Userid: CPM Schema: instrx Leadpct: 100% Pt. size: 9 Draft Ok to Print AH XSL/XML Fileid: … s/i990schr/2023/a/xml/cycle03/source (Init. & Date) _______ Page 1 of 7 10:54 - 29-Aug-2023 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Department of the Treasury Internal Revenue Service 2023 Instructions for Schedule R (Form 990) Related Organizations and Unrelated Partnerships Section references are to the Internal Revenue one or more of the following relationships Code unless otherwise noted. Overview Part I of Schedule R (Form 990) requires to the filing organization. identifying information on any • Parent—An organization that controls Future developments. For the latest organizations that are treated for federal (see definitions of control under Definition information about developments related to tax purposes as disregarded entities of of Control) the filing organization. Form 990 and its instructions, such as the filing organization. Part II requires • Subsidiary—An organization controlled legislation enacted after they were identifying information on related by the filing organization. published, go to IRS.gov/Form990. tax-exempt organizations. Part III requires • Brother/Sister—An organization identifying information on any related controlled by the same person or persons organizations that are treated for federal that control the filing organization. General Instructions tax purposes as partnerships. Part IV • Supporting/Supported—An Note. Terms in bold are defined in the requires identifying information on any organization that is (or claims to be) at any Glossary of the Instructions for Form 990, related organizations that are treated for time during the organization's tax year (i) a Return of Organization Exempt From federal tax purposes as C or S supporting organization of the filing Income Tax. corporations or trusts. Part V requires organization within the meaning of section information on transactions between the 509(a)(3), if the filing organization is a Purpose of Schedule organization and related organizations supported organization within the Schedule R (Form 990) is used by an (excluding disregarded entities). Part VI meaning of section 509(f)(3); or (ii) a organization that files Form 990 to provide requires information on an unrelated supported organization, if the filing information on related organizations, on organization treated as a partnership organization is a supporting organization. certain transactions with related through which the organization conducted • Sponsoring Organization of a VEBA— organizations, and on certain unrelated more than 5% of its activities (as An organization that establishes or partnerships through which the described in Part VI). maintains a section 501(c)(9) voluntary employees' beneficiary association organization conducts significant (VEBA) during the tax year. A sponsoring activities. Part VII of Schedule R (Form 990) may be used to provide additional information organization of a VEBA also includes an in response to questions in Schedule R. employee organization, association, Who Must File committee, joint board of trustees, or The chart below sets forth which other similar group of representatives of organizations must complete all or a part Relationships the parties which establish or maintain a of Schedule R and attach Schedule R to An organization, including a nonprofit VEBA. Form 990. If an organization isn't required organization, a stock corporation, a Contributing Employer of a VEBA—An to file Form 990 but chooses to do so, it partnership or limited liability company • employer that makes a contribution or must file a complete return and provide all (LLC), a trust, and a governmental unit contributions to the VEBA during the tax of the information requested, including the or other government entity, is a related year. required schedules. organization to the filing organization if it stands, at any time during the tax year, in Although a VEBA must report sponsoring organizations and contributing employers as related organizations, Type of filer IF you answer “Yes” to . . . THEN you must complete . . . sponsoring organizations and contributing employers shouldn't report a VEBA as a All organizations Form 990, Part IV, line 33 Schedule R, Part I. related organization, unless the VEBA is (regarding disregarded entities) related to the sponsoring organization or All organizations Form 990, Part IV, line 34 Schedule R, Parts II, III, IV, and V, contributing employer in some other (regarding related organizations) line 1, as applicable. capacity listed above. All organizations Form 990, Part IV, line 35b Schedule R, Part V, line 2. VEBA contributing employers and (regarding payments from or sponsoring organizations. If the filing transactions with controlled organization is a section 501(c)(9) VEBA, entities) it must list its sponsoring organizations and contributing employers on Schedule R Section 501(c)(3) organization Form 990, Part IV, line 36 Schedule R, Part V, line 2. (Form 990). The filing organization must (regarding transfers to exempt report all information on its sponsoring noncharitable related organizations in Parts II through IV, as organizations) applicable. However, the filing All organizations Form 990, Part IV, line 37 Schedule R, Part VI. organization is required to list only the (regarding conduct of activity name of its contributing employers in Parts through unrelated partnership) II through IV, and isn't required to report any additional information in those parts. Aug 29, 2023 Cat. No. 51519M |
