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Form 990-T Instruktioner

Instruktioner for Form 990-T, Exempt Organization Business Income Tax Return (og Proxy Tax Under Section 6033(e))

Rev. 2023

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  • Form 990-T - Forsøgsorganisation Business Income Tax Return (og proxy skat under punkt 6033(e))
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Department of the Treasury  
Internal Revenue Service  
2023  
Instructions for Form 990-T  
Exempt Organization Business Income Tax Return (and Proxy Tax Under Section  
6033(e))  
Section references are to the Internal Revenue Code unless  
What's New  
otherwise noted.  
Required electronic filing. If you are an organization or trust  
Contents  
Page  
defined in section 511 and need to file Form 990-T, you are  
required to file electronically. See When, Where, and How To  
File, later, for more information.  
Purpose of Form . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1  
Who Must File . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1  
When, Where, and How To File . . . . . . . . . . . . . . . . . 3  
Depository Method of Tax Payment . . . . . . . . . . . . . . 4  
Other Forms That May Be Required . . . . . . . . . . . . . . 5  
Accounting Methods . . . . . . . . . . . . . . . . . . . . . . . . . 6  
Specific Instructions . . . . . . . . . . . . . . . . . . . . . . . . . 8  
Items A Through L . . . . . . . . . . . . . . . . . . . . . . . . . . 8  
Part I. Total Unrelated Business Taxable Income . . . . . 9  
Part II. Tax Computation . . . . . . . . . . . . . . . . . . . . . 10  
Part III. Tax and Payments . . . . . . . . . . . . . . . . . . . . 11  
Tax-exempt and governmental entities. For tax years  
beginning after 2022, applicable entities (such as certain  
tax-exempt and governmental entities) can elect to treat certain  
general business credits as a payment of income tax. See  
Applicable Entity Making an Elective Payment Election on IRA  
2022 Credits, later.  
Section 6417(d)(1)(A) applicable entity. Form 990-T, Item G  
has been updated with a checkbox for applicable entities that  
are not normally required to file an annual tax return and are  
filing Form 990-T to make an elective payment election under  
section 6417.  
Part IV. Statements Regarding Certain Activities  
Advanced manufacturing investment credit. Eligible filers  
may elect to treat the advanced manufacturing investment credit  
with respect to a facility as a payment of income tax under  
section 48D(d). See section 48D and the Instructions for Form  
3468.  
and Other Information . . . . . . . . . . . . . . . . . . . . 13  
Part V. Supplemental Information . . . . . . . . . . . . . . . 13  
General Instructions — Schedule A (Form 990-T) . . . 14  
Purpose of the Schedule . . . . . . . . . . . . . . . . . . . . . 14  
Specific Instructions—Schedule A (Form 990-T) . . . 16  
Part I. Unrelated Trade or Business Income . . . . . . . 16  
Part II. Deductions Not Taken Elsewhere . . . . . . . . . . 19  
Part III. Cost of Goods Sold . . . . . . . . . . . . . . . . . . . 23  
Part IV. Rent Income . . . . . . . . . . . . . . . . . . . . . . . . 23  
Part V. Unrelated Debt-Financed Income . . . . . . . . . 24  
Alternative minimum tax. The Inflation Reduction Act of 2022  
(IRA 2022) amended section 55 to impose a new corporate  
alternative minimum tax (CAMT) based on the adjusted financial  
statement income (AFSI) of an applicable corporation. See Form  
4626, Alternative Minimum Tax-Corporations, and its  
Instructions, for more information.  
Part VI. Interest, Annuities, Royalties, and Rents  
General Instructions  
From Controlled Organizations . . . . . . . . . . . . . 25  
Part VII. Investment Income of a Section 501(c)(7),  
Purpose of Form  
(9), or (17) Organization . . . . . . . . . . . . . . . . . . 26  
Use Form 990-T and Schedule A (as applicable) to:  
Part VIII. Exploited Exempt Activity Income, Other  
Report unrelated business income;  
Figure and report unrelated business income tax liability;  
Report proxy tax liability;  
Than Advertising Income . . . . . . . . . . . . . . . . . 27  
Part IX. Advertising Income . . . . . . . . . . . . . . . . . . . 27  
Claim a refund of income tax paid by a regulated investment  
Part X. Compensation of Officers, Directors, and  
company (RIC) or a real estate investment trust (REIT), on  
undistributed long-term capital gain;  
Trustees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 27  
Part XI. Supplemental Information . . . . . . . . . . . . . . 27  
Business Activity Codes . . . . . . . . . . . . . . . . . . . . . 29  
Appendix A. Definitions . . . . . . . . . . . . . . . . . . . . . . 30  
Appendix B. Charitable Contribution Deduction . . . . . 31  
Request a credit for certain federal excise taxes paid for small  
employer health insurance premiums paid, and  
Make (along with filing Form 3800 and the applicable general  
business credit form(s)) an elective payment election under  
section 48D or section 6417.  
Appendix C. Public Inspection of Form 990-T  
Who Must File  
Organizations With Current Unrelated Business  
Taxable Income (UBTI)  
Returns Filed by Section 501(c)(3)  
Organizations . . . . . . . . . . . . . . . . . . . . . . . . . . 32  
Index . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 35  
Future Developments  
Any disregarded entity, domestic, or foreign organization  
exempt under section 501(a), section 529(a), or section 529A(a),  
if it has gross income of $1,000 or more from a regularly  
For the latest information about developments related to Form  
990-T and its instructions, such as legislation enacted after they  
were published, go to IRS.gov/Form990T.  
conducted unrelated trade or business (see Regulations section  
1.6012-2(e)). Gross income is gross receipts minus the cost of  
goods sold, (see Regulations section 1.61-3). For a discussion  
Jan 24, 2024  
Cat. No. 11292U  
   
of cost of goods sold, see Schedule A (Form 990-T), Part III.  
Cost of Goods Sold, later.  
Alaska Native Corporations,  
The Tennessee Valley Authority,  
Rural electric cooperatives, and  
Other tax-exempt entities.  
The gross receipts from a gaming business include all  
amounts wagered in games, not just the net proceeds  
!
CAUTION  
after payment of prizes and other expenses. Cash prizes  
Proposed regulations have been published that provide a  
aren't included in cost of goods sold, but are reported on  
Schedule A, Part II, line 14, as other deductions.  
more detailed definition of an applicable entity. Entities may rely  
on the definitions in the proposed regulations for tax years  
ending before final regulations are published, provided the entity  
follows the proposed regulations in their entirety and in a  
consistent manner with respect to all elections made under  
A disregarded entity, as described in Regulations  
sections 301.7701-1 through 301.7701-3, is treated as a  
!
CAUTION  
branch or division of its parent organization for federal  
tax purposes. Therefore, financial information applicable to a  
disregarded entity must be reported as the parent organization's  
financial information.  
The detailed description in the proposed regulations includes  
the following.  
An organization exempt from the tax imposed by subtitle A by  
Colleges and universities of states and other governmental  
reason of section 501(a);  
The government of an U.S. territory or political subdivision or  
units, and subsidiary corporations wholly owned by such  
colleges and universities. However, a section 501(c)(1)  
corporation that is an instrumentality of the United States and  
both organized and exempt from tax by an Act of Congress  
doesn’t have to file.  
instrumentality thereof;  
Any State, the District of Columbia, or a political subdivision or  
instrumentality thereof;  
The Tennessee Valley Authority;  
Qualified tuition programs described under section 529 that  
An Indian tribal government or a subdivision or instrumentality  
have $1,000 or more of unrelated trade or business gross  
income.  
thereof;  
Any Alaska Native Corporation (as defined in section 3 of the  
Qualified ABLE programs described under section 529A that  
Alaska Native Claims Settlement Act (43 U.S.C. 1602(m))); and  
have $1,000 or more of unrelated trade or business gross  
income.  
Any corporation operating on a cooperative basis that is  
engaged in furnishing electric energy to persons in rural areas.  
Pre-filing registration requirement. Before you file Form  
990-T, if you intend to make an elective payment election on  
Form 3800, you must complete a pre-filing registration for each  
property or facility. To register, go to IRS.gov/credits-deductions/  
5884, Inflation Reduction Act (IRA) and CHIPS Act of 2022  
(CHIPS) Pre-Filing Registration Tool. Also see Registering For  
and Making Elective Payment and Transfer Elections in the  
Instructions for Form 3800.  
Trustees for the following trusts that have $1,000 or more of  
unrelated trade or business gross income.  
1. Individual retirement accounts (IRAs), including traditional  
IRAs described under section 408(a).  
2. Simplified employee pension IRAs (SEP IRAs) described  
under section 408(k).  
3. Savings incentive match plan for employees of small  
employers IRAs (SIMPLE IRAs) described under section 408(p).  
4. Roth IRAs described under section 408A.  
5. Coverdell education savings accounts (ESAs) described  
under section 530.  
Organizations With or Without Current UBTI  
6. Archer medical savings accounts (Archer MSAs) described  
under section 220.  
Elective payment election. Applicable entities making an  
elective payment election with respect to applicable credits (see  
section 6417), and eligible taxpayers making an elective  
payment election with respect to the advanced manufacturing  
investment credit under section 48D.  
7. Health savings accounts (HSAs) described under section 223.  
Each account of a type listed above is treated as a  
separate trust for unrelated business income tax  
!
CAUTION  
purposes (even if there is a single owner or beneficiary  
Organizations making an elective payment election must  
complete and attach Form 3800, General Business Credit, as  
well as the required form(s) on which you compute each  
individual credit. If your organization is filing Form 990-T only to  
make the elective payment election, see Elective Payment  
Election under Which Parts to Complete, later.  
Proxy tax. Organizations liable for the proxy tax on lobbying  
and political expenditures. See Part II, Line 3. Proxy Tax, later, for  
a discussion of the proxy tax. If your organization is only required  
to file because of the proxy tax, see Proxy tax only under Which  
Parts To Complete, later.  
Other taxes or amounts. Organizations that are liable for  
other taxes (such as tax deferred under section 1291 (Form  
990-T, Part II, line 4) or section 1294 (Part III, line 4)), or  
organizations liable for other amounts due (or entitled to a refund  
of, or credit for other amounts such as recapture of tax credits or  
interest adjustments (such as recapture of a credit or interest  
due under a look-back rule (Form 990-T, Part III, line 3e)). See a  
discussion of these items later. If your organization is required to  
file Form 990-T only because of these taxes or other amounts,  
see Other Taxes under Which Parts To Complete, later.  
Qualified opportunity investment (annual report).  
Organizations that deferred a capital gain into a qualified  
opportunity fund (QOF) must file Form 990-T with Schedule D,  
Form 8949, and Form 8997 attached. Each such organization  
must file Form 990-T with Form 8997 attached annually until the  
for multiple accounts) and must have its own employer  
identification number (EIN) if it will file Form 990-T to report  
gross unrelated business taxable income of $1,000 or more. A  
custodian is treated as a trustee. See section 408(h). Individual  
retirement annuities, unlike IRAs, aren't subject to unrelated  
business income tax.  
IRAs and other tax-exempt shareholders in a RIC or  
REIT filing Form 990-T, only to obtain a refund of income  
tax paid on undistributed long-term capital gains should  
TIP  
complete Form 990-T, as explained in IRAs and other  
tax-exempt shareholders in a RIC or REIT, later.  
Applicable entity making an elective payment  
election on IRA 2022 credits  
IRA 2022 extends, modifies, or creates several energy-related  
investment and production tax credits. These credits are taken  
as general business credits. IRA 2022 also created new section  
6417, which permits an applicable entity to make an elective  
payment election with respect to each applicable credit.  
Under section 6417(d)(1)(A), applicable entities are defined  
as:  
State and local governments,  
Indian tribal governments,  
2
Instructions for Form 990-T  
 
