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         THE COMMONWEALTH OF            MASSACHUSETTS 

          OFFICE OF THE ATTORNEY  ENERALG       
                 ONE ASHBURTON          PLACE 
               BOSTON, MASSACHUSETTS     02108 

                                              (617) 963-2101 
                                              (617) 727-4765 TTY 
                                         www.mass.gov/ago/charities 
               Annual Charities Filings 
                 Form PC Instructions 

Contents 
I. THE BASICS .............................................................................................................................. 2 
 A. Who Must File a Form PC? ................................................................................................... 2 
 B. You Must Be Registered ........................................................................................................ 2 
 C. When is the Form PC Due? .................................................................................................... 2 
 D. What Must Be Filed? ............................................................................................................. 2 
 E. Where Do I File? .................................................................................................................... 4 
 F. Schedule VCO ........................................................................................................................ 4 
II. SPECIFIC INSTRUCTIONS - FORM PC ................................................................................ 5 
 A. Page 1 ..................................................................................................................................... 5 
 C. Question 5 .............................................................................................................................. 6 
 D. Question 6 .............................................................................................................................. 7 
 E. Question 13 ............................................................................................................................. 8 
 F. Question 14 ............................................................................................................................. 8 
 G. Questions 21 and 22 ............................................................................................................... 8 
 H. Question 23 ............................................................................................................................ 8 
 I. Question 24 .............................................................................................................................. 8 
III. DEFINITIONS .......................................................................................................................... 8 
 A. Related Organization.............................................................................................................. 8 
 B. Related Party .......................................................................................................................... 9 
 C. Termination of Employment or Change of Control Compensatory Arrangement............... 10 
 D. Indebtedness ......................................................................................................................... 10 
IV. TABLES ................................................................................................................................. 10

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                             Annual Charities Filings 
                                         Form PC Instructions 
 
I. THE BASICS 

 A. Who Must File a Form PC? 

Every public charity organized or operating in Massachusetts or soliciting funds in 
Massachusetts must file a Form PC with the Non-Profit Organizations/Public Charities Division 
(the “Division”), except organizations that hold property for religious purposes or certain 
federally chartered organizations.  The Form PC, including attachments, becomes a public record 
and is open to public inspection.  Failure to file may result in legal action by the Attorney 
General’s Office, including the assessment of civil penalties against the charity or its officers or 
other authorized agents. 

 B. You Must Be Registered  

You must be registered with the Division for the Division to process your Form PC.  If you need 
to register, please visit our website at https://www.mass.gov/info-details/registering-a-public-
charity. 

 C. When is the Form PC Due?  

Annual charities filings are due four and one-half months after the close of a charity’s fiscal year.  

Charitable organizations that are registered and in compliance with annual reporting 
requirements of the Division will be granted an automatic 6-month extension.  A written request 
is not required. 

 D. What Must Be Filed? 

All public charities must include the items that follow for their filing to be complete.  Your filing 
will be considered incomplete if any attachments are missing.   

Please type or print all responses clearly and complete each item that is applicable to your 
organization. If a question is not applicable to your organization, please write N/A. Do not leave 
any question blank. 

         (1) Form PC 

Attach all required schedules and explanations.  

Schedules A-1 and A-2 must be completed if your organization solicits funds from the public. To 
obtain a Certificate for Solicitation, there must be TWO different signatures on page 12 
and ONE signature on page 7. 

Schedule RO must be completed if there are organizations related to your organization (see 
definition section of these instructions) during the reporting year. 

Schedule VCO may be completed if you are a charitable organization established to benefit 
veterans or the military, intend to solicit donations in the Commonwealth and wish to receive a 

Form PC Instructions                     Page  2of  12                               Rev. 05/2021

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                               Annual Charities Filings 
                                     Form PC Instructions 
 
designation as a Veterans Charitable Organization (VCO).  More information about Schedule 
VCO can be found in Section I.F on page 5 below.   

