimum asset                  2. The adjusted basis under sections 1011–1023, without 
amount. These amounts are used in determining the                   regard to section 362(c). If assets acquired before August 17, 
distributable amount in Section C. Section D determines the         2006, were subject to depreciation or depletion, to determine 
organization’s distributions that count toward the distributable    the adjustments to basis between the date of acquisition and 
amount and determines whether the attentiveness                     August 17, 2006, straight-line depreciation or cost depletion 
requirement is met. Section E determines whether the                must be taken into account. Any other adjustments that 
distributable amount is satisfied through current distributions     would’ve been made during such period (such as a change in 
and prior-year carryovers, and determines carryovers to             useful life based upon additional data or a change in facts) 
future years.                                                       must also be taken into account.
A trust is excepted from the general distribution and               The adjusted basis for purposes of determining loss is only 
attentiveness requirements (and need not complete Sections          the amount described in item 2 above.
A through E) if on November 20, 1970, it met and continues 
to meet the requirements set forth in Regulations section           Line 2. Recoveries of prior-year distributions include the 
1.509(a)-4(i)(9). A trust that claims this status by checking       following.
the box on line 1 at the beginning of Part V must explain in        • Repayments received of amounts which were taken into 
Part VI how it meets each of the requirements. A trust that         account as a distribution counting toward the distribution 
has obtained a ruling from the IRS on this issue must so            requirement in a prior tax year.
indicate in Part VI.                                                • Proceeds from the sale or disposition of property to the 
                                                                    extent that acquisition of such property was taken into 
Section A. Adjusted Net Income                                      account as a distribution counting toward the distribution 
The principles of section 4942(f) and Regulations section           requirement in a prior tax year.
53.4942(a)-2(d) apply in determining adjusted net income.           • An amount set aside and taken into account as a 
See Regulations section 1.509(a)-4(i)(5)(ii)(B).                    distribution counting toward the distribution requirement in a 
                                                                    prior tax year to the extent it is determined that such amount 
Prior and current year columns. The organization’s                  isn't necessary for the purposes for which it was set aside.
adjusted net income for the prior tax year is used in 
determining the organization’s distributable amount for the         Line 3. Report all other gross income. Gross income 
current tax year. The form also allows for reporting the            includes all amounts derived from, or in connection with, 
organization’s adjusted net income for the current tax year for     property held by the organization (except as specified 
use in next year’s calculations; this reporting is optional but     otherwise in the instructions for Line 1). Include income from 
may be helpful if the organization anticipates being required       any related or unrelated trade or business. Include income 
to complete Part V next year.                                       from tax-exempt bonds. Don't include the following.
                                                                    • Gifts, grants, or contributions received.
Definition. Adjusted net income is gross income for the tax         • Long-term capital gains or losses or net short-term capital 
year less deductions allowable to a corporation subject to tax      losses.
under section 11, with certain modifications discussed in the       • Income received from an estate, unless the estate is 
line instructions later. In computing gross income and              considered terminated due to a prolonged period of 
deductions, the principles of the income tax provisions of the      administration.
Code apply (except to the extent inconsistent with section          • Distributions from a trust created and funded by another 
4942 or the underlying regulations), but exclusions,                person.
deductions, and credits aren't allowed unless expressly             • Certain amounts received by an organization in the 
provided for under section 4942 or the underlying                   redemption of stock in a corporate disqualified person in 
regulations. See Regulations section 53.4942(a)-2(d)(1).            order to avoid excess business holdings, which are treated as 
Line 1. Report the organization’s net short-term capital gain,      not essentially equivalent to a dividend under section 302(b)
if any. Long-term capital gains and losses from the sale or         (1) (and thus as amounts received in exchange for the stock, 
disposition of property aren't taken into account in                giving rise to long-term capital gain or loss) if the conditions 
determining adjusted net income (unless reportable on line 2        of Regulations section 53.4942(a)-2(d)(2)(iv) are met.