organization disposes of the investment. See the Instructions for  
Form 8997.  
Other taxes. Organizations that are required to file Form  
990-T only because they are liable for tax under section 1291 or  
tax previously deferred under section 1294, recapture taxes, the  
tax on a hospital organization’s non-compliant facility income, or  
other items listed in the instructions for Part III, line 4, must  
complete the following.  
If you are filing Form 990-T only with regard to an  
elective payment election, because of the proxy tax,  
other taxes, or only to claim a refund, go directly to  
TIP  
Elective Payment Election Only, Proxy Tax Only, Other Taxes, or  
Claim for Refund, later. If you are filing Form 990-T only to claim  
the credit for small employer health insurance premiums, see the  
instructions for Part III, line 6f, later.  
The heading above Part I except items J and K.  
The applicable lines of Parts II and III.  
Signature area.  
Attach all appropriate forms and/or schedules showing the  
computation of the applicable tax or taxes.  
Which Parts To Complete  
Other amounts due. Organizations that are required to file  
Form 990-T only because they are liable for amounts due  
because of the recapture of a tax credit, or other items listed in  
the instructions for Part III, line 3, must complete the following.  
Organizations with unrelated business taxable income.  
Organizations with UBTI must complete Form 990-T, and also a  
separate Schedule A (Form 990-T) for each separate unrelated  
trade or business. See Regulations section 1.512(a)-6.  
Complete all Schedules A (Form 990-T) first. See General  
Instructions for Schedule A (Form 990-T), later.  
The heading above Part I except items J and K.  
The applicable lines of Parts II and III that require an entry.  
Signature area.  
Attach all appropriate forms and/or schedules showing the  
Consolidated returns. The consolidated return provisions of  
section 1501 don't apply to exempt organizations, except for  
organizations having title holding companies. If a title holding  
corporation described in section 501(c)(2) pays any amount of  
its net income for a tax year to an organization exempt from tax  
under section 501(a) (or would, except that the expenses of  
collecting its income exceeded that income), and the corporation  
and organization file a consolidated return as described below,  
then treat the title holding corporation as being organized and  
operated for the same purposes as the other exempt  
organization (in addition to the purposes described in section  
501(c)(2)).  
Two organizations exempt from tax under section 501(a), one  
a title holding company and the other earning income from the  
first, will be includible corporations for purposes of section  
1504(a). If the organizations meet the definition of an affiliated  
group and the other relevant provisions of chapter 6, then these  
organizations may file a consolidated return. The parent  
organization must attach Form 851, Affiliations Schedule, to the  
consolidated return. For the first year a consolidated return is  
filed or for the first year a new corporation is added to a  
consolidated return, the title holding company must attach Form  
1122, Authorization and Consent of Subsidiary Corporation To  
Be Included in a Consolidated Income Tax Return. See  
Regulations section 1.1502-100.  
computation of the applicable tax or taxes.  
Claim for refund (including special instructions for IRA  
trustees or direct payments of certain credits). If your only  
reason for filing a Form 990-T is to claim a refund or request a  
credit, complete the following.  
The heading above Part I except items J and K.  
Enter -0- on Part I, lines 1 and 11, and Part III, line 4.  
Enter the credit or payment on Part III, lines 6a through 6g, as  
appropriate.  
Part III, lines 7, 10, and 11.  
Signature area.  
For claims described below, follow the additional instructions  
for that claim.  
IRAs and other tax-exempt shareholders in a RIC or REIT.  
If you are an IRA or other tax-exempt shareholder that is invested  
in a RIC or a REIT and file Form 990-T only to obtain a refund of  
income tax paid on undistributed long-term capital gains, follow  
the steps under Claim for refund (including special instructions  
for IRA trustees) above; check the applicable box in item H at the  
top of Form 990-T; and attach Copy B of Form 2439, Notice to  
Shareholder of Undistributed Long-Term Capital Gains.  
Composite Form 990-T. If you are a trustee of more than one  
IRA invested in a RIC, you may be able to file a composite Form  
990-T to claim a refund of tax under section 852(b) instead of  
filing a separate Form 990-T for each IRA. See Notice 90-18,  
1990-1 C.B. 327, for information on who can file a composite  
return. Complete the steps under Claim for refund (including  
special instructions for IRA trustees) above and follow the  
additional requirements in the notice.  
Organizations with no UBTI. An organization with no UBTI  
that needs to file Form 990-T should complete and file Form  
990-T only. Such an organization does not complete or attach  
Schedule A (Form 990-T) to its return.  
Elective payment election only. Organizations filing with  
regard to making an elective payment election and have no  
unrelated business taxable income, including applicable entities  
(as defined earlier) not subject to federal income tax and not  
otherwise required to file any annual tax or information return,  
must complete the following lines of Form 990-T.  
Backup withholding. If your only reason for filing Form  
990-T is to claim a refund of backup withholding, complete the  
steps under Claim for refund (including special instructions for  
IRA trustees) above and attach a copy of the Form 1099 showing  
the withholding.  
The heading area above Part I, except items B, C, E, J, K, and  
L.  
When, Where, and How To File  
When To File  
Part II, lines 3 and 7 (enter -0-).  
Part III, lines 6g, 7, 10, and 11.  
Signature area.  
15th day of 4th month or 15th day of 5th month. An  
employees' trust defined in section 401(a), an IRA (including  
SEPs and SIMPLEs), a Roth IRA, a Coverdell ESA, or an Archer  
MSA must file Form 990-T by the 15th day of the 4th month after  
the end of its tax year. All other organizations must file Form  
990-T by the 15th day of the 5th month after the end of their tax  
years. If the regular due date falls on a Saturday, Sunday, or legal  
holiday, file no later than the next business day. If the return is  
filed late, see Interest and Penalties, later.  
In addition, complete and attach Form 3800, and all forms  
required to compute each applicable credit.  
Proxy tax only. Organizations that are required to file Form  
990-T only because they are liable for the proxy tax on lobbying  
and political expenditures must complete the following.  
The heading (above Part I) except items J and K.  
Part II, lines 3 and 7.  
Part III.  
Signature area.  
Attach a statement showing the proxy tax computation.  
3
Instructions for Form 990-T  
 
payment system that works in conjunction with EFTPS. Make  
arrangements with your financial institution ahead of time, noting  
the institution's availability, deadlines, and costs. To learn more,  
Extensions. Filers may request an automatic extension of time  
to file Form 990-T by using Form 8868, Application for Automatic  
Extension of Time To File an Exempt Organization Return.  
Note: For 2023, an applicable entity filing Form 990-T solely to  
Timeliness of deposits. The IRS will use business days to  
determine the timeliness of deposits. Business days are any day  
that isn’t a Saturday, Sunday, or legal holiday in the District of  
Columbia.  
make an elective payment election that is:  
A State, the District of Columbia, or political subdivision or  
instrumentality or agency thereof;  
The Tennessee Valley Authority; or  
An Indian tribal government or a subdivision or instrumentality  
Interest and Penalties  
or agency thereof,  
Your organization may be subject to interest and penalty charges  
if it files a late return or fails to pay tax when due. Generally, the  
organization isn't required to include interest and penalty  
charges on Form 990-T because the IRS can figure the amount  
and bill the organization for it.  
does not need to file Form 8868 to request an automatic  
extension of time to file Form 990-T. For 2023, a paperless  
automatic extension will be provided to each such entity that has  
registered its intention to make an elective payment election and  
has obtained one or more registration numbers.  
Interest. Interest is charged on taxes not paid by the original  
due date of the return even if the organization uses Form 8868 to  
request an automatic extension of time to file. Interest is also  
charged on penalties imposed for failure to file, negligence,  
fraud, substantial valuation misstatements, and substantial  
understatements of tax from the due date (including extensions)  
to the date of payment. The interest charge is figured at the  
underpayment rate determined under section 6621.  
Amended return. To correct errors or change a previously filed  
return, check box F, Check box if an amended return,at the top  
of the return. Also, in Part V, Supplemental Information, include a  
statement that indicates the line numbers on the original return  
that were changed and give the reason for each change.  
Generally, the amended return must be filed within 3 years after  
the date the original return was due or 3 years after the date the  
organization filed it, whichever is later.  
Late filing of return. An organization that fails to file its return  
when due (including extensions of time for filing) is subject to a  
penalty of 5% of the unpaid tax for each month or part of a month  
the return is late, up to a maximum of 25% of the unpaid tax. The  
minimum penalty for a return that is more than 60 days late is the  
smaller of the tax due or $485. The penalty won't be imposed if  
the organization can show that the failure to file on time was due  
to reasonable cause. If you receive a notice about a penalty after  
you file this return, reply to the notice with an explanation and we  
will determine if you meet reasonable-cause criteria. Don’t  
include an explanation when you file your return.  
Where and How To File  
Required electronic filing. If you are an organization or trust  
defined in section 511 and need to file Form 990-T, you are  
required to file electronically. For additional information, visit  
If you are an applicable entity that is not an organization or  
trust defined in section 511, and you are filing Form 990-T to  
make an elective payment election, electronic filing is  
encouraged but not required.  
Late payment of tax. The penalty for late payment of taxes is  
usually 1/2 of 1% of the unpaid tax for each month or part of a  
month the tax is unpaid. The penalty can’t exceed 25% of the  
unpaid tax. If you receive a notice about a penalty after you file  
this return, reply to the notice with an explanation and we will  
determine if you meet reasonable-cause criteria. Don’t include  
an explanation when you file your return.  
Estimated Tax Payments  
Generally, an organization filing Form 990-T must make  
installment payments of estimated tax if its estimated tax (tax  
minus allowable credits) is expected to be $500 or more. Don't  
include the proxy tax when computing your estimated tax liability  
for 2023.  
Estimated tax penalty. An organization that doesn’t make  
estimated tax payments when due may be subject to an  
underpayment penalty for the period of underpayment.  
Generally, an organization is subject to this penalty if its tax  
liability for the tax year is $500 or more and it didn’t make  
estimated tax payments of at least the smaller of its tax liability  
for the tax year or 100% of the prior year's tax. See section 6655  
for details and exceptions.  
Depository Method of Tax Payment  
The organization must pay any tax due in full by the due date of  
the return without extension.  
Electronic Deposit Requirement  
The organization must deposit all depository taxes (such as  
employment tax, excise tax, and corporate income tax)  
electronically. Generally, electronic funds transfers are made  
using the Electronic Federal Tax Payment System (EFTPS). For  
more information about EFTPS or to enroll in EFTPS, go to  
EFTPS.gov, or call 800-555-4477. To contact EFTPS using  
Telecommunications Relay Services (TRS) for people who are  
deaf, hard of hearing, or have a speech disability, dial 711 and  
then provide the TRS assistant the 800-555-4477 number above  
or 800-733-4829. Also, see Pub. 966, Electronic Federal Tax  
Payment System: A Guide to Getting Started.  
Trust fund recovery penalty. This penalty may apply if certain  
excise, income, social security, and Medicare taxes that must be  
collected or withheld aren't paid to the U.S. Treasury. These  
taxes are generally reported on:  
Form 720, Quarterly Federal Excise Tax Return;  
Form 941, Employer's QUARTERLY Federal Tax Return;  
Form 943, Employer's Annual Federal Tax Return for  
Agricultural Employees; or  
Form 945, Annual Return of Withheld Federal Income Tax.  
The trust fund recovery penalty may be imposed on all  
Depositing on time. For EFTPS deposits to be made timely,  
the organization must submit the deposit by 8 p.m. Eastern time  
the day before the deposit is due.  
persons who are determined by the IRS to have been  
responsible for collecting, accounting for, and paying over these  
taxes, and who acted willfully in not doing so. The penalty is  
equal to the unpaid trust fund tax. See the Instructions for Form  
720; or Pub. 15 (Circular E), Employer's Tax Guide, for details,  
including the definition of responsible persons.  
Same-day wire payment option. If you fail to submit a deposit  
transaction on EFTPS by 8 p.m. Eastern time the day before the  
date a deposit is due, you can still make your deposit on time by  
using the Federal Tax Application (FTA), a same-day federal tax  
4
Instructions for Form 990-T  
 