Page 2 of 7 Fileid: … s/i990schr/2023/a/xml/cycle03/source 10:54 - 29-Aug-2023 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. The filing organization must also report its Control of a partnership or LLC. E and F. Organizations E and F are related transactions with sponsoring One or more persons control a partnership brother/sister related organizations with organizations and contributing employers if they own more than 50% of the profits respect to each other. in Part V, line 1, and, if applicable, line 2. interests or capital interests in the Indirect control. Control can be indirect. partnership (including an LLC treated as a Disregarded entity exception. For example, if the filing organization partnership or disregarded entity for Disregarded entities are treated as controls Entity A, which in turn controls federal tax purposes, regardless of the related organizations for purposes of (under the definition of control in these designation under state law of the reporting on Schedule R (Form 990), Part instructions) Entity B, the filing ownership interests as stock, membership I, but not for purposes of reporting organization will be treated as controlling interests, or otherwise). A person also transactions with related organizations in Entity B. To determine indirect control controls a partnership if the person is a Part V, or otherwise on Form 990. A through constructive ownership of a managing partner or managing member of disregarded entity of an organization corporation, rules under section 318 apply. a partnership or LLC which has three or related to the filing organization is Similar principles apply for purposes of fewer managing partners or managing generally treated as part of the related determining constructive ownership of members (regardless of which partner or organization and not as a separate entity. another entity (a partnership or trust). If an member has the most actual control), or if See Appendix F in the Instructions for entity (X) controls an entity treated as a the person is a general partner in a limited Form 990. partnership by being one of three or fewer partnership which has three or fewer partners or members, then an organization Bank trustee exception. If the filing general partners (regardless of which that controls X also controls the organization is a trust that has a bank or partner has the most actual control). For partnership. financial institution trustee that is also the this purpose, a “managing partner” is a trustee of another trust, the filing partner designated as such under the Example 1. B, an exempt organization isn't required to report the partnership agreement, or regularly organization, wholly owns (by voting other trust as a brother/sister related engaged in the management of the power) C, a taxable corporation. C holds a organization on the ground of common partnership. 51% profits interest in D, a partnership. control by the bank or financial institution Under the principles of section 318, B is trustee. Control of a trust with beneficial deemed to own 51% of D (100% of C's interests. One or more persons control a 51% interest in D). Thus, B controls both C trust if they own more than 50% of the and D, which are therefore both related Definition of Control beneficial interests in the trust. A person’s organizations with respect to B. Related organizations. For purposes of beneficial interest in a trust will be determining related organizations: determined in proportion to that person’s Example 2. X, an exempt actuarial interest in the trust as of the end organization, owns 80% (by value) of Y, a Control of a nonprofit organization of the tax year. taxable corporation. Y holds a 60% profits (or other organization without owners interest as a limited partner of Z, a limited or persons having beneficial interests, In some situations, a named partnership. Under the principles of whether the organization is taxable or beneficiary may have no determinable section 318, X is deemed to own 48% of Z tax exempt). One or more persons interest in the trust. For instance, if Trust A (80% of Y's 60% interest in Z). Thus, X (whether individuals or organizations) allows the trustee to distribute income and controls Y. X doesn't control Z through X's control a nonprofit organization if they principal in the trustee’s sole discretion for ownership in Y. Y is a related organization have the power to remove and replace (or 10 years to the then-living issue of X, with with respect to X, and (absent other facts) to appoint, elect, or approve or veto the the remainder (if any) to Charity B, then Z isn't. appointment or election of, if such power Charity B has no interest in the trust that includes a continuing power to appoint, can be determined before the 10-year Example 3. Same facts as in elect, or approve or veto the appointment period is ended, and therefore doesn't Example 2, except that Y is also one of or election of, periodically or in the event of control the trust for purposes of Form 990 three general partners of Z. Because Y vacancies) a majority of the nonprofit and Schedule R. controls Z through means other than ownership percentage, and X controls Y, in organization's directors or trustees, or a See Regulations sections 301.7701-2, these circumstances, Z is a related majority of the members who have the 3, and 4 for more information on organization with respect to X. The other power to elect a majority of the nonprofit classification of corporations, general partners of Z (if organizations) organization's directors or trustees. Such partnerships, disregarded entities, and aren't related organizations with respect to power can be exercised directly by a trusts. X, absent other facts. (parent) organization through one or more Examples of control by multiple Example 4. Organizations A, B, C, of the (parent) organization's officers, persons. and D are nonprofit organizations. directors, trustees, or agents, acting in their capacity as