as recoveries of prior-year distributions). Net short-term          Line 5. The deduction for depreciation under section 167 is 
capital loss can't be carried back or forward to other tax          allowed, but only on the basis of the straight-line method. The 
years. Amounts treated as long-term capital gains include           deduction for depletion under section 611 is allowed, but 
capital gain dividends from a regulated investment company          without regard to section 613 (percentage depletion).
and net section 1231 gains (but net section 1231 losses are 
treated as ordinary losses and thus taken into account). If the     Lines 6 and 7. No deduction is allowed except ordinary and 
fair market value of property distributed for charitable            necessary expenses paid or incurred for the production or 
purposes exceeds adjusted basis, the excess isn't deemed            collection of gross income, or for the management, 
includible in income.                                               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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interest, rent, and taxes. Where only a portion of property         reasonable method to make this determination if consistently 
produces income (or is held for the production of income)           used. For example, a value for a particular month might be 
and the remainder is used for charitable purposes, the              determined by the closing price on the first or last trading day 
expenses must be apportioned between exempt and                     of the month or an average of the closing prices on the first 
non-exempt use on a reasonable basis.                               and last trading days of the month. Market quotations are 
  Don't deduct the following.                                       considered readily available if a security is any of the 
• Net losses from a related business or other charitable            following.
activity that produces gross income (no deduction in excess         •    Listed on the New York or American Stock Exchange or 
of the income from such activity).                                  any city or regional exchange in which quotations appear on 
• Charitable contributions under section 170 or 642.                a daily basis, including foreign securities listed on a 
• Net operating loss carrybacks and carryovers under                recognized foreign national or regional exchange;
section 172.                                                        •    Regularly traded in the national or regional 
• Dividends under section 241 and the sections following it         over-the-counter market for which published quotations are 
(the dividends-received deductions for corporations).               available; or
• Net capital losses (short-term or long-term).                     •    Locally traded, for which quotations can be readily 
Expenses and interest relating to tax-exempt income under           obtained from established brokerage firms.
section 265 are deductible.                                         If securities are held in trust for, or on behalf of, a supporting 
                                                                    organization by a bank or other financial institution that 
Section B. Minimum Asset Amount                                     values those securities periodically using a computer pricing 
The rules for determining the supporting organization’s             system, the organization may use that system to determine 
minimum asset amount are set forth in Regulations sections          the value of the securities. The system must be acceptable to 
1.509(a)-4(i)(5)(ii)(C) and 1.509(a)-4(i)(8), using valuation       the IRS for federal estate tax purposes.
methods described in Regulations section 53.4942(a)-2(c).           Line 1b.  Figure cash balances on a monthly basis by 
Prior and current year columns.    The organization’s               averaging the amount of cash on hand on the first and last 
minimum asset amount for the prior tax year is used in              days of each month. Include all cash balances and amounts, 
determining the organization’s distributable amount for the         even if they may be used for charitable purposes (see the 
current tax year. The form also allows for reporting the            instructions for Line 4, later) or set aside and taken as a 
organization’s minimum asset amount for the current tax year        distribution (see the instructions for Section D, Line 5, later).
for use in next year’s calculations; this reporting is optional     Line 1c.  The fair market value of assets other than securities 
but may be helpful if the organization anticipates being            for which market quotations are readily available is 
required to complete Part V next year.                              determined annually except as described later. The valuation 
Definition. In figuring the minimum asset amount, include           may be made by supporting organization employees or by 
only assets of the supporting organization that aren't used or      any other person even if that person is a disqualified person. 
held for use by the supporting organization (or by a                If the IRS accepts the valuation, it is valid only for the tax year 
supported organization, if the supporting organization              for which it is made. A new valuation is required for the next 
provides the asset free of charge or at nominal rent) to carry      tax year.
out the exempt purposes of the supported organization(s).           Valuation date.  An asset required to be valued annually 
Assets held for the production of income or for investment          may be valued as of any day in the supporting organization's 
aren't considered to be used directly for charitable functions      tax year, provided the organization values the asset as of that 
even though the income from the assets is used for charitable       date in all tax years. However, a valuation of real estate 
functions. It is a factual question whether an asset is held for    determined on a 5-year basis by a certified, independent 
the production of income or for investment rather than used         appraisal (discussed later) may be made as of any day in the 
or held for use directly by the supporting organization or a        first tax year of the organization to which the valuation 
supported organization for charitable purposes. For example,        applies.
an office building used to provide offices for employees 
                                                                    Proration of value of assets held for part of year or in a 
engaged in managing endowment funds for the supporting 
                                                                    short tax year.  The value of an asset held less than a full 
organization or supported organization isn't considered an 
                                                                    tax year is prorated by multiplying the value of the asset by a 
asset used for charitable purposes.