           (2) Federal Form and/or Probate Account 

Unless the charity has a Gross Support and Revenue of $5,000 or less (as reported on Form PC, 
page 2, line 5B), one of the following forms must be submitted: 

     a) Federal Form 990 or 990-EZ (with all required IRS Schedules, except Schedule B) 
     b) Federal Form 990-PF 
     c) Probate Account 
     d) Federal Form 1120 or Federal Form 1041 
                       
A blank Federal Form 990 or 990-EZ may be obtained from the Internal Revenue Service by 
telephone order (800-829-3676) or at https://www.irs.gov/.  Federal Form 990-N is not accepted. 

           (3) Filing Fee 

You must submit the following filing fee based on your Gross Support and Revenue (as reported 
on Form PC, page 2, line 5B): 

                      Gross Support and Revenue          Filing Fee 
                      Less than $100,000                 $35 
                                                     
                      $100,001 to $250,000               $70 
                      $250,001 to $500,000               $125 
                      $500,001 to $1 million             $250 
                      $1,000,001 to $10 million          $500 
                      $10,000,001 to $100 million        $1,000 
                      $100 million+                      $2,000 

Payment should be made using the Commonwealth of Massachusetts secure, web-based payment 
system found at: https://www.mass.gov/service-details/electronic-payment-for-annual-filings-by-
charities. 

You will need the following information: 

                                                       1
 a) Your six-digit Attorney General Account Number;   

 b) The name of your organization (as it is registered with this office); and 

 c) The Gross Support and Revenue for your charity for the fiscal year for which you are 
     filing. The Gross Support and Revenue should be on your Form PC at page 2, line 5B and 
     MUST match that same value on your Federal filing, which can be found:   

1 If you do not know your 6-digit Attorney General Account Number, please visit the Annual Filing Document 
Search section of the AGO website and search for your organization by name: http://www.charities.ago.state.ma.us.  
The Attorney General Account Number will be listed in the search results and will start with a zero.   

Form PC Instructions                     Page  3of  12                                                 Rev. 05/2021

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                                  Annual Charities Filings 
                                    Form PC Instructions 
 
               Location of Gross Support and Revenue on Federal Filing 
           IRS Form                 Location of Gross Support and Revenue 
           Form 990                 Part VIII, Line 12 less– Line 7d Column A 
           Form 990-PF              Part I, Column (a), Line 12 less Line 6a 
           Form 990-EZ              Part I, Line 9 less Line 5c 

        (4) Financial Statements 

You must submit the following additional type of financial statement based on your Gross 
Support and Revenue (as reported on Form PC, page 2, line 5B): 

       Gross Support and            Type of Financial Statement 
       Revenue 
       $0 to $200,000               No additional financial statement is required 
       $200,001 to $500,000         CPA’s Review Report 
       $500,001 or more             Audited Financial Statements, prepared by an 
                                    independent CPA in accordance with 
                                    generally accepted accounting principles 
                                    (GAAP), and the accompanying independent 
                                    auditor’s report 

All financial statements must be final, not draft versions, and unbound.  The Division does not 
accept compilations. 

The following organizations are exempt from the audit requirement by regulation (940 CMR 
2.02): 

 a) Private foundations that file a 990-PF with the IRS; 
 b) Trusts filing probate accounts; and 
 c) Trusts audited by certain state and federal agencies. 

 E. Where Do I File? 

Form PC and all attachments should be filed by mail to: 

            Non-Profit Organizations/Public Charities Division 
            Office of the Attorney General 
            One Ashburton Place 
            Boston, MA 02108 

 F. Schedule VCO 

Charitable organizations established to benefit veterans or the military, who intend to solicit in 
the Commonwealth, may apply to receive designation as a Veterans Charitable Organization 
(VCO). VCO status can be obtained by completing the Schedule VCO and will be valid for 3 
years starting with the year of the Form PC being filed. 

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VCO status exempts eligible organizations from the filing fee requirement of the Form PC, and
the $100 initial registration fee if the organization is registering for the first time. Pursuant to
M.G.L. c. 68, s. 19A, any organization receiving VCO status may not utilize paid fundraisers
(commercial co-venturers, or professional solicitors); doing so will result in the loss of VCO
status.