officers, directors, Example 1. Organizations A and B Organization A appoints the board of trustees, or agents of the (parent) each appoint one-third of the board Organization B, which appoints the board organization. Also, a (parent) organization members of Organizations C and D, and of Organization C. A majority of the board controls a (subsidiary) nonprofit aren't otherwise related to Organizations C members of Organization D are also board organization if a majority of the and D. Although neither Organization A members of Organization A. Under these subsidiary's directors or trustees are nor Organization B is a parent of circumstances, Organizations B and D are trustees, directors, officers, employees, Organization C or Organization D, directly controlled by Organization A, and or agents of the parent. Organizations C and D are controlled by Organization C is indirectly controlled by the same persons, and therefore are Organization A. Therefore, Organizations Control of a stock corporation. One brother/sister related organizations with B, C, and D are subsidiaries of or more persons (whether individuals or respect to each other. Organization A; Organization C is also a organizations) control a stock corporation subsidiary of Organization B; and if they own more than 50% of the stock (by Example 2. There are 1,000 Organizations B and C have a brother/ voting power or value) of the corporation. individuals who are members of both sister relationship with Organization D. Organizations E and F. The members elect the board members of both Organizations -2- 2023 Instructions for Schedule R (Form 990) |
Page 3 of 7 Fileid: … s/i990schr/2023/a/xml/cycle03/source 10:54 - 29-Aug-2023 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Example 5. T, an exempt organization organizations of each subordinate sections 301.6109-1(h) and 301.7701-2(c) described in section 501(c)(3), owns 40% organization other than (1) related (2)(iv). of the stock of U, a taxable C corporation. organizations that are included within the T and U each own 40% of the stock of V, group exemption, or (2) related Column (b). Primary activity. Briefly another taxable C corporation. Under organizations that the central organization describe the primary activity of the these facts, T and U aren't related knows to be included in another group disregarded entity. organizations as parent/subsidiary exemption. If an organization isn't listed Column (c). Legal domicile. List the because T doesn't own more than 50% of because it is known to be included in U.S. state (or U.S. territory) or foreign U's stock. Under section 318(a)(2)(C), another group exemption, the central country in which the disregarded entity none of U's holdings are attributed to T by organization must explain in Part VII the is organized (the state or foreign country virtue of T's ownership of U stock, relationship between its own group and whose law governs the disregarded because T owns less than 50% of U stock. members and the related organization entity's internal affairs). Thus, T and V aren't related organizations known to be included in another group as parent/subsidiary. exemption (but you needn't include the Column (d). Total income. Enter the Example 6. Same facts as in names of such related organizations). amount of the filing organization's total Example 5, except that U is an S • An organization that isn't included in a revenue reported in Form 990, Part VIII, corporation. Under section 318(a)(5)(E), T group exemption isn't required to list in line 12, column (A), attributable to the constructively owns 16% of V through U Part II a related organization that is disregarded entity. (40% of U's 40% ownership of V), giving T included in a group exemption. Similarly, Column (e). End-of-year assets. Enter a total ownership interest of 56% in V, and an organization that is included in a group the amount of the organization's total making T and V related organizations as exemption isn't required to list in Part II a assets reported in Form 990, Part X, parent/subsidiary. related organization that is included in line 16, column (B), attributable to the another group exemption. In either case, disregarded entity. Example 7. Same facts as in the organization must explain in Part VII Example 5, except that T owns 50% of U's the relationship between it and the related Column (f). Direct controlling entity. stock. T and U aren't related organizations organization included in another group Enter the name of the entity that directly as parent/subsidiary because T doesn't exemption (but you needn't include the controls the disregarded entity. For own more than 50% of U's stock. Under names of such related organizations). instance, if B is a disregarded entity of the section 318(a)(2)(C), U's holdings are filing organization, and if C is a attributed to T by virtue of T's 50% Even if a related organization isn't required disregarded entity of B, report B as the ownership of U's stock. Thus, T to be listed in Part II of Schedule R (Form direct controlling entity of C. If the filing constructively owns 20% of V through U 990), the organization must report its organization directly controls, enter its (50% of U's 40% ownership of V), giving T transactions with the related organization name. a total ownership interest of 60% in V, and in Part V, as required by the Part V making T and V related organizations as instructions (for example, checking “Yes” Part II. Identification of parent/subsidiary. to Part V, line 1b, if the organization made Example 8. F is a 501(c)(3) public a grant to a related organization included Related Tax-Exempt charity that appoints the governing body of in a group exemption, and reporting on Organizations G, another 501(c)(3) public charity. G is Part