Report distributions from retirement or profit-sharing plans,  
Other penalties. There are also penalties that can be imposed  
for negligence, substantial understatement of tax, reportable  
transaction understatements, and fraud. See sections 6662,  
6662A, and 6663.  
IRAs, SEPs, SIMPLEs, and insurance contracts;  
Report proceeds from real estate transactions; and  
Report distributions from an HSA, an Archer MSA, or a  
Medicare Advantage MSA.  
Other Forms That May Be Required  
When filing the above listed Form 1099 series  
information returns, the organization must also file Form  
1096, Annual Summary and Transmittal of U.S.  
!
Forms W-2 and W-3. File Form W-2, Wage and Tax Statement,  
and Form W-3, Transmittal of Wage and Tax Statements, to  
report wages, tips, other compensation, withheld income taxes,  
and withheld social security/Medicare taxes for employees.  
CAUTION  
Information Returns.  
Form 4466. File Form 4466, Corporation Application for Quick  
Refund of Overpayment of Estimated Tax, to apply for a quick  
refund if the organization overpaid its estimated tax for the year  
by at least 10% of its expected income tax liability and at least  
$500.  
Form 461. Noncorporate taxpayers may need to file Form 461,  
Limitation on Business Losses. See Form 461 and its  
instructions.  
Form 720. File Form 720, Quarterly Federal Excise Tax Return,  
to report environmental excise taxes, communications and air  
transportation taxes, fuel taxes, manufacturers taxes, ship  
passenger tax, and certain other excise taxes. See Trust fund  
recovery penalty, earlier.  
Form 5498. File Form 5498, IRA Contribution Information, to  
report contributions (including rollover contributions) to any IRA,  
including a SEP, SIMPLE, or Roth IRA, and to report Roth IRA  
conversions, IRAs, and the fair market value (FMV) of the  
account.  
Form 926. File Form 926, Return by a U.S. Transferor of  
Property to a Foreign Corporation, if the organization is required  
to report certain transfers to foreign corporations under section  
6038B.  
Form 5498-ESA. File Form 5498-ESA, Coverdell ESA  
Contribution Information, to report contributions (including  
rollover contributions) to a Coverdell ESA.  
Form 940. File Form 940, Employer's Annual Federal  
Unemployment (FUTA) Tax Return, if the organization is liable for  
FUTA tax.  
Form 5498-SA. File Form 5498-SA, HSA, Archer MSA, or  
Medicare Advantage MSA Information, to report contributions to  
an HSA or Archer MSA, and the FMV of an HSA, an Archer  
MSA, or a Medicare Advantage MSA. See the Instructions for  
Forms 1099-SA and 5498-SA.  
Form 941 and Form 943. File Form 941, Employer's  
QUARTERLY Federal Tax Return; or Form 943, Employer's  
Annual Federal Tax Return for Agricultural Employees, to report  
income tax withheld, and employer and employee social security  
and Medicare taxes. Also, see Trust fund recovery penalty,  
earlier.  
Form 5713. File Form 5713, International Boycott Report, if the  
organization had operations in, or related to, certain boycotting  
countries.  
Form 5884-C. File Form 5884-C, Work Opportunity Credit for  
Qualified Tax-Exempt Organizations Hiring Qualified Veterans, to  
claim the work opportunity credit for qualified first-year wages  
paid to qualified veterans who begin working for the organization  
on or after November 22, 2011, and before January 1, 2026.  
Form 945. File Form 945, Annual Return of Withheld Federal  
Income Tax, to report income tax withheld from nonpayroll  
distributions or payments, including pensions, annuities, IRAs,  
gambling winnings, and backup withholding.  
Form 965-A and Form 965-B. See Form 965-A, Individual  
Report of Net 965 Tax Liability; Form 965-B, Corporate and Real  
Estate Investment Trust (REIT) Report of Net 965 Tax Liability  
and Electing REIT Report of 965 Amounts; and their respective  
instructions, for more information.  
Form 5884-D. File Form 5884-D, Employee Retention Credit for  
Certain Tax-Exempt Organizations Affected by Qualified  
Disasters, to claim the employee retention credit against certain  
payroll taxes if activities of the organization became inoperable  
because of damage from a qualified disaster. See the  
Instructions for Form 5884-D for more information.  
Form 1098. File Form 1098, Mortgage Interest Statement, to  
report the receipt from any individual of $600 or more of  
mortgage interest (including points) in the course of the  
organization's trade or business and reimbursements of overpaid  
interest.  
Form 6198. File Form 6198, At-Risk Limitations, if the  
organization has a loss from an at-risk activity conducted as a  
trade or business or for the production of income.  
Forms 8275 and 8275-R. Taxpayers and income tax return  
preparers file Form 8275, Disclosure Statement, and Form  
8275-R, Regulation Disclosure Statement, to disclose items or  
positions taken on a tax return or that are contrary to Treasury  
regulations (to avoid parts of the accuracy-related penalty or  
certain preparer penalties).  
Forms 1099-A, B, DIV, INT, LTC, MISC, NEC, OID, R, S, and  
SA. Organizations engaged in an unrelated trade or business  
may be required to:  
File an information return on Forms 1099-A, B, DIV, INT, LTC,  
MISC, NEC, OID, R, S, and SA;  
Report acquisitions or abandonments of secured property  
Form 8300. File Form 8300, Report of Cash Payments Over  
$10,000 Received in a Trade or Business, if the organization  
received more than $10,000 in cash or foreign currency in one  
transaction or in a series of related transactions. See Form 8300,  
Instructions for Form 8300, and Regulations section  
1.6050I-1(c).  
through foreclosure;  
Report proceeds from broker and barter exchange  
transactions;  
Report certain dividends and distributions;  
Report interest income;  
Report certain payments made on a per diem basis under a  
long-term care insurance contract, and certain accelerated  
death benefits;  
Form 8582. File Form 8582, Passive Activity Loss Limitations,  
for trusts that have losses (including prior-year unallowed losses)  
from passive activities.  
Report miscellaneous income (such as payments to providers  
of health and medical services, and miscellaneous income  
payments);  
Form 8697. File Form 8697, Interest Computation Under the  
Look-Back Method for Completed Long-Term Contracts, to  
figure the interest due or to be refunded under the look-back  
method of section 460(b)(2). The look-back method applies to  
Report nonemployee compensation;  
Report original issue discount;  
5
Instructions for Form 990-T  
 
certain long-term contracts that are accounted for under either  
the percentage method or the completion-capitalized cost  
method.  
Analysis (OTSA). Other penalties, such as an accuracy-related  
penalty under section 6662A, may also apply. See the  
Instructions for Form 8886 for details.  
Form 8810. File Form 8810, Corporate Passive Activity Loss  
and Credit Limitations, for closely held corporations that have  
losses or credits (including prior-year unallowed losses and  
credits) from passive activities.  
Form 8899. File Form 8899, Notice of Income From Donated  
Intellectual Property, to report income from qualified intellectual  
property.  
Form 8925. File Form 8925, Report of Employer-Owned Life  
Insurance Contracts, which must be filed by every applicable  
policyholder owning one or more employer-owned life insurance  
contracts issued after August 17, 2006.  
Form 8865. File Form 8865, Return of U.S. Persons With  
Respect To Certain Foreign Partnerships, if the organization:  
1. Controlled a foreign partnership (that is, owned more than  
a 50% direct or indirect interest in the partnership);  
Form 8975. Certain U.S. persons that are the ultimate parent  
entity of a U.S. multinational enterprise group with annual  
revenue for the preceding reporting period of $850 million or  
more are required to file Form 8975. Form 8975 and its  
Schedules A (Form 8975) must be filed with the income tax  
return of the ultimate parent entity of a U.S. multinational  
enterprise group for the tax year in or within which the reporting  
period covered by Form 8975 ends. For more information, see  
Form 8975, Schedule A (Form 8975), and the Instructions for  
Form 8975 and Schedule A (Form 8975).  
2. Owned at least a 10% direct or indirect interest in a  
foreign partnership while U.S. persons controlled that  
partnership;  
3. Had an acquisition, disposition, or change in proportional  
interest in a foreign partnership that:  
a. Increased its direct interest to at least 10% or reduced its  
direct interest of at least 10% to less than 10%;  
b. Changed its direct interest by at least a 10% interest; or  
4. Contributed property to a foreign partnership in exchange  
Form 8978. File Form 8978, Partner's Additional Reporting  
Year Tax, to report adjustments shown on Form 8986, Partner's  
Share of Adjustment(s) to Partnership-Related Items, received  
from a partnership that has elected to push out adjustments to  
partnership-related items to their partners.  
for a partnership interest if:  
a. Immediately after the contribution, the organization  
directly or indirectly owned at least a 10% interest in the foreign  
partnership; or  
b. The FMV of the property the organization contributed to  
the foreign partnership in exchange for a partnership interest,  
when added to other contributions of property made to the  
foreign partnership by the organization or a related person during  
the preceding 12-month period, exceeds $100,000.  
Form 8990. File Form 8990, Limitation on Business Interest  
Expense Under Section 163(j), to claim a deduction for business  
interest unless the taxpayer meets certain specified exceptions.  
Also, Form 8990 must be filed by any taxpayer that owns an  
interest in a partnership with current-year or prior-year carryover  
excess business interest expense allocated from the  
partnership.  
Also, the organization may have to file Form 8865 to report  
certain dispositions by a foreign partnership of property it  
previously contributed to that foreign partnership if it was a  
partner at the time of the disposition. See Form 8865 and its  
separate instructions.  
Form 8991. File Form 8991, Tax on Base Erosion Payments of  
Taxpayers With Substantial Gross Receipts, for any corporation,  
other than a RIC, a REIT, or an S corporation, that has aggregate  
gross receipts of at least $500 million in 1 or more of the 3  
preceding tax years ending with the preceding tax year.  
Form 8886. File Form 8886, Reportable Transaction Disclosure  
Statement, to disclose information for each reportable  
transaction in which the organization participated. Form 8886  
must be filed for each tax year that the federal income tax liability  
of the organization is affected by its participation in the  
transaction. The organization may have to pay a penalty if it is  
required to file Form 8886 but doesn’t do so. The following are  
reportable transactions.  
Form 8993. File Form 8993, Section 250 Deduction for  
Foreign-Derived Intangible Income (FDII) and Global Intangible  
Low-Taxed Income (GILTI), for the allowance of a deduction for  
the eligible percentage of FDII. The deduction is allowed only to  
domestic corporations (not including REITs, RICs, and S  
corporations).  
Any listed transaction that is the same as, or substantially  
Form 8994. File Form 8994, Employer Credit for Paid Family  
similar to, tax avoidance transactions identified by the IRS.  
and Medical Leave, to figure the employer credit for paid leave.  
Any transaction offered under conditions of confidentiality for  
which the organization paid an advisor a fee of at least  
$250,000.  
Form 8995. Refer to Form 8995, Qualified Business Income  
Deduction Simplified Computation, if you are a trust filing Form  
990-T and have unrelated business income, to determine if you  
have qualified business income (QBI) and may be allowed a QBI  
deduction under section 199A. See the instructions for Form  
8995, Part I, line 9.  
Certain transactions for which the organization has  
contractual protection against disallowance of the tax benefits.  
Any transaction resulting in a loss of at least $10 million in any  
single year or $20 million in any combination of years.  
Certain transactions identified by the IRS in published  
Form 8995-A. Refer to Form 8995-A. Use this form to figure  
your qualified business income deduction. Use separate  
Schedules A, B, C, and/or D, as appropriate, to help calculate  
the deduction.  
guidance as a “transaction of interest” (a transaction that the IRS  
believes has a potential for tax avoidance or evasion, but hasn’t  
yet been identified as a listed transaction).  
Form 8886-T. File Form 8886-T, Disclosure by Tax-Exempt  
Entity Regarding Prohibited Tax Shelter Transaction, to disclose  
information with respect to each prohibited tax shelter  
Form 8997. File Form 8997, Initial and Annual Statement of  
Qualified Opportunity Fund (QOF) Investments, annually to  
report investments held in a QOF at any time during the year.  
See the instructions for Form 8997.  
transaction to which the organization is a party.  
Penalties. The organization may have to pay a penalty if it is  
required to disclose a reportable transaction under section 6011  
and fails to properly complete and file Form 8886. The penalty is  
$50,000 ($200,000 if the reportable transaction is a listed  
transaction) for each failure to file Form 8886 with its return or for  
failure to provide a copy of Form 8886 to the Office of Tax Shelter  
Accounting Methods  
An accounting method is a practice a taxpayer follows to  
determine the year in which to report revenue and expenses for  
federal income tax purposes. An accounting method includes  
6
Instructions for Form 990-T  
   