II. SPECIFIC INSTRUCTIONS - FORM PC

A. Page 1

Please type or print all responses clearly and complete each item that is applicable to your
organization.

Please refer to the tables at the end of the instructions in order to code your county (Table 1),
type of organization (Table 2), and the organization’s main purposes (Table 3).

The “Final Report” box at the bottom of the left of page 1 is for PC filers that are permitted
under law to stop filing after this report. Examples of PC filers for whom a “Final PC” may be
appropriate without a judicial dissolution include: a trust with self-contained termination powers;
a charity that has merged into another, separately reporting charity; unincorporated associations;
or a non-charity or out-of-state charity that was, but is no longer, holding Massachusetts
charitable funds. A charity incorporated in Massachusetts must obtain a judicial dissolution, not
merely file a “final report.” The Division has prepared a guide to dissolutions that is available on
our website.

B. Question 4 and Schedule RO

If your organization has a Related Organization as defined in Section III on page 9, you must
answer “Yes” and complete Schedule RO. Once completed, Schedule RO should provide a
roadmap to the system of organizations which are related to your organization. If the name of
any Related Organization has changed within the last three years, indicate and list both the prior
name as well as the current name of the organization on an attached explanation sheet.

i. Schedule RO, Question 1

For each Related Organization you must identify its name, primary purpose or business activity,
the fiscal year end-date (“FYE”) for the Related Organization and restrictions on its assets as of
its most recent FYE, broken down as follows:

Category of Assets Additional Description
A Donor restricted funds (-) liabilities n/a
rd
B 3 party restricted funds (-) Those funds which cannot be used other than for
liabilities their intended purpose without incurring penalties
or other adverse impact (for example, insurance
reserves or funds restricted by covenants contained
in financing instruments) and which were
restricted by individuals or organizations unrelated
to the reporting charity.

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C Unrestricted funds (-) liabilities Unrestricted Funds includes funded depreciation.
D Total net assets (A+B+C) n/a

Additional information about restricted or unrestricted funds may be provided by attaching an
explanation.

ii. Schedule RO, Question 2

You must identify the amount of compensation paid to the chief executive (e.g., executive
director) of your organization and the four other current or former directors, trustees, officers, or
employees within your family of Related Organizations that receives the highest aggregate
compensation within the system of Related Organizations identified in Schedule RO, Section 1.
Include these persons even if their compensation is paid only by your organization and not by
related organizations. Itemize each compensation source, regardless of number of sources. List
only those individuals whose total annual compensation is $30,000 or higher.

iii. Additional notes for Schedule RO

Religious Related Organizations: If the filing organization is related to a religious organization,
the filer need not disclose the assets that the religious organization holds or the compensation
that the religious organization pays, so long as the filer (1) states the name and primary purpose
of the religious organization in Schedule RO, Question 1 and (2) answers “yes” to Schedule RO,
Question 3.

Non-Charitable Related Organizations: If the filing organization is a foundation created by a
non-charitable Related Organization and the non-charitable Related Organization (a) is not
required by law to register and file with the Division, (b) is not created, owned or controlled by
any charitable organization, and (c) is not established to benefit or further the purposes of any
charitable organization, the filer need not disclose the assets that the non-charitable Related
Organization holds or the compensation that the non-charitable Related Organization pays so
long as the filer (1) states the name and primary purpose or business activity of the non-
charitable Related Organization in Schedule RO, Question 1 and (2) answers “yes” to Schedule
RO, Question 3.

C. Question 5

The Summary of Financial Data on Page 2 must be completed in its entirety whether or not a
similar question has been answered on an attached federal IRS form. You must use your
completed IRS form to answer Question 5. Below we have broken down how to complete
Question 5 based on the type of tax return you have attached.