                                                                    fraction, of which the numerator is the number of days the 
Dual-use property.   When property is used for both                 organization held the asset during its tax year, and the 
charitable and other purposes, the property is considered           denominator is 365 (366 if the tax year includes February 
used entirely for charitable purposes if 95% or more of its         29). If the supporting organization has a short tax year, the 
total use is for that purpose. If less than 95% of its total use is value of all assets is accordingly prorated.
for charitable purposes, a reasonable allocation must be 
                                                                    5-year valuation for real estate. A written, certified, and 
made between charitable and noncharitable use.
                                                                    independent appraisal of the fair market value of any real 
Excluded property.   Certain assets (in addition to                 estate, including any improvements, may be determined on a 
exempt-use assets) are excluded entirely from the                   5-year basis by a qualified person. The qualified person may 
computation of the minimum asset amount. These include              not be a disqualified person with respect to the supporting 
charitable pledges and interests in an estate or trust (created     organization or an employee of the supporting organization.
and funded by another person) prior to distribution to the               Commonly accepted valuation methods must be used in 
supporting organization.                                            making the real estate appraisal. A valuation based on 
Line 1a. Report on line 1a the average monthly fair market          acceptable methods of valuing property for federal estate tax 
value of securities (such as common and preferred stock,            purposes will be considered acceptable.
bonds, and mutual fund shares) for which market quotations 
are readily available. A supporting organization may use any 

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  The real estate appraisal must include a closing statement          necessary to pay expenses and disbursements, then the 
that, in the appraiser's opinion, the appraised assets were           organization may enter the larger amount instead (prorated in 
valued according to valuation principles regularly employed           the case of a short tax year). If the organization uses a larger 
in making appraisals of such property, using all reasonable           amount, explain why in Part VI.
valuation methods. The supporting organization must keep a 
                                                                      Line 7. Enter the amount of recoveries (if any) reportable on 
copy of the independent appraisal for its records. If a 
                                                                      Section A, line 2.
valuation is reasonable, the organization may use it for the 
tax year for which the valuation is made and for each of the 4        Section C. Distributable Amount
following tax years.
                                                                      The organization’s distributable amount for the current tax 
  Any valuation of real estate by a certified independent             year is ordinarily the greater of:
appraisal may be replaced during the 5-year period by a 
subsequent 5-year certified independent appraisal or by an            1. 85% of its adjusted net income for the prior tax year or
annual valuation, as described earlier. The most recent               2. Its minimum asset amount for the prior tax year,
valuation should be used to figure the organization's                 less income taxes imposed on the organization during the 
minimum asset amount.                                                 prior tax year. See Regulations section 1.509(a)-4(i)(5)(ii)(B).
  If the valuation is made according to the above rules, the 
IRS will continue to accept it during the 5-year period for           First tax year. The distributable amount for the first tax year 
which it applies even if the actual fair market value of the real     that an organization is treated as a non-functionally 
estate changes during the period.                                     integrated Type III supporting organization is zero rather than 
                                                                      the amount as ordinarily determined. Such an organization 
Line 1e. If the fair market value of any securities, real estate      should check the box on line 7. For purposes of determining 
holdings, or other assets reported on lines 1a and 1c reflects        whether the organization has an excess of distributions in its 
a blockage discount, marketability discount, or other                 tax year that can be carried over to future years, the 
reduction from full fair market value because of the size of the      distributable amount as ordinarily determined applies to 
asset holding or any other factor, enter on line 1e the               every non-functionally integrated Type III supporting 
aggregate amount of the discounts claimed. Provide an                 organization (including an organization that checked the box 
explanation in Part VI that includes the following information        on line 7 for the current year). The distributable amount as 
for each asset or group of assets involved.                           ordinarily determined is reported in Sections C and E.