V, line 2, the organization's receipt of For purposes of Schedule R (Form 990), supported by H, a Type III supporting interest or annuities from a controlled treat governmental units and organization within the meaning of section entity included in a group exemption), instrumentalities and foreign 509(f)(1), but G doesn't control H. G and H including listing the name of the related governments as tax-exempt are thus related organizations because of organization in Part V, line 2, column (a), organizations. the supporting/supported relationship. for transactions that must be reported in Absent other facts, F and H aren't related line 2. Enter the details of each related organizations. organization on separate lines of Part II. Group exemption. Central Specific Instructions Column (a). Name, address, and EIN. organizations and subordinate Enter the related organization's full legal name, mailing address, and EIN. organizations of a group exemption Part I. Identification of aren't required to be listed as related Column (b). Primary activity. Briefly organizations in Schedule R (Form 990), Disregarded Entities describe the primary activity of the related Part II. All other related organizations of Enter the details of each disregarded organization. the central organization or of a entity on separate lines of Part I. Column (c). Legal domicile. List the subordinate organization are required to Column (a). Name, address, and EIN. U.S. state (or U.S. territory) or foreign be listed in Schedule R (Form 990). The Enter the full legal name and mailing country in which the related organization following rules apply. address of the disregarded entity. Also is organized. For a corporation, enter the • An organization that is a central or enter the employer identification state of incorporation (or the country of subordinate organization in a group number (EIN) of the disregarded entity, if incorporation for a foreign corporation exemption (whether filing an individual it has one. formed outside the United States). For a return or a group return) isn't required to list any of the subordinate organizations of A disregarded entity generally trust or other entity, enter the state whose the group in Part II. TIP must use the EIN of its sole law governs the organization's internal • In the case of a group return, the central member. An exception applies to affairs (or the foreign country whose law organization must attach a list of the employment taxes—for wages paid to governs for a foreign organization other subordinate organizations included in the employees of a disregarded entity, the than a corporation). group return in response to Form 990, disregarded entity must file separate Column (d). Exempt Code section. page 1, item H(b). The central employment tax returns and use its own Enter the section that describes the organization must list in Schedule R (Form EIN on such returns. See Regulations related organization (for example, section 990), Parts II through IV the related 501(c)(3) for a public charity, section 2023 Instructions for Schedule R (Form 990) -3- |
Page 4 of 7 Fileid: … s/i990schr/2023/a/xml/cycle03/source 10:54 - 29-Aug-2023 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. 501(c)(6) for a business league, or section member in the partnership, then complete Column (g). Share of end-of-year as- 527 for a separate segregated fund). For only columns (a), (b), and (c), and enter sets. Enter the dollar amount of the filing purposes of Schedule R, an organization “N/A” in columns (d), (e), (f), (g), (i), and organization's distributive share of the that claims exemption is treated as (k). related partnership's end-of-year total exempt. Also, for purposes of Schedule R, assets, in accordance with the treat as a section 501(c)(3) organization a Enter the details of each related related foreign organization recognized organization on separate lines of Part III. organization's capital interest, as specified by the partnership or LLC agreement, for as a charity by the foreign country, or for Some of the information requested in the related partnership's tax year ending which the filing organization has made a this part is derived from Schedule K-1 with or within the filing organization's tax reasonable judgment (or has an opinion of (Form 1065), Partner's Share of Income, year. Use Schedule K-1 (Form 1065) for U.S. counsel) that the foreign organization Deductions, Credits, etc., issued to the the partnership's year ending with or within is described in section 501(c)(3). The filing organization. If the Schedule K-1 (Form the organization's tax year to determine organization isn't required to make or 1065) isn't available, provide a reasonable this amount by adding the organization's obtain such a determination for purposes estimate of the required information. ending capital account to the of Schedule R. For governmental units, organization's share of the partnership's instrumentalities, and foreign Column (a). Name, address, and EIN. governments that don't have a section Enter the related partnership's full legal liabilities at year end reported on the 501(c) determination letter, leave blank. name, mailing address, and EIN. Schedule K-1. Column (e). Public charity status. For Column (b). Primary activity. Briefly Column (h). Disproportionate alloca- a related section 501(c)(3) organization, describe the primary business activity tions. Check “Yes” if the interest of the report its public charity status, using the conducted, or product or service provided, filing organization as a partner of the appropriate line number (lines 1 through by the related partnership (for example, partnership (or as a member of the LLC) in 12d) corresponding to the public charity investment in other entities, low-income