not only the overall plan of accounting for gross income or  
deductions (for example, an accrual method or the cash receipts  
and disbursement method), but also the treatment of an item  
used in such overall plan. However, a practice that does not  
affect the timing for reporting an item of income or deduction for  
purposes of determining taxable income is not an accounting  
method. A taxpayer, including a tax-exempt entity, adopts any  
permissible accounting method in the first year in which it uses  
the method in determining its taxable income. See Rev. Proc.  
2015-13, 2015-5 I.R.B. 419.  
Alternatively, if a taxpayer, including a tax-exempt entity, has  
not yet adopted an accounting method for an item of income or  
deduction, a change in how the entity reports the item isn’t a  
change in accounting method. In this case, the procedures  
applicable to requests for accounting method changes (the  
requirement to file Form 3115) aren’t applicable. See Rev. Proc.  
2015-13 for the definition of what constitutes an accounting  
method change.  
Thus, a tax-exempt entity that has never taken into account  
an item of income or deduction in determining taxable income  
does not have to request consent to change its method of  
reporting that item on its Form 990-T. Additionally, a tax-exempt  
entity that has never been subject to federal income tax on an  
item of income or deduction, but that is required to file a Form  
990-T solely due to owing a section 6033(e)(2) proxy tax, does  
not have to request consent to change its method for reporting  
the item.  
Adjustments required when changing an accounting  
method. A taxpayer, including a tax-exempt entity, that changes  
its accounting method must generally calculate and report an  
adjustment to ensure that no portion of the item being changed  
is permanently omitted or duplicated (see section 481(a)).  
However, depending on the specific method change, the IRS  
may provide that an adjustment isn’t required or permitted.  
An exempt organization may adopt an accounting  
method not only for purposes of calculating taxable  
!
CAUTION  
income, but also for purposes of determining whether  
taxable income will be subject to federal income tax. For  
example, a tax-exempt entity may adopt an accounting method  
for an item of income from an unrelated trade or business activity  
even if the gross income from the activity is less than $1,000 and  
is therefore not taxed for federal income tax purposes pursuant  
to Regulations section 1.6012-2(e).  
An accounting method for an item of income or deduction may  
generally be adopted separately for each of the taxpayer’s trades  
or businesses. However, in order to be permissible, an  
accounting method must clearly reflect the taxpayer’s income.  
Unless instructed otherwise, the organization should generally  
use the same accounting method on the Form 990-T and all  
schedules to report revenue and expenses that it regularly uses  
to keep its books and records.  
Generally, a taxpayer, including a tax-exempt entity, will  
recognize a positive section 481(a) adjustment (that is,  
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CAUTION  
an increase to income) ratably over 4 tax years and will  
recognize a negative section 481(a) adjustment in full in the year  
of change. See Rev. Proc. 2015-13 or its successor.  
Accounting method change. Once a taxpayer, including a  
tax-exempt entity, adopts an accounting method for federal  
income tax purposes, the taxpayer must generally request the  
IRS consent before it can change its accounting method (even if  
the year in which the taxpayer seeks to make the change is a  
year in which it generates only tax-exempt income or is  
otherwise not taxed on its taxable income). In most cases, a  
taxpayer requests consent to change an accounting method by  
filing Form 3115, Application for Change in Accounting Method.  
See Rev. Proc. 2015-13, or any successor, for general  
procedures for obtaining consent to change an accounting  
method. See the Instructions for Form 3115 and Pub. 538 for  
more information and exceptions. See Rev. Proc. 2021-34 for  
additional procedures that may apply for obtaining automatic  
consent to change methods of accounting for revenue  
recognition and certain other methods of accounting that may  
affect the accounting for revenue recognition. Also see Rev.  
Proc. 2022-09 for additional procedures that may apply for  
obtaining automatic consent to change certain methods of  
accounting related to small businesses.  
An organization may elect a 1-year adjustment period for a  
positive section 481(a) adjustment that is less than $50,000. See  
the Instructions for Form 3115 for more information and the  
requirements to make this election.  
Include any positive section 481(a) adjustment on  
Schedule A (Form 990-T), Part I, line 12 (Other income). If the  
section 481(a) adjustment is negative, report it as a deduction on  
Schedule A (Form 990-T), Part II, line 14 (Other deductions).  
The section 481(a) adjustment should not be reported on Form  
990-T as a negative number.  
However, as discussed above, if a tax-exempt entity has not  
yet adopted an accounting method for an item, a change in how  
the entity reports the item for purposes of filing the Form 990-T is  
not a change in accounting method. In this case, an adjustment  
under section 481(a) isn’t required or permitted.  
Accounting Period  
Depending on the specific accounting method change being  
requested, the taxpayer may be able to request automatic  
consent. This means that, as long as the taxpayer follows the  
applicable procedures, the taxpayer does not have to wait for  
formal approval by the IRS before applying the new accounting  
method available at Rev. Proc. 2022-14, for the List of Automatic  
Changes for 2022; as modified by Rev. Proc. 2022-23; 2022-18  
I.R.B. 1052, available at Rev. Proc. 2022-23, providing guidance  
allowing late elections under sections 168(j)(8) and 168(l)(3)(D),  
and also providing guidance allowing a late election under  
section 181(a)(1), for a list of accounting method changes that  
may qualify for automatic consent.  
For example, a tax-exempt entity that has adopted an  
accounting method for an item of income from an unrelated trade  
or business must generally request consent before it can change  
its method of accounting for that item in any subsequent year.  
This is true regardless of whether gross income from the  
unrelated trade or business is $1,000 or more in such  
subsequent year.  
The return must be filed using the organization's established  
annual accounting period. If the organization has no established  
accounting period, file the return on the calendar-year basis.  
Applicable entities such as state and local governmental  
entities and Indian tribal governments that have not established  
an annual accounting period for purposes of filing a tax return  
should identify their annual accounting period on their first Form  
990-T.  
Fiscal year. If the organization has established a fiscal year  
accounting period, use the 2023 Form 990-T to report on the  
organization's fiscal year that began in 2023 and ended 12  
months later. A fiscal year accounting period should normally  
coincide with the natural operating cycle of the organization. Be  
certain to indicate in Item A of Form 990-T, the date the  
organization's fiscal year began in 2023 and the date the fiscal  
year ended in 2024.  
To change an accounting period, some organizations may  
make a notation on a timely filed Form 990, 990-EZ, 990-PF, or  
7
Instructions for Form 990-T  
   
990-T. Others may be required to file Form 1128, Application To  
Adopt, Change, or Retain a Tax Year. For details on which  
procedure applies to your organization, see Rev. Proc. 85-58,  
1985-2 C.B. 740, and the Instructions for Form 1128.  
Name and Address  
The name and address on Form 990-T should be the same as  
the name and address shown on other Forms 990.  
Include the suite, room, or other unit number after the street  
address. If the Post Office doesn’t deliver mail to the street  
address and the organization has a P.O. box, show the box  
number instead of the street address.  
For the short-period return, figure the tax by placing the  
organization's taxable income on an annual basis. If the  
organization changes its accounting period, file Form 990-T for  
the short period that begins with the first day after the end of the  
old tax year and ends on the day before the first day of the new  
tax year. For details, see section 443.  
If the organization receives its mail in care of a third party  
(such as an accountant or an attorney), enter on the street  
address line “C/O” followed by the third party's name and street  
address or P.O. box.  
Reporting 990-T Information on Other Returns  
Change of name. If the organization has changed its  
name, it must check the box next to “Name of  
!
Your organization may be required to file an annual information  
return on:  
CAUTION  
organization” and also provide the following when filing  
this return, if it is:  
Form 990, Return of Organization Exempt From Income Tax;  
Form 990-EZ, Short Form Return of Organization Exempt  
A corporation, is incorporated with the state or limited liability  
From Income Tax;  
company treated as a corporation for tax purposes (that is, not a  
disregarded entity)—an amendment to the articles of  
incorporation or articles of organization along with proof of filing  
with the state;  
Form 990-PF, Return of Private Foundation or Section 4947(a)  
(1) Nonexempt Charitable Trust Treated as a Private Foundation;  
or  
Form 5500, Annual Return/Report of Employee Benefit Plan.  
A trust—an amendment to the trust agreement with the  
trustee(s) signature; or  
An association, or an unincorporated association—an  
If so, include on that information return the unrelated business  
amendment to the articles of association, constitution, by-laws,  
or other organizing document with signatures of at least two  
officers/members.  
gross income and expenses (but not including the specific  
deduction claimed on Part I, line 8, or any expense carryovers  
from prior years) reported on Form 990-T for the same tax year.  
Items A Through L  
Rounding Off to Whole Dollars  
Item A. If the organization has changed its address since it last  
You may round off cents to whole dollars on the organization’s  
return and schedules. If you do round to whole dollars, you must  
round all amounts. To round, drop amounts under 50 cents and  
increase amounts from 50 to 99 cents to the next dollar. For  
example, $1.39 becomes $1 and $2.50 becomes $3. If you have  
to add two or more amounts to figure the amount to enter on a  
line, include cents when adding the amounts and round off only  
the total. If you are entering amounts that include cents, make  
sure to include the decimal point. There is no cents column on  
the form.  
filed a return, check item A.  
If a change in address occurs after the return is filed, use  
Form 8822-B, Change of Address or Responsible  
TIP  
Party — Business, to notify the IRS of the new address.  
Item B. Check the box under which the organization receives its  
tax exemption.  
Qualified pension, profit-sharing, and stock bonus plans  
should check the 501 box and enter “a” between the first set of  
parentheses. Do not make an entry in the space between the  
second parentheses.  
For other organizations exempt under section 501, check the  
box for 501 and enter the section that describes their tax-exempt  
status, for example, 501(c)(3).  
Public Inspection Requirements of Section 501(c)  
(3) Organizations  
Under section 6104(d), a section 501(c)(3) organization that files  
Form 990-T must make its entire annual exempt organization  
business income tax return (including amended returns)  
available for public inspection. See Appendix C. Public  
Inspection of Form 990-T Returns Filed by Section 501(c)(3)  
Organization, later.  
For tax-exempt organizations that don't receive their  
exemption under section 501, use the following guide.  
IF you are a  
THEN check this box  
408(e).  
IRA, SEP, or SIMPLE  
Roth IRA  
408A.  
Specific Instructions  
Archer MSA  
220(e).  
Coverdell ESA  
530(a).  
Period Covered  
Qualified State Tuition Program  
Qualified ABLE Program  
529(a).  
File the 2023 form for calendar year 2023 or a fiscal year  
beginning in 2023 and ending in 2024. For a fiscal year, fill in the  
tax year information at the top of the form.  
529A.  
The 2023 Form 990-T may also be used if:  
Public colleges and universities that have not obtained  
recognition of exemption under section 501(c)(3), and applicable  
entities that are not described in section 501(a) should not check  
any box in item B.  
The organization has a tax year of less than 12 months that  
begins and ends in 2024, and  
The 2024 Form 990-T isn't available at the time the  
organization is required to file its return. The organization must  
show its 2024 tax year on the 2023 Form 990-T and take into  
account any tax law changes that are effective for tax years  
beginning after 2023.  
Item C. Enter the total of the end-of-year assets from the  
organization's books of account.  
8
Instructions for Form 990-T  
             
1. The corporation is a subsidiary in an affiliated group  
(defined in section 1504) but isn't filing a consolidated return for  
the tax year with that group.  
Item D. Every organization or entity filing Form 990-T must  
have its own employer identification number (EIN).  
No organization or other entity should use the EIN  
2. The corporation is a subsidiary in a parent-subsidiary  
of any other organization or entity.  
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controlled group (defined in section 1563).  
CAUTION  
Excluded member. If the corporation is an "excluded  
member" of a controlled group (see section 1563(b)(2)), it is still  
considered a member of a controlled group for purposes of item  
K.  
An employees' trust described in section 401(a) and exempt  
under section 501(a) should enter its own trust identification  
number in this block.  
An IRA trust enters its own EIN in this block. An IRA trust  
Item L. Enter the name and address of the person who has the  
organization's books and records and the telephone number at  
which they can be reached.  
never enters a social security number (SSN) or the trustee's EIN.  
An EIN may be applied for in one of the following ways.  
Online. Go to IRS.gov/EIN. The EIN is issued immediately  
once the application information is validated.  
Part I. Total Unrelated Business  
Taxable Income  
Total of Unrelated Business Taxable Income  
Computed From All Unrelated Trades or  
Businesses  
By mailing or faxing Form SS-4, Application for Employer  
Identification Number.  
Note. Only organizations located in the United States or U.S.  
territories can use the online application. Foreign organizations  
must use one of the other methods to apply for an EIN in one of  
the following ways.  
Item E. If the organization is covered by a group exemption,  
Line 1. Enter the sum of the positive amounts from all  
Schedules A (Form 990-T), Part II, line 18. Don’t include any  
amount from Schedule A (Form 990-T), Part II, line 18, that is  
less than zero in the computation of total unrelated trade or  
business income reported on Part I, line 1.  
enter the group exemption number.  
Item F. Check this box if the organization previously filed a  
Form 990-T return with the IRS for a tax year and is now filing  
another return for the same tax year to amend the previously  
filed return. Also, see Amended return, earlier, for information  
you must include in an amended return.  
Line 2. Reserved. Do not enter any amount on this line.  
Charitable Contributions  
Item G. Check the box that describes your organization.  
Check the box for "6417(d)(1)(A) Applicable entity" only if no  
other checkbox on this line applies. For example, a rural electric  
cooperative exempt under section 501(c)(12) should check the  
box for 501(c) Corporation or 501(c) Trust, (as the case may be).  
Similarly, a public college or university should check the box for  
"State college/university" even if it is filing Form 990-T solely with  
regard to an elective payment election.  
Line 4. Enter contributions or gifts actually paid within the tax  
year to or for the use of charitable and governmental  
organizations described in section 170(c). Also, enter any  
unused contributions carried over from earlier years. The  
deduction for contributions will be allowed whether or not directly  
connected with the conduct of a trade or business. See  
Appendix B. Charitable Contribution Deduction, later.  
“Other trust” includes IRAs, SEPs, SIMPLEs, Roth IRAs,  
Coverdell ESAs, and Archer MSAs.  
Deduction for Net Operating Loss Arising in Tax  
Years Beginning Before 2018  
Section 529 organizations check the 501(c) corporation or  
501(c) trust box depending on whether the organization is a  
corporation or a trust. Also, the box for 529(a) in item B must be  
checked.  
Line 6. Enter the smaller of (a) the amount of NOL arising in tax  
years beginning before January 1, 2018, or (b) the amount  
shown on Part I, line 1.  
Compute your tax in Part II on the appropriate line. If you  
check 501(c) corporation, you must compute your tax on  
!
CAUTION  
Part II, line 1, and leave line 2 blank. If you check 501(c)  
Specific Deduction  
trust, 401(a) trust, or Other trust, you must compute your tax on  
Part II, line 2, and leave line 1 blank.  
Line 8. A specific deduction of $1,000 is allowed except for  
computing the NOL and the net operating loss deduction under  
section 172.  
Item H. Check if filing Form 990-T only to claim a credit from  
Form 8941, to claim a refund shown on Form 2439, or to claim  
the elective payment election amount from Form 3800.  
Only one specific deduction may be taken, regardless of the  
number of unrelated businesses conducted. However, a  
diocese, province of a religious order, or convention or  
association of churches is allowed one specific deduction for  
each parish, individual church, district, or other local unit that  
regularly conducts an unrelated trade or business. This applies  
only to those parishes, districts, or other local units that aren't  
separate legal entities but are components of a larger entity  
(diocese, province, convention, or association). Each specific  
deduction will be the smaller of $1,000 or the gross income from  
any unrelated trade or business the local unit conducts. If you  
claim a total specific deduction larger than $1,000, attach a  
statement showing how you figured the amount. The attached  
statement should include the name of each local unit, its gross  
unrelated business income, and its allowable specific deduction  
(which can’t exceed the smaller of $1,000 or the local unit’s  
gross unrelated business income).  
Item I. Check if you are a 501(c)(3) organization filing a  
consolidated return with a 501(c)(2) title holding corporation.  
See Consolidated returns, earlier, for additional information.  
Item J. Enter the total number of Schedules A attached to Form  
990-T. An organization with one or more unrelated trades or  
businesses will complete a separate Schedule A for each  
unrelated trade or business.  
Complete all needed Schedules A before completing  
Parts I through V of Form 990-T.  
TIP  
Item K. Check “Yes” box if your organization is a corporation  
and either (1) or (2) below applies.  
9
Instructions for Form 990-T  
         