  1. A description of the asset or asset group (for example,          Emergency temporary reduction.       In cases of disaster or 
20,000 shares of XYZ, Inc., common stock);                            emergency, the IRS may provide for a temporary reduction in 
  2. For securities, the percentage of the total issued and           the distributable amount by publication in the Internal 
outstanding securities of the same class that is represented          Revenue Bulletin. In these cases, the reduced amount should 
by the organization's holding;                                        be reported on line 6 and the reduction noted in Part VI.
  3. The fair market value of the asset or asset group 
before any claimed blockage discount or other reduction;              Section D. Distributions
  4. The amount of the discount claimed; and                          Section D sets forth the supporting organization’s 
                                                                      distributions that count toward its distribution requirement, 
  5. An explanation of the reason for the discount.                   and determines whether the attentiveness requirement is 
  In the case of securities, there are certain limitations on         met. The amount of a distribution made to a supported 
the size of the reduction in value that can be claimed. The           organization is the amount of cash or fair market value of 
organization may reduce the fair market value of securities           property on the date of distribution. The organization must 
only to the extent that it can establish that the securities could    use the cash method of accounting for this purpose. See 
only be liquidated in a reasonable period of time at a price          Regulations section 1.509(a)-4(i)(6).
less than the fair market value because:                              Line 1. Report amounts paid to supported organizations to 
• The securities are such a large block that liquidation would        accomplish their exempt purposes. Distributions furthering 
depress the market,                                                   the “exempt” purposes of supported organizations not 
• The securities are in a closely held corporation, or                described in section 501(c)(3) refer solely to distributions for 
• The sale would result in a forced or distress sale.                 section 501(c)(3) purposes.
Any reduction in value of securities may not exceed 10% of 
the fair market value (determined without regard to any               Line 2. Report amounts paid to perform any activity that 
reduction in value).                                                  directly furthers exempt purposes of supported organizations 
                                                                      and that would otherwise normally be engaged in by the 
Line 2. Enter the total acquisition indebtedness that applies         supported organizations, but only to the extent that expenses 
to assets included on line 1 (prorated in the case of assets          from the activity exceed income from the activity. See the 
held for a portion of the year or in a short tax year). For details   Schedule A (Form 990), Part IV, Section E, Line 2, 
on acquisition indebtedness, see section 514(c)(1).                   instructions on “direct furtherance” activities.
Line 4. Supporting organizations may exclude from the                 Line 3. Report reasonable and necessary administrative 
minimum asset amount the reasonable cash balances                     expenses paid to accomplish exempt purposes of supported 
necessary to cover current administrative expenses and                organizations. Don't include expenses incurred in the 
other normal and current disbursements directly connected             production of investment income.
with the charitable, educational, or other similar activities. 
The amount of cash that may be excluded is generally 1.5%             Line 4. Report amounts paid to acquire exempt-use assets. 
of the fair market value of all assets (minus any acquisition         Such assets must be used (or held for use) to carry out the 
indebtedness). However, if under the facts and                        exempt purposes of the supported organizations. The assets 
circumstances an amount larger than the deemed amount is              may be used or held by either the supporting organization or 
                                                                      one or more supported organizations; if the latter, the 

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supporting organization must make the asset available to the         2. The amount of support received from the supporting 
supported organization(s) free of charge or for nominal rent.    organization is necessary to avoid the interruption of a 
See Regulations section 53.4942(a)-2(c)(3) for further           particular function or activity of the supported organization.
