In Announcement 2011-36, the IRS invites the public to submit comments on
certain issues regarding the redesigned Form 990 for tax-exempt organizations.
The IRS substantially revised the Form 990 in 2008 and continues to make
refinements based on questions and comments from the public.
The IRS seeks comments on the following issues:
- Adoption (or rejection) of a coding system for exempt activities.
- How to report payments to management companies and other third parties
that are owned or controlled by an organization manager.
- Thresholds for reporting compensation to organization managers.
- How to report contributions and program service revenue received from
- How to reduce redundancy of reporting net asset reconciliation.
- Whether to require additional reporting on audited financial statements.
- Whether to require reporting of names and EINs of foreign grantees.
- Whether to require reporting of indirect foreign expenditures.
- Whether to require reporting on deposits into and withdrawals from a
bank account as business transactions on Schedule L.
- Whether separately organized trusts or nonprofit corporations that are
part of a community trust should be required to file separate Form 990
returns, or alternatively, how to increase transparency in reporting by
community trusts and their component parts.
- The advantages and disadvantages of allowing exceptions to reporting of
controlling or controlled organizations on Schedule R.
Comments must be submitted to the IRS in writing by Aug. 1, 2011, under a
cover page that states “Announcement 2011-36” to the following address: Internal
Revenue Service, Attn: Stephen Clarke (Announcement 2011-36), SE:T:EO (3C1),
1111 Constitution Avenue, N.W., Washington, D.C. 20224.
Comments may also be submitted to the email address
“Announcement 2011-36” in the subject line. All comments submitted will be made
available for public inspection and copying.
McGuireWoods LLP Nonprofit & Tax-Exempt Organizations Group
and tax-exempt organizations lawyers provide advice and guidance that enable
charities and other nonprofits to operate more efficiently and effectively in
today’s increasingly complicated, regulated and competitive environment.