The diocese, province of a religious order, or convention or  
association of churches must file a return reporting the gross  
income and deductions of all its units that aren't separate legal  
entities. These local units can’t file separate returns because  
they aren't separately incorporated. Local units that are  
separately incorporated must file their own returns and can’t be  
included with any other entity except for a title holding company.  
See Consolidated Returns, earlier.  
Tax Rate Schedule for Trusts  
If the amount on Part II, line 2, is:  
Of the amount  
over—  
Over—  
But not over—  
Tax is:  
$0  
$2,900  
10,550  
14,450  
- - - - -  
10%  
$290 + 24%  
2,126 + 35%  
3,491 + 37%  
$0  
2,900  
10,550  
14,450  
2,900  
10,550  
14,450  
For details on the specific deduction, see section 512(b)(12)  
and the related regulations.  
Proxy Tax  
Line 3. To pay the section 6033(e)(2) proxy tax on  
Section 199A Deduction  
nondeductible lobbying and political expenditures, enter the  
proxy tax on Part II, line 3, and attach a statement showing the  
computation.  
For trust filers only. If you are a trust filing Form 990-T and  
have unrelated business income, you may have Qualified  
Business Income (QBI) and may be allowed a QBI deduction  
under section 199A.  
Refer to the instructions for Form 8995, or Form 8995-A, (as  
applicable) to determine whether you meet the requirements for  
the QBI deduction and how to complete the applicable form.  
Exempt organizations, except section 501(c)(3) and certain  
other organizations, must include certain information regarding  
lobbying expenditures on Form 990. In addition, organizations  
may have to provide notices to members regarding their share of  
dues to which the expenditures are allocable. See the  
Instructions for Form 990 and Rev. Proc. 98-19, 1998-1 C.B. 547,  
for exceptions.  
If the organization elects not to provide the notices described  
earlier, it must pay the proxy tax described in section 6033(e)(2).  
If the organization doesn’t include the entire amount of allocable  
dues in the notices, it may have to pay the proxy tax. This tax  
isn't applicable to section 501(c)(3) organizations. Figure the  
proxy tax by multiplying the aggregate amount not included in  
the notices described earlier by 21%. No deductions are  
allowed.  
Line 9. For purposes of calculating the QBI deduction, the  
taxable income before the QBI deduction is the amount reported  
on Part I, line 7, minus the amount reported on Part I, line 8.  
Note. For tax years beginning after 2017, the organization  
determines the unrelated business income separately for each  
unrelated trade or business, and the income for an unrelated  
trade or business can’t be less than zero. Since a loss from an  
unrelated trade or business isn’t included in the UBTI for the tax  
year due to application of section 512(a)(6), when calculating  
QBI, omit items of income, gain, deduction, and loss from any  
unrelated trade or business that operated at a loss. A loss from  
an unrelated trade or business will be carried forward to future  
years when the trust has income (or gain that is subject to  
unrelated business income tax) from the same unrelated trade or  
business and will be used in those years in calculating the QBI.  
Additionally, W-2 wages and unadjusted basis immediately after  
the acquisition (UBIA) of qualified property from an unrelated  
trade or business that operated at a loss for the current tax year  
aren’t used in calculating the limitation on QBI for taxpayers over  
the threshold.  
Other Tax Amounts  
Line 4. Part II, line 4, is intended to capture any positive tax  
amount that doesn’t have a specific line. An MeF (Internet filing)  
dependency (attachment) captures the detail. Use line 4 to  
report tax amounts not reported on a specific line in Part II  
(excluding tax deferred under section 1294, which is included on  
Part III, line 4).  
Use this line to report the base erosion minimum tax amount  
under section 59A from Form 8991, Part IV, line 5e. Section 59A  
applies to base erosion payments paid or accrued in tax years  
beginning after 2017. See the Instructions for Form 8991 to  
determine if the organization is an applicable taxpayer under  
section 59A(e), and, if the organization is an applicable taxpayer,  
to determine the base erosion minimum tax amount. Enter the  
base erosion minimum tax amount on Part II, line 4.  
Part II. Tax Computation  
Organizations Taxable as Corporations  
Line 1. Multiply Part I, line 11, by 21% (0.21).  
Use this line to report the tax and interest on a nonqualified  
withdrawal from a capital construction fund (section 7518).  
Use this line to report the deferred tax amount (defined in  
Trusts  
Line 2. Trusts exempt under section 501(a), which otherwise  
would be subject to subchapter J (estates, trusts, etc.), are taxed  
at trust rates. This rule also applies to employees' trusts that  
qualify under section 401(a). Most trusts figure the tax on the  
UBTI amount on Part I, line 11, using the Tax Rate Schedule for  
Trusts, below. If the tax rate schedule is used, enter the tax on  
Part II, line 2, and check the “Tax rate schedule” box. If the trust  
is eligible for the rates on net capital gains and qualified  
dividends, complete Schedule D (Form 1041) and enter on Part  
II, line 2, the tax from Schedule D (Form 1041). Check the  
“Schedule D” box on line 2 and attach Schedule D (Form 1041)  
to Form 990-T.  
section 1291(c)(1)) that is the aggregate increase in taxes  
(described in section 1291(c)(2)) on an excess distribution from  
a passive foreign investment company (PFIC) that is taxable as  
UBTI. See the Instructions for Form 8621, Information Return by  
a Shareholder of a Passive Foreign Investment Company or  
Qualified Electing Fund.  
Use this line to report the increase in tax attributable to a  
partner's audit liability. If your organization received Form 8986  
from one or more partnerships that have elected to push out  
adjustments to partnership-related items to their partners,  
complete and attach Form 8978. See the Instructions for Form  
8978. Include any increase in taxes due from Form 8978, line 14,  
on Part II, line 4. If Form 8978 shows a decrease in tax, do not  
report that here. Instead, a negative adjustment should be  
reported in Part III on line 1b.  
A trust with more than one unrelated trade or business  
that computes its tax on Schedule D (Form 1041) may  
!
CAUTION  
need to adjust the amount entered on Schedule D (Form  
Unless otherwise indicated, when reporting deferred tax on  
line 4, don't include interest on the tax amount. Instead, report  
such interest as an “other amount due” on Part III, line 3. For  
example, interest on tax deferred under section 1291(c)(1),  
1041), Part V, line 22, to include only the net gain from  
Schedule D (Form 1041), line 18a (column 2), or line 19 (column  
2), that is included in income on Part I of Form 990-T.  
10  
Instructions for Form 990-T  
             
determined under section 1291(c)(3) is reported on Part III,  
line 3.  
The organization is required to file Form 3800, General  
Business Credit, to claim any business credit. For a list of  
credits, see Form 3800. Include the allowable credit from Form  
3800, Part II, line 38, on Form 990-T, Part III, line 1c.  
How to report. Attach a statement to Part II, line 4, showing (a)  
a brief description of the type of tax, and (b) the amount. For  
example, if the organization is reporting $100 of tax due from an  
increase in tax attributable to a partner's audit liability (Form  
8978), the attachment would show “Form 8978” and “$100.”  
Do not enter the net elective payment election amount  
from Form 3800 on line 1c. Enter the elective payment  
!
CAUTION  
election amount from Form 3800 on line 6g.  
An organization described in section 501(c) which is  
Alternative Minimum Tax  
exempt from tax under section 501(a) should not use  
!
Line 5. Organizations liable for tax on unrelated business  
CAUTION  
Form 3800 to claim the refundable small employer tax  
taxable income may be liable for alternative minimum tax.  
credit for certain health insurance premiums paid on behalf of its  
employees. See the instructions for Part III, line 6f. See the  
instructions to Form 3800.  
Trusts attach Schedule I, Alternative Minimum Tax–Estate  
and Trusts, and enter any tax from Schedule I on this line.  
Corporations may need to complete and attach Form 4626,  
Alterative Minimum Tax–Corporation, and enter any tax from  
Form 4626 on this line. See the Instructions for Form 4626 for  
more information.  
Credit for Prior-Year Minimum Tax  
Line 1d. Use Form 8801 to figure the minimum tax credit and  
any carryforwards of that credit for trusts. For corporations, use  
Form 8827.  
Tax on Noncompliant Facility Income  
Line 6. There is a tax on a hospital organization’s noncompliant  
facility income. See Regulations section 1.501(r)-2 for more  
information. This tax is an income tax and is separate from the  
excise tax on a failure to meet the community health needs  
assessment requirements of section 501(r)(3) that is reported on  
Form 4720.  
Total Credits  
Line 1e. Add lines 1a through 1d.  
Line 3. Other Amounts Due  
Line 3a. Recapture of investment credit. Use line 3a to  
report recapture of investment tax credit amounts required when  
certain investment tax credit property ceases to be qualified  
property before the end of the recapture period. See Form 4255,  
Recapture of Investment Credit.  
Total  
Line 7. Add Part II, lines 3, 4, 5, and 6, to Part II, line 1 or 2,  
whichever applies.  
Line 3b. Recapture of low-income housing credit. If the  
corporation disposed of property (or there was a reduction in the  
qualified basis of the property) for which it took the low-income  
housing credit, and the corporation did not follow the procedures  
that would have prevented recapture of the credit, it may owe a  
tax. See Form 8611, Recapture of Low-Income Housing Credit.  
Line 3c. Interest due under the look-back method --  
completed long-term contracts. If the corporation used the  
percentage-of-completion method under section 460(b) for  
certain long-term contracts, figure any interest due or to be  
refunded using the look-back method, described in section  
460(b)(2). Use Form 8697 to figure any interest due or to be  
refunded. See the Instructions for Form 8697. Include any  
interest due on line 3c.  
Part III. Tax and Payments  
Foreign Tax Credit  
Corporations. See Form 1118, Foreign Tax  
Credit—Corporations, for an explanation of when a corporation  
can claim this credit for payment of income tax to a foreign  
country or U.S. possession.  
Trusts. See Form 1116, Foreign Tax Credit (Individual, Estate,  
or Trust), for rules on how the trust computes the foreign tax  
credit.  
Line 1a. Complete the form that applies to the organization and  
attach the form to Form 990-T. Enter the credit on this line.  
Line 3d. Interest due under the look-back method --  
income forecast method. If the corporation used the income  
forecast method to depreciate property, it must figure any  
interest due or to be refunded using the look-back method,  
described in section 167(g)(2). Use Form 8866 to figure any  
interest due or to be refunded. See the Instructions for Form  
8866. Include any interest due on line 3d.  
Other Credits  
Line 1b. Use line 1b to enter nonrefundable credits not  
identified elsewhere in Part III, line 1. Attach a statement that lists  
the applicable form and the amount of the credit. Such credits  
may include the following.  
Any QEV passive activity credits from prior years allowed for  
Line 3e. Other Additional amounts due may be included in the  
total entered on Part III, line 3. Check the box for “Other” if the  
organization includes any of the items discussed. See How to  
report below for details on reporting these amounts on an  
attached statement.  
the current tax year from Form 8834, Qualified Electric Vehicle  
Credit, line 7. Attach Form 8834.  
The allowable credits from Form 8912, Credit to Holders of  
Tax Credit Bonds, line 12.  
If your organization received Form 8986 from one or more  
Interest on deferred tax attributable to installment sales of  
partnerships that have elected to push out adjustments to  
partnership-related items to their partners, complete and attach  
Form 8978. See the Instructions for Form 8978. Enter the  
amount of any decrease in taxes due from Form 8978, line 14.  
certain time-shares and residential lots (section 453(l)(3)) and  
certain nondealer installment obligations (section 453A(c)).  
Interest due on deferred gain (section 1260(b)).  
If the organization makes the election to be taxed on its  
income from qualifying shipping activities, complete Form 8902,  
Alternative Tax on Qualifying Shipping Activities, and attach it to  
Form 990-T. See Income from qualifying shipping activities, later.  
How to report. If the organization checked the “Other” box,  
attach a statement showing the computation of each item  
included in the total for Part III, line 3e. In addition, identify (a) the  
applicable Code section or form number, (b) the type of tax or  
General Business Credit  
Line 1c. Enter the organization's total general business credit  
(excluding the work opportunity credit, the employee retention  
credit, the empowerment zone employment credit, the Indian  
employment credit, and the credit for employer differential wage  
payments). See the Instructions for Form 3800 for exceptions.  
11  
Instructions for Form 990-T  
                 