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                                  Annual Charities Filings 
                                  Form PC Instructions 
 
                      Question 5 by IRS Form Your Organization Files 
 Sub-Part  Description             Form 990                  Form 990-PF       Form 990-EZ 
 A      Contributions, gifts,      Part I, Line 8 –          Part I, Column    Part I, Line 1 
        grants, and similar        Current year              (A), Line 1 
        amounts received 
 B      Gross support and revenue  Part VIII, Line           Part I, Column    Part I, Line 9 
                                   12-Column A               (a), Line 12 less less 5c 
                                   less Line7D-              Line 6a 
                                   Column A 
 C      Program services and       Part IX, Line 25  Part I, Column            Part III, Line 
        similar amounts paid out   – Column B                (a), Line 25      32 
 D      Fundraising expenses       Part IX, Line 25  Enter amount              Enter amount 
                                   – Column D                from your own     from your own 
                                                             records           records 
 E      Management and general     Part IX, Line 25  Not required              Enter amount 
        expenses                   – Column C                                  from your own 
                                                                               records 
 F      Payments to affiliates     Part IX, Line 21  Not required              Enter amount 
                                   – Column A                                  from your own 
                                                                               records 
 G      Total expenses             Part IX, Line 25  Part I, Column            Part I, Line 17 
                                   – Column A                (a), Line 26 
 H      Net assets or fund         Part I, Line 22 –  Part III, Line 6         Part I, Line 21 
        balances at the end of the End of Year 
        year 

Charities with a gross support and revenue of $5,000 or less are not required to file a federal 
form with the Form PC.  If your organization’s revenue is under that threshold, the Division will 
ask that you nevertheless complete Question 5 using figures from your own records. 

   D. Question 6 

This question must be completed whether or not a question regarding compensation is answered 
on an IRS return. 

Under “Salary and Other Income,” report salary, fees, bonuses, severance payments and all other 
items included as personal income for federal income tax purposes. 

Under “Benefit Plans,” report (to the extent not reported in other columns) all forms of deferred 
compensation (whether or not funded or subject to conditions, and whether or not the deferred 
compensation plan is a qualified plan under federal tax laws) and all payments by your 
organization to employee benefit plans and retirement plans. 

Under “Other Compensation,” report (to the extent not reported in other columns) all other 
taxable and non-taxable benefits. 

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E. Question 13

If your response to Question 13 is yes, complete Schedule A-1 unless your organization is
exempt from the solicitation certificate requirement and mark the appropriate box under
Question 15.

F. Question 14

If your response to Question 14 is yes, complete Schedule A-2 unless your organization is
exempt from the solicitation certificate requirement and mark the appropriate box under
Question 15.

G. Questions 21 and 22

As a general rule, donor restrictions may only be removed by court order and donated funds may
not be loaned in violation of donor restrictions on the use of principal. If the answer to either
Question 21 or Question 22 is “Yes,” attach an explanation of procedures followed.

H. Question 23

See definition section for definitions of “Related Party” and “Termination of Employment or
Change of Control Compensatory Arrangement.” Report only if payments made or promised to
any individual are in excess of four months’ salary at time of termination, or $100,000.00,
whichever dollar amount is less.

In (a), report actual payments made or value transferred during the reporting year, either at the
time of severance or under a payment schedule, for individuals described at Sections (a) and (b)
of the Related Party definition.

In (b), identify and describe the terms of any existing agreements containing termination of
employment or change of control compensatory arrangements, whether or not activated in the
reporting year, for individuals described at Sections (a) and (b) of the Related Party definition.

The existence of a confidentiality agreement does not excuse a reporting organization’s
obligation to complete section (a) or (b) of this question. The affected individual’s name may be
omitted, but his or her title or position must be disclosed.

I. Question 24

Follow the instructions on the form. See definitions of “Related Party” and “Indebtedness.”