discussion of exempt-use assets.                                     3. The amount of support received from the supporting 
Line 5. Report qualified amounts set aside for a specific        organization is a sufficient part of the supported 
project that accomplishes the exempt purposes of a               organization’s total support to ensure attentiveness, based on 
supported organization to which the supporting organization      all pertinent facts, including the number of supported 
is responsive. A qualified set-aside counts toward the           organizations, the length and nature of the relationship 
distribution requirement in the tax year set aside but not       between the supporting organization and supported 
again when paid.                                                 organization, and the purpose to which the funds are put. The 
                                                                 attentiveness of a supported organization is normally 
Approval required. For each set-aside, a supporting              influenced by the amounts received from the supporting 
organization must obtain the written approval of both the        organization, but evidence of actual attentiveness to the 
pertinent supported organization(s) and the IRS. The             operations (including investments) of the supporting 
supporting organization must apply to the IRS for approval       organization is of almost equal importance. Where the 
(using Form 8940) before the end of its tax year in which the    supporting organization supports a particular department or 
amount is set aside. Explain in Part VI whether the              school of a university, hospital, or church, the department’s or 
organization has requested and obtained the necessary            school’s total support is considered instead of the supported 
approvals for the set-aside. See Regulations section             organization’s total support.
1.509(a)-4(i)(6)(v) for more information.
                                                                     Amounts received from a supporting organization that are 
Line 6.  Report any other distributions not described above      held in a donor-advised fund of the supported organization 
that the organization claims are for the use of its supported    are disregarded in determining attentiveness.
organizations, and describe such distributions in detail in Part 
VI.                                                                  See the examples in Regulations section 1.509(a)-4(i)(5)
                                                                 (iii)(D).
Lines 8–10.  Report on line 8 the amount of distributions            Responsiveness test. A supporting organization is 
reported on line 1 to supported organizations that met the       “responsive” to the needs and demands of a supported 
attentiveness and responsiveness tests, discussed later, and     organization if it meets the responsiveness test set forth in 
provide in Part VI the supplemental information, discussed       the instructions for Part IV, Section D, Lines 2 and 3, with 
later.                                                           respect to the supported organization.
  A Type III non-functionally integrated supporting                  Supplemental information required.   In Part VI, identify 
organization must distribute at least one-third of its           each of the supported organizations listed in Part I, line 12g, 
distributable amount each tax year to one or more supported      column (i), that met both of the following conditions for the tax 
organizations that are “attentive” to its operations and to      year.
which the supporting organization is “responsive” (as                1. The supporting organization was responsive to the 
described later); thus, the line 10 amount must be at least      supported organization, and
0.333. Carryovers of excess distributions from prior years 
don't count toward the attentiveness requirement.                    2. The supported organization was attentive to the 
                                                                 supporting organization. With respect to each of the identified 
  If the line 10 amount is less than one-third (that is, the     supported organizations, set forth the facts that show how 
amount of distributions to supported organizations that met      both the attentiveness test and the responsiveness test were 
both the attentiveness test and responsiveness test is less      met by the supporting organization and the supported 
than one-third of the distributable amount), then the            organization.
organization doesn't qualify as a Type III non-functionally 
integrated supporting organization for the tax year. See         Section E. Distribution Allocations
Regulations sections 1.509(a)-4(i)(5)(i) and (iii). If the 
organization doesn't otherwise qualify as a public charity,      Section E determines whether the distributable amount for 
then the organization is a private foundation and must file      the current tax year (and any underdistribution for reasonable 
Form 990-PF for the tax year.                                    cause in a prior year) is satisfied through current-year 
                                                                 distributions and carryovers of prior-year excess distributions. 
  Attentiveness test.  A supported organization is 
                                                                 Section E also determines carryovers of excess distributions 
“attentive” to the operations of a supporting organization if, 
                                                                 to future years. Several lines in Section E aren't yet applicable 
during the tax year, at least one of the following requirements 
                                                                 during the phase-in period of the new regulations for Type III 
is satisfied.