any item of income, gain, loss, deduction, status checked on Schedule A (Form housing, etc.). or credit, or any right to distributions was disproportionate to the filing organization's 990), Public Charity Status and Public Column (c). Legal domicile. List the investment in such partnership or LLC at Support, Part I. If the related organization U.S. state (or U.S. territory) or foreign any time during the filing organization's is a private foundation, use the country in which the related partnership is tax year. Otherwise, check “No.” designation “PF.” If the related organization organized (the state or foreign country is a section 509(a)(3) supporting whose law governs the related Column (i). Code V—UBI amount in organization, also indicate its type: I, II, partnership's internal affairs). box 20 of Schedule K-1 (Form 1065). III-FI, or III-O (for Type I, Type II, Type III Enter the dollar amount, if any, listed as functionally integrated, or Type III other, Column (d). Direct controlling entity. the Code V amount (unrelated business respectively). Enter the name of the entity (if any) that taxable income) in box 20 of directly controls the related partnership; Schedule K-1 (Form 1065) received from For purposes of Schedule R, treat as a otherwise, enter “N/A.” If the filing the related partnership for the public charity a related foreign organization directly controls, enter its partnership's tax year ending with or organization that hasn't been recognized name. within the filing organization's tax year. If as a section 501(c)(3) public charity by the IRS but for which the filing organization Column (e). Predominant income. no Code V amount is listed in box 20, has made a good faith determination, Classify the predominant type of enter “N/A.” based on an affidavit from the foreign partnership income as: If the organization has reason to organization or the opinion of counsel, that • Related; TIP believe that the stated amount in the foreign organization is the equivalent • Unrelated; or box 20 is incorrect, it should of a public charity. The filing organization • Excluded from tax under section 512, consult with the partnership. The stated isn't required to make or obtain such a 513, or 514. amount in box 20 isn't controlling with determination for purposes of Schedule R; In other words, enter which of the three respect to the organization's unrelated if it hasn't, leave column (e) blank. types listed above is more prevalent than business income tax liability. the others. Column (f). Direct controlling entity. Column (j). General or managing part- Enter the name of the entity (if any) that For classification purposes, use the directly controls the related organization; definitions set forth in the instructions to ner. Check “Yes” if the filing organization otherwise, enter “N/A.” If the filing the Statement of Revenue in Form 990, was at any time during its tax year a organization directly controls, enter its Part VIII, columns (B), (C), and (D). general partner of a related limited partnership, or a managing partner or name. Column (f). Share of total income. managing member of a related general Column (g). Section 512(b)(13) con- Enter the dollar amount of the filing partnership, LLC, or other entity treated as trolled entity. Check “Yes” if the related organization's distributive share of the a partnership. Otherwise, check “No.” organization is a controlled entity of the related partnership's total income, in filing organization under section accordance with the organization's profits Column (k). Percentage ownership. 512(b)(13). If not, check “No.” interest as specified by the partnership or Enter the filing organization's percentage LLC agreement, for the related interest in the profits or in the capital of the partnership's tax year ending with or related partnership, whichever is greater. Part III. Identification of within the filing organization's tax year. Related Organizations Use the total amount reported by the Part IV. Identification of Taxable as a Partnership related partnership on Schedule K-1 Related Organizations In this part, identify any related (Form 1065) for the partnership's tax year organization treated as a partnership for ending with or within the filing Taxable as a Corporation federal tax purposes. If the partnership is organization's tax year (total of or Trust related to the filing organization by reason Schedule K-1, Part III, lines 1 through 11 In this part, identify any related of being its parent or brother/sister and the and 18, tax-exempt income). organization treated as a C or S filing organization isn't a partner or corporation or trust for federal tax -4- 2023 Instructions for Schedule R (Form 990) |
Page 5 of 7 Fileid: … s/i990schr/2023/a/xml/cycle03/source 10:54 - 29-Aug-2023 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. purposes (such as a charitable remainder U.S. Corporation Income Tax Return) by 512(b)(13). If not, check “No.” trust), other than a related organization the following fraction: the value of the filing Split-interest trusts. If the related reported as a tax-exempt organization in organization's shares of all classes of organization is a split-interest trust Part II of Schedule R (Form 990). If the stock in the C corporation, divided by the described in section 4947(a)(2), the corporation or trust is related to the filing value of all outstanding shares of all organization may enter in column (a) the organization as its parent or as a brother/ classes of stock in the C corporation. The term “Charitable remainder trust,” sister related organization, and the filing total income is for the related “Charitable lead trust,” or “Pooled income organization doesn't have an ownership organization's tax year ending with or