interest, and (c) the amount of tax or interest. For example, if the  
organization is reporting $100 of tax due from the recapture of  
the QEV credit, enter “Section 30—QEV recapture tax—$100”  
on the attached statement.  
line 6e. See Backup withholding under Which Parts To  
Complete, earlier.  
Credit for Small Employer Health Insurance  
Premiums  
Line 6f. An organization described in section 501(c) which is  
exempt from tax under section 501(a) may be eligible to claim  
the refundable small employer tax credit for a percentage of  
certain health insurance premiums paid on behalf of its  
employees.  
A tax-exempt eligible small employer can request the  
refundable credit by attaching Form 8941, Credit for Small  
Employer Health Insurance Premiums, showing the calculation  
for the amount of the refundable credit claimed. A tax-exempt  
organization is eligible for the refundable credit if it is an  
organization that is described in section 501(c) which is exempt  
from tax under section 501(a). The organization must keep  
records to substantiate the amount of the credit claimed.  
Total Tax  
Line 4. Include any deferred tax on the termination of a section  
1294 election applicable to shareholders in a qualified electing  
fund (QEF) in the amount entered on Part III, line 4. See Form  
8621, Part VI, and How to report, later.  
Subtract from the total entered on Part III, line 4, any deferred  
tax on the corporation's share of undistributed earnings of a  
QEF. See Form 8621, Part III.  
How to report. Attach a statement showing the computation  
of each item included in, or subtracted from, the total on Part III,  
line 4. Specify (a) the applicable Code section, (b) the type of  
tax, and (c) the amount of tax.  
Line 5  
Section 965  
If a tax-exempt eligible small employer is filing Form  
990-T only to request a credit for small employer health  
insurance premiums paid, complete the following steps.  
TIP  
Corporation. For tax years 2021 and later, a corporation will not  
have any section 965(a) inclusions to report. If the organization  
elected to pay its section 965 net tax liability in installments, the  
organization should attach Form 965-B to Form 990-T. However,  
the current-year installment should be paid with a separate  
voucher (which will be mailed to the organization in advance of  
the payment due date). Don’t include the current-year installment  
in the Tax and Payments computation in Part III.  
1. Fill in the heading (the area above Part I) except items J  
and K. Check the box for “Credit from Form 8941” in item H .  
2. Enter -0- on Part I, line 11, and Part III, line 4.  
3. Enter the credit from Form 8941, line 20, on Part III,  
line 6f.  
4. Complete Part III, lines 7, 10, and 11, and the signature  
area.  
Trust. A trust that has "net 965 tax liability" for the current tax  
year (as described in the Instructions for Form 965-A) should  
enter on line 5 the amount from the current-year line on Form  
965-A, Part II, column (k). If the trust has no net 965 tax liability  
for the current tax year, but has elected to pay its section 965 net  
tax liability in installments, the trust should attach Form 965-A to  
Form 990-T, but should not include the current-year installment  
in the Tax and Payments computation in Part III (as described  
above for corporations).  
Elective payment election  
Line 6g. Enter the elective payment election amount from Form  
3800. See the Instructions for Form 3800. On line 6g, enter the  
total net elective payment election amount from Form 3800, Part  
III, line 6, column (i).  
Tax on Undistributed Long-Term Capital Gain by  
RIC or Reit  
Estimated Tax Payments  
Line 6h. Enter the elective payment election amount from Form  
Line 6b. Enter the total estimated tax payments made for the  
3800. See the Instruction for Form 3800.  
tax year.  
Enter the amount of tax paid by a regulated investment  
company (RIC) or real estate investment trust (REIT) on  
undistributed long-term capital gains. Attach each Form 2439  
you received from each RIC or REIT of which you are a  
shareholder. If you are filing a composite Form 990-T, see  
Composite Form 990-T under Which Parts To Complete, earlier.  
If an organization is the beneficiary of a trust, and the trust  
makes a section 643(g) election to credit its estimated tax  
payments to its beneficiaries, include the organization's share of  
the estimated tax payments in the total amount entered here.  
Attach a statement showing the amount of the section 643(g)  
credit amount.  
Credit for Federal Excise Tax Paid on Fuels  
Foreign Organizations  
Line 6i. If you paid a federal excise tax on certain fuels and  
qualify for any of the credits listed below, attach Form 4136 to  
your return and enter the total credit on line 6i.  
Line 6d. Enter the tax withheld on UBTI from U.S. sources that  
isn't effectively connected with the conduct of a trade or  
business within the United States. Attach Form 1042-S, Foreign  
Person's U.S. Source Income Subject to Withholding, or another  
form which verifies the withheld tax reported on Part III, line 6d.  
The biodiesel or renewable diesel mixture credit  
The alternative fuel credit.  
A credit for certain nontaxable uses (or sales) of fuel during  
Backup Withholding  
your income tax year.  
A credit for blending a diesel-water fuels emulsion.  
A credit for exporting dyed fuels or gasoline blendstocks.  
Substainable aviation fuel (SAF) credit.  
Line 6e. Recipients of dividend or interest payments must  
generally certify their correct tax identification number to the  
bank or other payer on Form W-9. If the payer doesn’t get this  
information, it must withhold part of the payments as “backup  
withholding.If your organization was subject to erroneous  
backup withholding because the payer didn’t realize you were an  
exempt organization and not subject to this withholding, you can  
claim credit for the amount withheld by including it on Part III,  
See the instructions for Form 4136 for more information about  
these credits.  
Note: Form 8849, Claim for Refund of Excise Taxes, may be  
used to claim a periodic refund of excises taxes instead of  
12  
Instructions for Form 990-T  
           
waiting to claim a credit on Form 4136. See the Instructions for  
Form 8849 and Pub. 510, Excise Taxes.  
If the “Yes” box is checked, write the name of the foreign  
country or countries. If the list of foreign country names will not fit  
in the available space, continue the list in Part V, Supplemental  
Information.  
Other Credits  
Get FinCEN Form 114, Report of Foreign Bank and Financial  
Accounts (FBAR), to see if the organization is considered to  
have an interest in or signature or other authority over a financial  
account in a foreign country (such as a bank account, securities  
account, or other financial account). If the organization is  
required to file this form, file FinCEN Form 114 electronically with  
the Department of the Treasury using FinCEN's BSA E-Filing  
System. Because FinCEN Form 114 isn't a tax form, don't file it  
with Form 990-T.  
Line 6j. For other credits, check the “Other ” box and provide  
the following information:  
The number of the form used to calculate the credit, or the  
code section that establishes the credit,  
A brief description of the credit, and  
The amount of the credit.  
If necessary, provide information required to claim a specific  
credit in Part V, Supplemental Information.  
Other credits may include the following:  
See FinCEN for more information.  
The credit for ozone-deleting chemicals. Include any credit the  
Line 2. The organization may be required to file Form 3520,  
Annual Return To Report Transactions With Foreign Trusts and  
Receipt of Certain Foreign Gifts, if either of the following applies.  
organization is claiming under section 4682(g) for taxes paid on  
chemicals under as propellants in metered-dose inhalers.  
The amount of current year net section 965 tax liability, For a  
It directly or indirectly transferred money or property to a  
trust, this amount will be from Form 956-A, Part I, column (d),  
line 4.  
foreign trust. For this purpose, any U.S. person who created a  
foreign trust is considered a transferor.  
Note: Do not use Part III, line 6j, to claim a refund of federal tax  
withheld and shown on Form 1099, Claims for refund of backup  
withholding should be shown on Part III, line 6e.  
It is treated as the owner of any part of the assets of a foreign  
trust under the grantor trust rules.  
See the Instructions for Form 3520.  
An owner of a foreign trust must ensure that the trust  
Estimated Tax Penalty  
files an annual information return on Form 3520-A,  
!
Line 8. Use Form 2220, Underpayment of Estimated Tax by  
Corporations, to see if the organization owes a penalty and its  
amount. Generally, the organization isn't required to file this form  
because the IRS can figure the amount of any penalty and notify  
the organization. However, even if the organization doesn’t owe  
the penalty, you must complete and attach Form 2220 if either of  
the following applies.  
CAUTION  
Annual Information Return of Foreign Trust With a U.S.  
Owner. For details, see the Instructions for Form 3520-A.  
Line 3. Report any tax-exempt interest received or accrued in  
the space provided. Include any exempt-interest dividends  
received as a shareholder in a mutual fund or other RIC.  
Line 4. Use line 4 to show the amount of the NOL carryover to  
the tax year from tax years prior to 2018 (“pre-2018 NOL), even  
if some of the loss is used to offset income on this return. The  
amount to enter is the total of all pre-2018 NOLs generated in  
any year prior to 2018, and not used to offset income (either as a  
carryback or carryover) to a tax year prior to 2023. Do not reduce  
the amount by any NOL deduction reported on Part I, line 6.  
The annualized income or adjusted seasonal installment  
method is used.  
The organization is a “large organization” computing its first  
required installment based on the prior year's tax.  
If you attach Form 2220, check the box on Form 990-T, Part  
III, line 8, and enter the amount of any penalty on this line.  
Line 5. Use the table in line 5 to show the amount of each NOL  
carryover from tax years after 2017 that is attributable to each  
separate trade or business conducted at any time after 2017  
(“siloed post-2017 NOL) to the tax year. Include the NOL for  
each separate trade or business conducted after 2017, even if a  
Schedule A for any one or more specific trades or businesses  
isn’t included with this return for this tax year. Report the full  
amount of the available NOL for each separate trade or  
business, even if some of the loss is used.  
Tax Due  
Line 9. You must pay the tax in full when the return is filed. You  
may pay by EFTPS. For more information about EFTPS, see  
Electronic Deposit Requirement, earlier. Also, you may pay by  
credit or debit card.  
To pay by credit or debit card. For information on paying  
your taxes electronically, including by credit or debit card, go to  
In the first column under line 5, identify the business activity  
code to which each NOL relates. In the second column, enter the  
total amount of each siloed post-2017 NOL generated in any  
prior year after 2017 and not used to offset income (either as a  
carryback or carryover) to a tax year prior to 2023 to offset  
income reported on a Schedule A filed for that separate trade or  
business on this return. Don’t reduce the amount by any NOL  
deduction reported on Schedule A, Part II, line 17. See Separate  
Trades or Businesses, later, for information about changing the  
business activity code associated with a particular trade or  
business, and the effect of such a change on NOLs.  
Part IV. Statements Regarding Certain  
Activities and Other Information  
Complete all lines in Part IV.  
Line 1. Check “Yes” if either item (1) or (2) below applies.  
1. At any time during the year the organization had an  
interest in or signature or other authority over a financial account  
in a foreign country (such as a bank account, securities account,  
or other financial account); and  
a. The combined value of the accounts was more than  
Part V. Supplemental Information  
$10,000 at any time during the year; and  
Use Part V to provide the IRS with narrative information required  
for responses to specific questions on Form 990-T, and to  
explain the organization’s operations or responses to various  
questions.  
b. The accounts were not with a U.S. military banking facility  
operated by a U.S. financial institution.  
2. The organization owns more than 50% of the stock in any  
corporation that would answer “Yes” to item (1).  
13  
Instructions for Form 990-T  
         