                                                                 non-functionally integrated supporting organizations. Those 
  1. The supporting organization distributes to the              lines are grayed out.
supported organization at least 10% of the supported 
organization’s total support in its tax year ending before the       In applying distributions, there are three basic steps.
beginning of the supporting organization’s tax year. For             1. First, apply distributions to eliminate any 
example, if the supporting organization and the supported        underdistribution for reasonable cause in a prior tax year.
organization both use a calendar year, and the supported             2. Second, apply distributions to satisfy the distributable 
organization has total support of $X in a year, then the         amount for the current year.
supporting organization’s support in the following year must 
be at least 10% of $X. Where the supporting organization             3. Third, carry over to future years any remaining excess 
supports a particular department or school of a university,      distributions.
hospital, or church, the department’s or school’s total support  Apply the oldest distributions first.    Carryovers of excess 
is considered instead.                                           distributions from prior years are always applied in full before 
                                                                 current-year distributions (unlike the rules for qualifying 

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distributions by private foundations), and older carryovers are     Line 2. An organization that is treated as a Type III 
applied before newer carryovers. Excess distributions of a          non-functionally integrated supporting organization for the 
given year can't be carried over for more than 5 years.             first time in its 2022 tax year will have a distributable amount 
Example 1. X is a Type III non-functionally integrated              of zero during the 2022 tax year.
supporting organization that for its tax year including             If the organization had any underdistributions for a prior 
December 28, 2020, and through its following 2021 tax year          tax year (2021 or 2022), then it didn't qualify as a Type III 
meets the requirements of Regulations section 1.509(a)-4(i)         non-functionally integrated supporting organization in that tax 
(3)(iii) as in effect prior to December 28, 2020. Under             year and subsequent years (and would be classified as a 
transition rules, X is deemed to meet its distribution              private foundation unless it met the requirements of another 
requirement for 2021, but its distributable amount is               public charity status) unless it met the requirements of the 
calculated in the ordinary manner to determine its excess           reasonable cause exception or the judicial proceeding 
distributions. For 2021, X had a distributable amount, as           exception discussed in the instructions for Lines 5 and 6, 
ordinarily determined, of $80,000 and distributions of              later. If the organization met either of these exceptions, 
$100,000. Accordingly, X had excess distributions of                explain in detail in Part VI how the organization met the 
$20,000. For 2022, X had a distributable amount of $95,000          requirements for the exception.
and distributions of $85,000. X first applied its 2021 excess 
distributions carryover of $20,000 to the 2022 distributable        Line 3. On lines 3d and 3e, enter the amounts reported on 
amount of $95,000. Then, X applied $75,000 of its 2022              lines 8d and 8e, respectively, from the organization's return 
distributions of $85,000 to the remaining 2022 distributable        for the 2022 tax year. The sum of the amounts on lines 3d 
amount. Accordingly, X has excess distributions of $10,000          and 3e is also reported on line 3f. The amount reported on 
from 2022 (2022 distributions of $85,000 minus $75,000              line 3f is then applied in the following priority.
applied to the 2022 distributable amount), which it may carry       1. First to any prior-year underdistributions on line 3g,
over to 2023. For 2023, X has a distributable amount of             2. Second (if any remaining amount) to the current-year 
$100,000 and distributions of $150,000. X applies the               distributable amount on line 3h, and
$10,000 excess distribution carryover from 2022 to the 2023 
                                                                    3. Third (if any remaining amount) on line 3j for carryover 
distributable amount. Then, X applies $90,000 of its 2023 
                                                                    to future years.
distributions to the remaining 2023 distributable amount. 
Section E will show $0 carryovers for 2021 and 2022                 Excess distributions can't be carried over for more than 5 tax 
(because the excess carryovers for each of those years were         years immediately following the tax year in which the excess 
previously applied). In addition, Section E will show excess        amount is created, and thus are forfeited if not used in the 
distributions of $60,000 in 2023 (2023 distributions of             fifth year of carryover. Such amounts are set forth on line 3i 
$150,000 minus $90,000 applied to the 2023 distributable            (not applicable to the 2023 tax return).
amount), which it may carry over in the next 5 tax years until 
                                                                    Line 4. Apply the current-year distributions (from Section D, 
applied.