fund,” as appropriate, instead of the trust's interest in the corporation or trust, then within the filing organization's tax year. name, EIN, or address. If the organization complete only columns (a), (b), (c), and For a related organization that is an S was related to more than one of a certain (e), and enter “N/A” in columns (d), (f), (g), corporation, enter the filing organization's type of related split-interest trust during and (h). Don't report trusts described allocable share of the S corporation's total the tax year, it should enter the number of within section 401(a). income. Use the amount on Schedule K-1 that type of trust in parentheses after the Some of the information requested in (Form 1120-S) for the S corporation's tax name. For instance, if the organization had this part is derived from Schedule K-1 year ending with or within the filing two related charitable remainder trusts (Form 1041), Beneficiary's Share of organization's tax year (Part III, lines 1 and three related charitable lead trusts, it Income, Deductions, Credits, etc., or through 10, of Schedule K-1 (Form should enter “Charitable remainder trusts Schedule K-1 (Form 1120-S), 1120-S)). (2)” on one line of column (a) and Shareholder's Share of Income, For a related organization that is a trust, “Charitable lead trusts (3)” on another line Deductions, Credits, etc., issued to the enter the total income and gains reported in column (a). The organization may leave organization. If the Schedule K-1 isn't on Part III, lines 1 through 8, of columns (e), (f), (g), and (h) blank for available, provide a reasonable estimate Schedule K-1 (Form 1041) issued to the these lines. Use Part VII if the organization of the required information. filing organization for the trust's tax year needs space to provide additional ending with or within the filing information for columns (b), (c), (d), or (i). Enter the details of each related organization's tax year. organization on separate lines of Part IV. A section 501(c)(3) organization Part V. Transactions With Column (a). Name, address, and EIN. TIP that is an S corporation Related Organizations Enter the related organization's full legal shareholder must treat all name, mailing address, and EIN. allocations of income from the S Line 1. Check “Yes” in the appropriate Column (b). Primary activity. Briefly corporation as unrelated business boxes of line 1 if the filing organization describe the primary business activity income, including gain on the disposition engaged in any of the transactions listed in conducted, or product or service provided, of stock. Part V with any related organizations (other than disregarded entities listed in by the related organization (for example, Part I). A single transaction may be holding company, management Column (g). Share of end-of-year as- company). sets. Enter the dollar amount of the filing described by and reported in more than organization's allocable share of the one line. A “transfer,” for purposes of Part Column (c). Legal domicile. List the related organization's total assets as of V, lines 1r and 1s, includes any U.S. state (or U.S. territory) or foreign the end of the related organization's tax conveyance of funds or property not country in which the related organization year ending with or within the filing described in lines 1a through 1q, whether is organized. For a corporation, enter the organization's tax year. For related C and or not for consideration, such as a merger state of incorporation (or the country of S corporations, this amount is determined with a related organization. incorporation for a foreign corporation by multiplying the corporation's Line 2. The filing organization must report formed outside the United States). For a end-of-year total assets by the fraction on this line any of the following trust or other entity, enter the state whose described in column (f). For related trusts, transactions that it engaged in with a law governs the organization's internal this amount corresponds to the filing controlled entity of the filing affairs (or the foreign country whose law organization's percentage ownership in organization, as defined in section governs for a foreign organization other the trust. 512(b)(13), during the tax year. than a corporation). All transactions described in line 1a, Column (h). Percentage ownership. • Column (d). Direct controlling entity. For a related organization taxable as a which includes all receipts or accruals of Enter the name of the entity (if any) that corporation, enter the filing organization's interest, annuities, royalties, or rent from a directly controls the related organization; percentage of stock ownership in the controlled entity under section 512(b)(13), otherwise, enter “N/A.” If the filing corporation (total combined voting power regardless of amount. organization directly controls, enter its or total value of all outstanding shares, • Any other type of transaction, described name. whichever is greater). For a related S in lines 1b through 1s, with controlled Column (e). Type of entity. Use one of corporation, use the percentage reported entities, if the amounts involved during the the following codes to indicate the tax on Schedule K-1 (Form 1120-S) for the tax year between the filing organization classification of the related organization: C year ending with or within the filing and a particular controlled entity exceed (corporation or association taxable under organization's tax year. For a related $50,000 for that type of transaction. subchapter C), S (corporation or organization taxable as a trust, enter the Section 501(c)(3) organizations must association taxable under subchapter S), filing organization's percentage of also report on line 2 transactions or T (trust, including a split-interest trust). beneficial interest. In each case, enter the described in Part V, lines 1b through 1s, percentage interest as of the end of the that they engaged in with related Column (f). Share of total income. For related organization's tax year ending with tax-exempt organizations not described in a related organization that is a C or within the filing organization's tax year. section 501(c)(3) (including section 527 corporation, enter the dollar amount of the political organizations), if the amounts organization's share of the C corporation's Column (i). Section 512(b)(13) control- involved during the tax year between the total income. To calculate this share, led entity. Check “Yes” if the related filing organization and a particular related multiply the total income of the C organization is a controlled entity of the tax-exempt organization exceed $50,000. corporation (as reported on its Form 1120, filing organization under section 2023 Instructions for Schedule R (Form 990) -5- |
Page 6 of 7 Fileid: … s/i990schr/2023/a/xml/cycle03/source 10:54 - 29-Aug-2023 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. Enter the details of each related Part VI. Unrelated ($60,000/$1,300,000), wouldn't be greater organization and each transaction type on than 5% of X's total activities, and a separate line of the table. Transactions Organizations Taxable as a therefore X wouldn't be required to identify of a specified type, described in lines 1b Partnership Y in Schedule R (Form 990), Part VI. through 1s, with a particular organization In this part, provide information on any Disregard the unrelated partnerships don't need to be reported if the total unrelated organization (an organization that meet both of the following conditions. amount of transactions of such type during that isn't a related organization with 1. 95% or more of the filing the tax year didn't exceed $50,000. respect to the filing organization) that organization's total revenue from the Column (a). Name of related organiza- meets all of the following conditions. partnership for the partnership's tax year tion. Enter the full legal name of the 1. The unrelated organization is ending with or within the organization's tax related organization. treated as a partnership for federal tax year is described in sections 512(b)(1)–(3) Column (b). Transaction type (a–s). purposes (S corporations are excluded). and (5), such as interest, dividends, Enter the transaction type (lines 1a 2. The filing organization was a royalties, rents, and capital gains through 1s). Aggregate all transactions of partner or member of the unrelated (including unrelated debt-financed the same type with the same related partnership at any time during the filing income). organization. organization's tax year. 2. The primary purpose of the filing Column (c). Amount involved. The 3. The filing organization conducted organization's investment in the amount involved in a transaction is the fair more than 5% of its activities, based on partnership is the production of income or market value of the services, cash, and the greater of its total assets at the end of appreciation of property and not the other assets provided by the filing its tax year or its total revenue for its tax conduct of a section 501(c)(3) charitable organization during its tax year, or the fair year, through the unrelated partnership. activity such as program-related investing. market value received by the filing In determining the percentage of the Enter the details of each organization organization, whichever is higher, filing organization's activities as measured on separate lines of Part VI. regardless of whether the transaction was by its total assets, use the amount Some of the information requested in entered into by the parties in a prior year. reported on Form 990, Part X, line 16, this part is derived from Schedule K-1 Any reasonable method for determining column (B), as the denominator, and the (Form 1065) issued to the organization. If such amount is acceptable. filing organization's ending capital account the Schedule K-1 isn't available, provide a Column (d). Method of determining balance for the partnership tax year reasonable estimate of the required amount involved. Describe the method ending with or within the filing information. used to determine the value of the organization's tax year as the numerator services, cash, and other assets reported (the amount reported on Schedule K-1 Column (a). Name, address, and EIN. in column (c). (Form 1065) can be used). In determining Enter the unrelated partnership's full legal the percentage of the filing organization's name, mailing address, and EIN. Split-interest trusts. If the organization activities as measured by its total revenue, Column (b). Primary activity. Briefly engaged in a type of transaction use the amount reported on Form 990, describe the primary business activity reportable in Part V, line 2, with one or Part VIII, line 12, as the denominator, and conducted, or product or service provided, more split-interest trusts described in the filing organization's distributive share by the unrelated partnership. section 4947(a)(2), the organization may of the partnership's gross revenue for the enter in column (a) the term “Charitable partnership tax year ending with or within Column (c). Legal domicile. List the remainder trust,” “Charitable lead trust,” or the filing organization's tax year as the U.S. state (or U.S. territory) or foreign “Pooled income fund,” as appropriate, numerator. country in which the unrelated partnership instead of the trust's name. For instance, if is organized (the state or foreign country the organization carried a $100,000 Example. X, a section 501(c)(3) whose law governs the