III. DEFINITIONS

A. Related Organization

A Related Organization is:

(a) Any entity (whether nonprofit or for-profit) which your organization directly or
indirectly owns, or which directly or indirectly owns your organization. For this

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                                Annual Charities Filings 
                                Form PC Instructions 
 
        purpose, “owns” means directly or indirectly holding more than 50% of voting 
        membership rights or voting stock; 

 (b)    Any entity (whether nonprofit or for-profit) under common control with your 
        organization.  For this purpose, “control” means over 50% of an entity’s directors, 
        trustees, or other members of its governing body are representatives of, or are directly 
        or indirectly controlled by a second entity; 

 (c)    Any entity (whether nonprofit or for-profit) (i) a purpose of which is to benefit or 
        further the purposes of the reporting organization, or which the reporting organization 
        was established to  benefit or further in its purposes and (ii) which engaged in 
        business transactions or business  arrangements  (including pledges or assignments of 
        collateral and loan guarantees or other contracts of suretyship) with the reporting 
        organization, or paid compensation to, an officer, director, trustee or employee of the 
        reporting organization. 

 B. Related Party 

A Related Party is: 

 (a)    An officer, director, or trustee (or an individual having powers or responsibilities 
        similar to those of officers, directors, or trustees) of your organization. 

 (b)    An employee of your organization who has management responsibilities for 
        achieving the objectives of the reporting organization and who is authorized to 
        establish institution-wide policies or make institution-wide decisions by which those 
        objectives are to be achieved. This includes, for example, the chief executive officer, 
        chief operating officer, vice presidents in charge of principal functions with 
        institution-wide responsibilities, and other persons who perform similar policy or 
        decision-making functions. Persons without formal titles may also be management 
        employees. (Note: In contract with the IRS definition of “key employees,” this 
        section does include individuals who may be heads of sub-units within your 
        organization, if they have institutional policy or decision-making responsibility.) 

 (c)    A spouse (other than a spouse who is legally divorced from the individual or who is 
        residing apart under a decree of separate maintenance), a child (including legally 
        adopted children), grandchild, sibling, parent, and grandparent of individuals 
        described in (a) and (b) above. 

 (d)    Any entity (whether nonprofit or for-profit) (l) which is directly or indirectly owned 
        or controlled by an individual, or individuals, described at (a), (b) or (c) above; or, (2) 
        of which an individual   identified at (a) or (b) above is an officer, director, trustee, 
        partner, or employee, or of which an individual identified at (c) above is an officer, 
        director, trustee, or partner.  For this purpose, “owned” means an individual, or 
        individuals, described at (a), (b) or (c) above, alone or collectively, directly or 
        indirectly hold more than 35% of voting membership rights or voting stock in an 
        entity other than the reporting organization. “Controlled” means an individual or 
        individuals, described at (a), (b) or (c) above, alone, or collectively, comprise over 

Form PC Instructions                    Page  9of  12                               Rev. 05/2021

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                       Annual Charities Filings 
                       Form PC Instructions 
 
 35% of the directors, trustees, or other members of the governing body of an entity 
 other than the reporting organization.  If in substance the transaction is between your 
 organization and an entity described in the first sentence above, then the entity will be 
 a Related Party regardless of how billing may be structured, or contracts written. 

 C. Termination of Employment or Change of Control Compensatory Arrangement 

A Termination of Employment or Change of Control Compensatory Arrangement is a 
compensatory plan or arrangement pursuant to which payment(s) or other value will result from 
the resignation, retirement or any other termination of the individual’s employment, or from a 
change in control of the organization or a change in the individual’s responsibilities following a 
change in control.  This includes arrangements accompanied by non-competition agreements, 
consulting contracts, or other personal service agreements entered into by the individual. 

 D. Indebtedness  

Indebtedness means any loan or other obligation, contingent or otherwise, which should, in 
accordance with generally accepted accounting principles, be classified on the obligor’s balance 
sheet as a liability and (i) all liability for money borrowed or the deferred purchase price of 
property or services, (ii) obligations as lessee under leases which should or have been capitalized 
on the books of the lessee, (iii) obligations under letters of  credit issued for the account of any 
person, (iv) all guarantees and contingent obligations to purchase, to provide funds for payment, 
to supply funds to invest in any person, or to assure a creditor against loss, (v) obligations 
secured by any lien on property owned by you, whether or not the obligations have been 
assumed or guaranteed. 