                                                                    line 7) in the same order of priority as described in the 
Example 2. Y is a Type III supporting organization that for         instructions for Line 3 to any prior-year underdistributions 
its tax year including December 28, 2020, meets the                 (line 4a) and current-year distributable amount (line 4b) 
requirements of Regulations section 1.509(a)-4(i)(3)(iii) as in     remaining after applying carryovers on line 3. Any remaining 
effect prior to such date, but doesn't meet such requirements       distributions are reported on line 4c for carryover to future 
in its following 2021 tax year (because of underdistributions       years.
for which the prior regulation didn't expressly provide a 
reasonable cause exception). Therefore, Y didn't benefit from       Lines 5 and 6.   If the current-year distributable amount is 
the transition rule for its 2021 tax year. Y's distributable        greater than the sum of the excess distributions carryover 
amount was $120,000 for 2021. Y made distributions of that          from the prior year plus the current-year distributions, then 
amount and had no excess distributions to carry over to             the organization doesn't meet the distribution requirement 
2022. Y calculated that its distributable amount was                and can't qualify as a Type III non-functionally integrated 
$150,000 for 2022 and made distributions of exactly that            supporting organization for the tax year, unless an exception 
amount in 2022. Early in its 2023 tax year, Y discovers that its    applies. If the organization doesn't qualify as a supporting 
distributable amount for 2022 actually was $200,000. Within         organization or otherwise as a public charity for the tax year, 
180 days, Y makes a $110,000 distribution ($50,000 to cover         then it is a private foundation and must file Form 990-PF for 
the underdistribution for 2022 and $60,000 as part of its 2023      the tax year and subsequent years until private foundation 
distributions). Later in the 2023 tax year, Y makes additional      status is terminated under section 507. If either the 
distributions totaling $200,000. Y’s distributable amount in        reasonable cause or judicial proceeding exception applies, 
the 2023 tax year is $190,000. In its 2023 Form 990, Y claims       then explain in detail in Part VI how the organization met the 
reasonable cause for the 2022 underdistribution due to a            requirements for the exception.
clerical error. Under these circumstances, Y first applies          Reasonable cause exception.      An organization that fails 
$50,000 of its 2023 distributions of $310,000 to the 2022           to distribute its distributable amount won't be classified as a 
underdistribution of $50,000 ($200,000 minus $150,000),             private foundation for the year of the failure if the organization 
then applies $190,000 of its remaining 2023 distributions of        establishes to the satisfaction of the IRS that:
$260,000 ($310,000 minus $50,000) to satisfy its 2023               1. The failure was due to unforeseen events or 
distributable amount. Y’s remaining $70,000 of distributions        circumstances beyond its control, a clerical error, or an 
in 2023 ($310,000, minus $50,000 allocated to 2022, and             incorrect valuation of assets;
minus $190,000 allocable to 2023) are excess distributions          2. The failure was due to reasonable cause and not to 
that may be carried over to future years.                           willful neglect; and
Line 1. Report the distributable amount for 2023 from               3. The distribution requirement is met within 180 days 
Section C, line 6.                                                  after the organization is first able to distribute its distributable 

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amount notwithstanding the unforeseen events or                distributable amount (and not already carried over for 5 tax 
circumstances, or within 180 days after the clerical error or  years). The organization may carry over these amounts to 
incorrect valuation was or should have been discovered.        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             Part VI. Supplemental Information
requirement for the tax year in which paid.
                                                               Use Part VI to provide narrative information required by these 
Judicial proceeding exception. An organization is              instructions or to supplement responses to questions on 
excused from meeting the distribution requirements to the      Schedule A (Form 990). Identify the specific part and line 
extent of a conflicting mandatory provision in its governing   number that the response supports, in the order in which they 
instrument, if a judicial proceeding is pending to reform a    appear on Schedule A (Form 990). Part VI can be duplicated 
governing instrument that prohibits compliance, under the      if more space is needed.
circumstances set forth in Regulations section 1.509(a)-4(i)
(11)(ii)(E).                                                            Don't include in Part VI the names of any donors, 
                                                                        grantors, or contributors because Part VI will be 
Lines 7 and 8. Enter on line 7 the prior-year carryover and    CAUTION! made available for public inspection.
the current-year distributions to the extent not applied to 
prior-year underdistributions and the current-year 

                                                              -20-         Instructions for Schedule A (Form 990) 2023






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