unrelated liability for a loan it received from a related organization, is a partner of Y, an partnership's internal affairs). charitable lead trust, it should enter unrelated partnership, which conducts an “Charitable lead trust” in column (a), activity that constitutes an unrelated Column (d). Predominant income. transaction type “e” in column (b), and trade or business with respect to X. X's Classify the predominant type of income “$100,000” in column (c). Multiple distributive share of Y's total income is as: transactions of the same type with the $60,000 for Y's tax year ending with or • Related; same type of split-interest trust may be within X's tax year. X has an ending capital • Unrelated; or aggregated on the same line, with the account balance in Y of $120,000 as • Excluded from tax under section 512, number of each type of trust listed in reported on Schedule K-1 (Form 1065). 513, or 514. parentheses. For instance, if the X's total revenue and total assets for its tax In other words, enter one of the three organization received $60,000 from one year are $1,000,000 and $1,200,000, types of income listed above that is more related charitable remainder trust as respectively. Because X's total assets prevalent than the others. For payment for investment services and exceed X's total revenue for its tax year, X classification purposes, use the definitions $70,000 from another related charitable must consider total assets in determining set forth in the instructions to the remainder trust as payment for investment whether X conducted more than 5% of its Statement of Revenue in Form 990, Part services during the tax year, it may enter activities through Y for X's tax year. X VIII, columns (B), (C), and (D). “Charitable remainder trusts (2)” in column conducted 10% of its activities through Y, (a), transaction type “l” in column (b), and as measured by X's total assets Column (e). Section 501(c)(3) part- “$130,000” in column (c). ($120,000/$1,200,000), and thus must ners. Check “Yes” if all the partners of the identify Y in Schedule R (Form 990), Part unrelated partnership (or members of the VI, and provide the required information. If, LLC) are section 501(c)(3) organizations instead, X's total revenue for its tax year or governmental units (or wholly owned was $1,300,000, then total revenue would subsidiaries of either). Otherwise, check be considered rather than total assets; X's “No.” activities conducted through Y, as Column (f). Share of total income. measured by X’s total revenue Enter the dollar amount of the filing -6- 2023 Instructions for Schedule R (Form 990) |
Page 7 of 7 Fileid: … s/i990schr/2023/a/xml/cycle03/source 10:54 - 29-Aug-2023 The type and rule above prints on all proofs including departmental reproduction proofs. MUST be removed before printing. organization's distributive share of the Column (h). Disproportionate alloca- respect to the organization's unrelated related partnership's total income, in tions. Check “Yes” if the interest of the business income tax liability. accordance with the organization's profits filing organization as a partner of the interest as specified by the partnership or partnership (or as a member of the LLC) in Column (j). General or managing part- LLC agreement, for the related any item of income, gain, loss, deduction, ner. Check “Yes” if the filing organization partnership's tax year ending with or or credit, or any right to distributions was was at any time during its tax year a within the filing organization's tax year. disproportionate to the organization's general partner of an unrelated limited Use the total amount reported by the investment in such partnership or LLC at partnership, or a managing partner or related partnership on Schedule K-1 any time during the filing organization's managing member of an unrelated general (Form 1065) for the partnership's tax year tax year. Otherwise, check “No.” partnership, LLC, or other entity treated as ending with or within the filing a partnership. Otherwise, check “No.” organization's tax year (total of Column (i). Code V—UBI amount in Schedule K-1, Part III, lines 1 through 11 box 20 of Schedule K-1 (Form 1065). Column (k). Percentage ownership. and line 18, tax-exempt income). Enter the dollar amount, if any, listed as Enter the filing organization's percentage the Code V amount (unrelated business interest in the profits or in the capital of the Column (g). Share of end-of-year as- taxable income) in box 20 of related partnership, whichever is greater. sets. Enter the dollar amount of the filing Schedule K-1 (Form 1065) received from organization's distributive share of the the unrelated partnership for the Part VII. Supplemental unrelated partnership's total assets, in partnership's tax year ending with or Information accordance with the filing organization's within the filing organization's tax year. If Use Part VII if the organization needs capital interest as specified by the no Code V amount is listed in box 20, space to provide additional information in partnership or LLC agreement, as of the enter “N/A.” response to questions in Schedule R end of the unrelated partnership's tax year ending with or within the filing If the organization has reason to (Form 990). In Part VII, identify the specific organization's tax year. Use the ending TIP believe that the stated amount in part and line number that each response capital account reported on Schedule K-1 box 20 is incorrect, it should supports in the order in which those parts (Form 1065) for the year ending with or consult with the partnership. The stated and lines appear on Schedule R (Form within the filing organization's tax year. amount in box 20 isn't controlling with 990). 2023 Instructions for Schedule R (Form 990) -7- |