IV. TABLES 
 
The following tables are to be used to enter the codes requested on the Form. 

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                                       Annual Charities Filings 
                                       Form PC Instructions 
 
Table 1 

 COUNTY                  CODE        COUNTY             CODE 
 Barnstable              1           Middlesex                  9 
 Berkshire               2           Nantucket              10 
 Bristol                 3           Norfolk                11 
 Dukes                   4           Plymouth               12 
 Essex                   5           Suffolk                13 
 Franklin                6           Worcester              14 
 Hampden                 7           Out-of-state           15 
 Hampshire               8           Foreign                16 
 
Table 2 

        TYPE OF ORGANIZATION                 CODE       TYPE OF ORGANIZATION              CODE 
 Arts/Culture/Humanities                       1  Recreation/ Sports/ Leisure/ Athletics  14 
 Educational Institutions and  Related         2  Youth Development                       15 
 Activities 
 Environmental Quality/ Protection/            3  Human Services - Multipurpose and       16 
 Beautification                                   Other 
 Animal Related                                4  International/ Foreign Affairs/         17 
                                                  National Security 
 Health - General and Rehabilitative           5  Civil Rights/ Social Action/ Advocacy   18 
 Mental Health and Crisis Intervention         6  Community Development/ Capacity         19 
                                                  Building 
 Diseases/ Disorders/ Medical Disciplines      7  Philanthropy/ Voluntarism/ Grantmaking  20 
                                                  Foundations 
 Medical Research                              8  Science and Technology Research         21 
                                                  Institutes/ Services 
 Crime and Legal Related                       9  Social Science Research Institutes/     22 
                                                  Services 
 Employment and Job Related                    10 Public/ Society Benefit - Multipurpose  23 
                                                  and Other 
 Food/ Agriculture/ Nutrition                  11 Religion Related/ Spiritual Development 24 
 Housing and Shelter                           12 Mutual/ Membership Benefit              25 
                                                  Organization/ Other 
 Public Safety and Disaster Preparedness/      13 Other                                   26 
 Relief 
 
Form PC Instructions                      Page 11 of 12                               Rev. 05/2021

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                                       Annual Charities Filings 
                                       Form PC Instructions 
 
Table 3 

 PURPOSE                               CODE PURPOSE                                 CODE 
 Higher education                      1      Police                                32 
 Secondary education                   2      Fire                                  33 
 Elementary education                  3      Emergency aid / disaster relief       34 
 Pre-elementary education              4      Other public safety                   35 
 Day care center (child or adult)      5      Ex-offenders                          36 
 Scholarships                          6      Victim advocacy                       37 
 Parent teacher groups                 7      Fraternal                             38 
 Other educational                     8      Professional/occupational             39 
 Hospital                              9      Veterans                              40 
 Rehabilitation                        10     Children                              41 
 Nursing home, long-term care          11     Adoption                              42 
 Direct health services (non-hospital) 12     Youth sports                          43 
 Mental health                         13     Elderly                               44 
 Family planning                       14     Family services                       45 
 Drug abuse                            15     Legal services                        46 
 Alcohol                               16     Poor                                  47 
 AIDS                                  17     Persons with disabilities             48 
 Alzheimer’s                           18     Minorities                            49 
 Heart disease                         19     Women’s issues                        50 
 Cancer                                20     Gay, lesbian, transgendered, bisexual 51 
 Other health                          21     Homeless shelter                      52 
 Museum                                22     Animals                               53 
 Library                               23     Consumer                              54 
 Performing arts                       24     Civic                                 55 
 Other cultural                        25     Issue advocacy                        56 
 Historical society                    26     Religious                             57 
 Other historical                      27     Friends of                            58 
 Environment                           28     Research                              59 
 Land conservation                     29     Provide grants                        60 
 Community/neighborhood development    30     Other:                                61 
 Housing facility                      31     Other:                                62 
 
Form PC Instructions                   Page 12 of 12                                Rev. 05/2021

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