The authorization can’t be revoked. However, the  
authorization will automatically end no later than the due date  
(excluding extensions) for filing next year's Form 990-T.  
Signature  
Corporations. The return must be signed and dated by the  
president, vice president, treasurer, assistant treasurer, or chief  
accounting officer, or by any other corporate officer (such as a  
tax officer) authorized to sign. Receivers, trustees, or assignees  
must also sign and date any return filed on behalf of the  
organization.  
Enter the paid preparer’s Preparer Tax Identification  
Number (PTIN), not their SSN, in the “PTIN” box in the  
!
CAUTION  
paid preparer’s block. Because Form 990-T is publicly  
disclosable when filed by a 501(c)(3) organization, any  
information entered in this block will be publicly disclosed. For  
more information about PTINs, go to IRS.gov/Taxpros.  
Trusts. The return must be signed and dated by the individual  
fiduciary, or by the authorized officer of the trust receiving or  
having custody or control and management of the income of the  
trust. If two or more individuals act jointly as fiduciaries, any one  
of them may sign.  
Special rule for IRA trusts. A trustee of IRA trusts may use  
a facsimile signature if all of the following conditions are met.  
General Instructions — Schedule A  
(Form 990-T)  
Purpose of the Schedule  
Each group of returns sent to the IRS must be accompanied  
by a letter signed by the person authorized to sign the returns  
declaring, under penalties of perjury, that the facsimile signature  
appearing on the returns is the signature adopted by that person  
to sign the returns filed and that the signature was affixed to the  
returns by that person or at that person's direction.  
Complete a separate Schedule A to report income and allowable  
deductions for each separate unrelated trade or business.  
Separate Trades or Businesses  
The letter must also list each return by the name and EIN of  
An exempt organization may engage in more than one unrelated  
trade or business. Prior to the enactment of section 512(a)(6), an  
exempt organization deriving gross income from the regular  
conduct of two or more unrelated trades or businesses  
calculated UBTI by determining its aggregate gross income from  
all such unrelated trades or businesses and reducing that  
amount by the aggregate deductions allowed with respect to all  
such unrelated trades or businesses. However, section 512(a)(6)  
changed this calculation for exempt organizations with more than  
one unrelated trade or businesses so that, in the case of any  
exempt organization with more than one unrelated trade or  
business:  
the IRA trust.  
After the facsimile signature is affixed, no entries on the return  
may be altered other than to correct discernible arithmetic errors.  
A manually signed copy (of the letter submitted to the IRS with  
the returns and a record of any arithmetic errors corrected) must  
be retained on behalf of the IRA trusts listed in the letter and it  
must be available for inspection by the IRS.  
Paid preparer. If an officer of the organization filled in its return,  
the paid preparer's space should remain blank. Anyone who  
prepares the return but doesn’t charge the organization should  
not sign the return. Certain others who prepare the return should  
not sign. For example, a regular, full-time employee of the  
organization, such as a clerk, secretary, etc., should not sign.  
UBTI, including for purposes of determining any NOL  
deduction, shall be computed separately with respect to each  
trade or business and without regard to section 512(b)(12)  
(allowing a specific deduction of $1,000);  
Generally, anyone who is paid to prepare the organization's  
tax return must sign it and fill in the Paid Preparer Use Only area.  
The UBTI of such exempt organization shall be the sum of the  
The paid preparer must complete the required preparer  
UBTI so computed with respect to each trade or business, less a  
specific deduction under section 512(b)(12); and  
information and do the following.  
Sign the return in the space provided for the preparer's  
For purposes of section 512(a)(6)(B), UBTI with respect to  
signature.  
any such trade or business shall not be less than zero.  
Give a copy of the return to the organization.  
Thus, under section 512(a)(6), an exempt organization may  
not aggregate income and deductions from all unrelated trades  
or businesses when calculating UBTI.  
Note. A paid preparer may sign original returns, amended  
returns, or requests for filing extensions by rubber stamp,  
mechanical device, or computer software program. Also,  
facsimile signatures are authorized.  
An organization determines whether it regularly carries on  
one or more unrelated trades or businesses by applying sections  
511 through 514. Identify each separate trade or business using  
the first two digits of the NAICS two-digit code that most  
accurately describes the unrelated trade or business based on  
the more specific NAICS code, such as at the six-digit level.  
Identify activities in the nature of investments, which aren’t  
described in NAICS, using the appropriate business activity  
code described under Non-NAICS Business Activity Codes,  
later.  
Paid preparer authorization. If the organization wants to allow  
the IRS to discuss this tax return with the paid preparer who  
signed it, check the “Yes” box in the signature area of the return.  
This authorization applies only to the individual whose signature  
appears in the Paid Preparer Use Only section of its return. It  
doesn’t apply to the firm, if any, shown in that section.  
If the “Yes” box is checked, the organization is authorizing the  
IRS to call the paid preparer to:  
Give the IRS any information that is missing from its return;  
Call the IRS for information about the processing of its return  
or the status of its refund or payment(s); and  
An organization will use each NAICS two-digit code only  
once. For example, a hospital organization that operates several  
hospital facilities that include pharmacies that sell goods to the  
general public would include all the pharmacies under the  
NAICS two-digit code for retail trade, regardless of whether the  
hospital organization keeps separate books and records for each  
pharmacy.  
Respond to certain IRS notices that the organization has  
shared with the preparer about a math error, offsets, and return  
preparation. The notices won't be sent to the preparer.  
The organization isn't authorizing the paid preparer to receive  
any refund check, bind the organization to anything (including  
any additional tax liability), or otherwise represent the  
organization before the IRS. If the organization wants to expand  
the paid preparer's authorization, see Pub. 947, Practice Before  
the IRS and Power of Attorney.  
Once a two-digit NAICS code or business activity code is  
used for an unrelated trade or business, you should continue to  
use that same code in subsequent tax years. If it is necessary to  
14  
Instructions for Form 990-T  
       
change the two-digit NAICS code or business activity code  
previously used for an unrelated trade or business, you must  
report the change in a statement attached to the Schedule A on  
which the activities are reported. The statement should include  
(1) the two-digit NAICS code or business activity code used in  
the previous tax year; (2) the two-digit NAICS code or business  
activity code used this year and, if filing more than one  
Schedule A, the sequence numbers from item D of the  
applicable Schedule A; and (3) a narrative explanation  
describing the reason for the change.  
Schedule A that apply to the unrelated trade or business  
reported on that Schedule A.  
Is gross income $10,000 or less? If the sum of the amounts in  
all Schedules A (Form 990-T), Part I, line 13, column (A), is  
$10,000 or less, complete Schedule A (Form 990-T) and Form  
990-T as follows.  
Schedule A (Form 990-T)  
Complete the heading on each Schedule A.  
See Regulations section 1.512(a)-6(h)(4) regarding the  
potential effects on NOL carryforwards upon a change of  
Part I. Complete only the lines that apply.  
!
CAUTION  
the two-digit NAICS code for an unrelated trade or  
1. Enter information directly in column (A) on lines 1, 3  
business.  
through 5, 12, and 13.  
2. Entries for lines 2, and 6 through 11, must be made on the  
Part referenced in the text for the line in Part I. For example, enter  
the amount for Part I, line 2, on Part III, line 8. For Part I, line 6,  
columns (A) and (B), enter the amounts on Part IV, line 3 and  
line 5, respectively.  
Regulations section 1.512(a)-6(c)(9) describes a  
transition rule for certain partnership interests. The  
!
CAUTION  
transition period ended on the first day of the first tax  
year beginning after December 2, 2020.  
3. Make entries as necessary to complete the applicable  
Dual-Use Property  
lines in column (C).  
Section 512(a)(1) permits an exempt organization with an  
unrelated trade or business to reduce the income from that trade  
or business by the deductions allowed by Chapter 1 that are  
directly connected with the carrying on of such trade or  
business. To be “directly connected” with a trade or business, an  
item of deduction must have a proximate and primary  
Part II. Complete lines 15–18, and if necessary, the attachment  
to line 17 (NOL deduction).  
Form 990-T  
1. Complete all applicable lines in the heading area.  
relationship to the carrying on of the unrelated trade or business  
generating the gross income. See Regulations section  
1.512(a)-1(a). Expenses, depreciation, and similar items  
attributable solely to the conduct of an unrelated trade or  
business are proximately and primarily related to that trade or  
business and qualify to reduce income from such trade or  
business under section 512(a)(1) to the extent such items meet  
the requirements of section 162 (trade or business expenses),  
section 167 (depreciation), and other relevant provisions. To the  
extent that an exempt organization may have items of deduction  
that are shared between an exempt activity and an unrelated  
trade or business, Regulations section 1.512(a)-1(c) provides  
special rules for allocating such expenses. For example, if  
facilities are used both to carry on exempt activities and to  
conduct unrelated trade or business activities, then expenses,  
depreciation, and similar items attributable to such facilities must  
be allocated between the two uses on a reasonable basis. See  
Regulations section 1.512(a)-1(c). The allocation issues under  
section 512(a)(1) are also relevant under section 512(a)(6)  
because an exempt organization with more than one unrelated  
trade or business must not only allocate indirect expenses  
among exempt and taxable activities, as described in  
2. Complete all applicable lines as needed to determine the  
appropriate tax, applicable credits, and balance due or refund  
amount.  
3. Complete the signature area.  
If an entry for a line on Part I or Part II must be made on a  
different Part of Schedule A, complete only the lines in  
!
CAUTION  
the Part that reference a specific line on Part I or Part II.  
Leave all other lines in the applicable Part blank.  
Filers with gross income of $10,000 or less, as described  
above, don't have to complete Schedule A, Parts III though X  
(except as described above because certain entries must be  
made in those sections to populate lines in Parts I and II).  
However, refer to the applicable Parts of Schedule A when  
completing Schedule A, Part I, column (A), and in determining  
the deductible expenses to include on Schedule A, Part I,  
line 13, column (B).  
Exceptions and Special Rules  
Regulations section 1.512(a)-1(c) but also among separate  
unrelated trades or businesses.  
Member income of mutual or cooperative electric compa-  
nies. Income of a mutual or cooperative electric company  
described in section 501(c)(12), which is treated as member  
income under subparagraph (H) of that section, is excluded from  
UBTI.  
The allocation of expenses, depreciation, and similar items  
using an unadjusted gross-to-gross method is not reasonable if  
the cost of providing the good or service is substantially the  
same but the price charged differs between related and  
unrelated activities.  
Income from qualifying shipping activities. The  
organization's gross income doesn’t include income from  
qualifying shipping activities (as defined in section 1356) if the  
organization makes an election under section 1354 on a timely  
filed return (including extensions) to be taxed on its notional  
shipping income (as defined in section 1353) at the highest  
corporate rate. If the election is made, the organization generally  
may not claim any loss, deduction, or credit with respect to  
qualifying shipping activities. An organization making this  
election may also elect to defer gain on the disposition of a  
qualifying vessel under section 1359. Use Form 8902 to figure  
the tax. Include the alternative tax on Form 990-T, Part III, line 3e.  
Which Parts To Complete  
Complete a separate Schedule A, Parts I and II, for each  
unrelated trade or business. Complete only the lines relevant to  
the unrelated trade or business being reported on that  
Schedule A.  
Is gross income more than $10,000? If the sum of the  
amounts in all Schedules A (Form 990-T), Part I, line 13, column  
(A), is more than $10,000, you must complete all Parts of each  
15  
Instructions for Form 990-T  
 
How to report income received from a payment  
card and third-party network transaction. An  
organization that receives a Form 1099-K reporting a  
Passive loss and at-risk limitations. Under section 469,  
certain taxpayers, including certain tax-exempt organizations,  
may not deduct a passive activity loss (PAL). Such tax-exempt  
organizations (“affected tax-exempt organizations”) include a  
trust (such as a trust described in section 501(c), a trust  
described in section 401(a), or an IRA), and a corporation if at  
any time during the last half of its tax year more than 50% in  
value of the outstanding stock of the corporation is owned,  
directly or indirectly, by or for not more than five organizations  
that are private foundations under section 509(a) or are  
described in section 401(a) or 501(c)(17) (for example, a stock  
corporation described in section 501(c)(2) with a 401(a) parent  
or private foundation parent).  
A PAL occurs when total losses (including prior-year  
unallowed losses) from all the organization’s passive activities  
exceed the total income from all its passive activities. Generally,  
passive activities include (1) trade or business activities in which  
the organization didn’t materially participate for the tax year; and  
(2) rental activities, regardless of your participation. If the  
organization has income or loss from a passive activity, several  
lines on Form 990-T and Schedule A (Form 990-T) may be  
affected by these rules.  
!
CAUTION  
“gross amount” received from payment card and third-party  
network transactions in the tax year should report these amounts  
in the same manner as if the payments weren’t reported on a  
Form 1099-K. There isn’t any one specific line on which to report  
an amount from Form 1099-K; the correct line should be  
determined based on the nature of the payments. Some  
payments received may constitute unrelated business income;  
see the instructions below to determine the appropriate line. For  
instance, if some of the payments are sales income from an  
unrelated business, then those payments would be reported on  
Part I, line 1a. Retain Form 1099-K with your other records.  
Specific Instructions—Schedule A  
(Form 990-T)  
Items A Through E  
Item A. Enter the same name as entered in the heading area of  
Form 990-T.  
PALs can’t be used to offset income from nonpassive  
activities. Passive activity income doesn’t include portfolio  
income. Portfolio income (see Temporary Regulations section  
1.469-2T(c)(3)) is income from a nonpassive activity. Portfolio  
income includes all gross income, other than income derived in  
the ordinary course of a trade or business, that is attributable to  
interest, dividends, annuities, and royalties (by contrast, a bank's  
receipt of interest is in the ordinary course of a trade or business,  
as is a securities dealer's receipt of dividends). Portfolio income  
also includes gain or loss from the disposition of property that  
produces portfolio income or is held for investment (see section  
163(d)(5)). The rule treating portfolio income as not from a  
passive activity doesn’t apply to the extent that income, of a type  
generally regarded as portfolio income, is derived in the ordinary  
course of a trade or business. For example, the business income  
of a bank typically is largely interest. Similarly, a securities  
broker/dealer may earn a substantial portion of the income from  
the business in the form of dividends and gains on sales of  
dividend-bearing instruments. Interest income may also arise in  
the ordinary course of a trade or business with respect to  
installment sales and interest charges on accounts receivable.  
This means that portfolio income may not be reduced by PALs or  
passive activity credits. For example, any portfolio income  
earned by a trust described in section 501(a) that is UBTI (such  
as unrelated debt-financed income) may not be offset by PALs  
from an unrelated trade or business.  
Section 469(k) provides that the passive activity limitations  
must be applied separately to items from each publicly traded  
partnership (PTP). A PTP is a partnership whose interests are  
traded on an established securities market or are readily  
tradable on a secondary market (or its substantial equivalent).  
PALs from a PTP may generally be used only to offset income or  
gain from passive activities of the same PTP. This means that a  
partner in a PTP may not use PALs and passive activity credits  
from a PTP to offset income from other sources, including  
passive activity income from another PTP. Such PALs and  
passive activity credits aren't allowed for the tax year.  
Item B. Enter the same EIN as entered in item D of Form 990-T.  
Item C. On each Schedule A, enter the business activity code  
that best describes the organization's unrelated trade or  
business reported on that Schedule A. Modernized e-File  
requires a 6-digit numerical entry for item C. Unless you are  
using a 6-digit non-NAICS business activity code, you should  
enter the 2 digits of the NAICS code in the first two positions and  
then enter 4 zeros to complete the entry. For example, if the  
2-digit business activity code 45 (for retail trade) best describes  
your unrelated trade or business, enter “450000” in item C. See  
Business Activity Codes, later, for more information about  
business activity codes.  
Part I. Unrelated Trade or Business  
Income  
Gross Receipts or Sales  
Line 1a. Enter the gross receipts from an unrelated trade or  
business regularly conducted that involves the sale of goods or  
performance of services.  
A section 501(c)(7) social club would report its  
restaurant and bar receipts from nonmembers on  
TIP  
Schedule A, Part I, line 1, but would report its investment  
income on Schedule A, Part I, line 9, and on Schedule A, Part  
VII.  
Advance payments. In general, advance payments are  
reported in the year of receipt. To report income from long-term  
contracts, see section 460. For rules that allow a limited deferral  
of advance payments beyond the current tax year, see section  
451(c). Also, see Regulations sections 1.451-8(c), (d), and (e).  
For applicability dates, see Regulations section 1.451-8(h). For  
information on adopting or changing to a permissible method for  
reporting advance payments for services and certain goods by  
an accrual method corporation, see the Instructions for Form  
3115. Also, see Rev. Proc. 2021-34.  
Generally, PALs are subject to other limitations (for example,  
basis and at-risk limitations) before they are subject to the PAL  
limitations. For example, the at-risk rules under section 465  
generally prohibit trusts and corporations that are affected  
tax-exempt organizations from claiming losses from activities in  
excess of the taxpayer’s amount at risk in the activity.  
An affected tax-exempt organization may need to attach Form  
6198 and either Form 8582 or Form 8810. For more information  
on these rules, see Pub. 925, Passive Activity and At-Risk Rules.  
Installment sales. Generally, the installment method cannot be  
used for dealer dispositions of property. A dealer disposition” is  
(a) any disposition of personal property by a person who  
regularly sells or otherwise disposes of personal property of the  
same type on the installment plan, or (b) any disposition of real  
property held for sale to customers in the ordinary course of the  
taxpayer's trade or business.  
16  
Instructions for Form 990-T  
     
These restrictions on using the installment method don't  
apply to dispositions of property used or produced in a farming  
business or sales of time-shares and residential lots for which  
the organization elects to pay interest under section 453(l)(3).  
For sales of time-shares and residential lots reported under  
the installment method, the organization's income tax is  
increased by the interest payable under section 453(l)(3).  
An organization that transfers securities it owns for the  
contractual obligation of the borrower to return identical  
securities recognizes no gain or loss on that exchange or on the  
subsequent receipt of identical securities in satisfaction of the  
contractual obligation. To qualify for this treatment, the  
organization must lend the securities under an agreement that  
requires:  
1. The return of identical securities;  
Enter on Schedule A, Part I, line 1a and line 3, the gross profit  
on collections from installment sales for any of the following.  
2. The payment of amounts equivalent to the interest,  
dividends, and other distributions that the owner of the securities  
would normally receive; and  
Dealer dispositions of property before March 1, 1986.  
Dispositions of property used or produced in the trade or  
business of farming.  
3. The risk of loss or opportunity for gain not be lessened.  
Certain dispositions of time-shares and residential lots  
See sections 512(a)(5) and 1058(b) for details.  
reported under the installment method.  
Attach Form 6252 to show information about each installment  
Debt-financed property disposition. The amount of gain or  
loss to be reported on the sale, exchange, or other disposition of  
debt-financed property is the same percentage as the highest  
acquisition indebtedness for the property for the 12-month  
period before the date of disposition is to the average adjusted  
basis of the property. The percentage may not be more than  
100%. See the instructions for Schedule A, Part V, line 5, to  
determine adjusted basis and average adjusted basis.  
sale.  
Nonaccrual experience method. Accrual method  
organizations aren't required to accrue certain amounts to be  
received from the performance of services that, on the basis of  
their experience, won't be collected, if:  
The services are in the field of health, law, engineering,  
architecture, accounting, actuarial science, performing arts, or  
consulting; or  
If debt-financed property is depreciable or depletable  
property, the provisions of sections 1245, 1250, 1252, 1254, and  
1255 must be considered first.  
The organization's average annual gross receipts for the 3  
prior tax years doesn’t exceed $29 million.  
Example. On January 1, 2022, an exempt educational  
corporation, using $288,000 of borrowed funds, purchased an  
office building for $608,000. The only adjustment to basis was  
$29,902 for depreciation (straight line method under MACRS  
over the 39-year recovery period for nonresidential real  
property). The corporation (section 501(c)(3) organization) sold  
the building on December 31, 2023, for $640,000. At the date of  
sale, the adjusted basis of the building was $578,098 ($608,000  
− $29,902) and the indebtedness remained at $288,000. The  
adjusted basis of the property on the first day of the year of  
disposition was $593,037. The average adjusted basis is  
$585,568 (($593,037 + $578,098) ÷ 2). The debt/basis  
percentage is 49% ($288,000 ÷ $585,568).  
The taxable gain is $30,332 (49% × ($640,000 − $578,098)).  
This is a long-term capital gain. A corporation should enter the  
gain on Schedule D (Form 1120), Part II, line 8. A trust should  
enter the gain on Schedule D (Form 1041), Part II, line 8, if  
applicable. In either scenario (a corporation or a trust), the  
educational organization must attach a statement to Form 990-T,  
in addition to the Schedule D, showing how the gain was figured  
along the lines described in this example, if the details weren’t  
provided with the Schedule D.  
This provision doesn’t apply to any amount if interest is  
required to be paid on the amount or if there is any penalty for  
failure to timely pay the amount. See Regulations section  
1.448-3. Organizations that qualify to use the nonaccrual  
experience method should attach a statement showing total  
gross receipts, amounts not accrued as a result of the  
application of section 448(d)(5), and the net amount accrued.  
Enter the net amount on Schedule A, Part I, line 1a.  
Gain or loss on disposition of certain brownfield property.  
Gain or loss from the qualifying sale, exchange, or other  
disposition of a qualifying brownfield property (as defined in  
section 512(b)(19)(C)), which was acquired by the organization  
after 2004, is excluded from unrelated business taxable income  
and is excepted from the debt-financed rules for such property.  
See sections 512(b)(19) and 514(b)(1)(E).  
Capital Gain Net Income  
Line 4a. Generally, organizations required to file Form 990-T  
(except organizations described in sections 501(c)(7), (9), and  
(17)) aren't taxed on the net gains from the sale, exchange, or  
other disposition of property. However, net capital gains on  
debt-financed property, capital gains on cutting timber, and  
ordinary gains on sections 1245, 1250, 1252, 1254, and 1255  
property are taxed. See Form 4797, Sales of Business Property,  
and its instructions for additional information.  
Also, any capital gain or loss passed through from an S  
corporation or any gain or loss on the disposition of S  
corporation stock by a qualified tax-exempt organization (see S  
Corporations, later) is taxed as a capital gain or loss and  
reported on Part I, line 4.  
Capital gains and losses should be reported by a trust on  
Schedule D (Form 1041), Capital Gains and Losses, and by a  
corporation on Schedule D (Form 1120), Capital Gains and  
Losses (and Form 8949, Sale and Other Dispositions of Capital  
Assets). Schedule D of Form 1041 or Form 1120 (and Form  
8949, if applicable) must be attached to Form 990-T.  
If you deferred a capital gain into a QOF, you must attach  
Schedule D, Form 8949, and Form 8997 to your Form 990-T. You  
will need to annually file Form 8997 until you dispose of the  
investment. See the Instructions for Form 8997.  
Disposition of property received from taxable subsidiary  
and used in unrelated business. A taxable 80%-owned  
subsidiary corporation of one or more tax-exempt entities is  
generally subject to tax on a distribution in liquidation of its  
assets to its exempt parent (or parents). See section 337. The  
assets are treated as if sold at FMV.  
Tax-exempt entities” for this purpose include organizations  
described in sections 501(a), 529, 529A, and 115; charitable  
remainder annuity trusts or unitrusts; U.S. (including states) and  
foreign governments; Indian tribal governments and certain  
corporations; international organizations; and similar non-taxable  
organizations.  
A taxable corporation that transfers substantially all of its  
assets to a tax-exempt entity in a transaction that otherwise  
qualifies for nonrecognition treatment must recognize gain on the  
transaction as if it sold the assets at FMV. However, such a  
transfer isn't taxable if it qualifies as a like-kind exchange under  
section 1031 or an involuntary conversion under section 1033. In  
such a case, the built-in appreciation is preserved in the  
replacement property received in the transaction. A “taxable  
17  
Instructions for Form 990-T  
         
corporation” is any corporation that isn't a tax-exempt entity as  
defined above, including an S corporation.  
or business, and its share of the partnership deductions directly  
connected with the unrelated gross income.  
A corporation that changes status from taxable to tax-exempt  
is generally treated as if it transferred all of its assets to a  
tax-exempt entity immediately before the change in status (thus  
subjecting it to the tax on a deemed sale for FMV). This rule  
doesn’t apply where the taxable corporation becomes exempt  
within 3 years of formation (within 7 years of formation for section  
501(c)(7) organizations), or had previously been exempt and  
within several years (generally a period of 3 years) regains  
exemption, unless the principal purpose of the transactions is to  
avoid the tax on the change in status.  
In the transactions described above, the taxable event is  
deferred for property that the tax-exempt entity immediately uses  
in an unrelated business. If the tax-exempt parent later disposes  
of the property, then any gain (not in excess of the amount not  
recognized) is included in the parent’s UBTI. If there is partial  
use of the assets in unrelated business, then there is partial  
recognition of gain or loss with respect to the assets not so used.  
Property is treated as disposed if the tax-exempt entity no longer  
uses it in an unrelated business.  
S Corporations  
Qualified tax-exempt organizations can be shareholders in an S  
corporation without the S corporation losing its status as an S  
corporation. Qualified tax-exempt organizations that hold stock  
in an S corporation treat their stock interest as an interest in an  
unrelated trade or business. All items of income, loss, or  
deduction that the organization receives as a shareholder of the  
S corporation are taken into account in Schedule A, Part I, line 5,  
in figuring UBTI and not reported on another line of Schedule A  
(Form 990-T) that otherwise would apply, except capital gains  
and losses, which are reported on Schedule A, Part I, line 4.  
Report on Schedule A, Part I, line 4, any gain or loss on the  
disposition of S corporation stock.  
Qualified tax-exempts. A qualified tax-exempt is an  
organization that is described in section 401(a) (qualified stock  
bonus, pension, and profit-sharing plans) or 501(c)(3) and  
exempt from tax under section 501(a).  
Exception. Employee stock ownership plans (ESOPs) don't  
follow these S corporation rules if the S corporation stock is an  
employer security, as defined in section 409(l).  
Attach a statement to this return showing the qualified  
tax-exempt's share of all items of income, loss, or deduction.  
Combine the income, loss, and deductions (except for the capital  
gains and losses) on the statement. If you hold stock in more  
than one S corporation, total the combined amounts. Show  
capital gains and losses separately and include them on  
Schedule A, Part I, line 4a.  
Losses on the transfer of assets to a tax-exempt entity are  
disallowed if part of a plan having a principal purpose of  
recognizing losses.  
Net Gain or (Loss)  
Line 4b. Show gains and losses on other than capital assets on  
Form 4797. Enter on this line the net gain or (loss) from Form  
4797, Part II, line 17.  
An exempt organization using Form 4797 to report ordinary  
gain on sections 1245, 1250, 1252, 1254, and 1255 property will  
include only depreciation, amortization, or depletion allowed or  
allowable in figuring UBTI or taxable income of the organization  
(or a predecessor organization) for a period when it was not  
exempt.  
Rent Income  
Line 6. Enter the amount computed on Part IV, line 3, on Part I,  
line 6, column (A). Enter the amount computed on Part IV, line 5,  
on Part I, line 6, column (B).  
Capital Loss Deduction for Trusts  
Line 4c. If a trust has a net capital loss, it is subject to the  
limitations of Schedule D (Form 1041). Enter on this line the loss  
figured on Schedule D (Form 1041).  
Unrelated Debt-Financed Income  
Line 7. Enter the amount computed on Part V, line 8, on Part I,  
line 7, column (A). Enter the amount computed on Part V, line 10,  
on Part I, line 7, column (B).  
Income or (Loss) From a Partnership or an S  
Corporation  
Line 5. See Regulations section 1.512(a)-6 for rules permitting  
the aggregation of income (and directly connected deductions)  
of certain partnership interests.  
Interest, Annuities, Royalties, and Rents From a  
Controlled Organization  
Line 8. Enter the sum of columns 5 and 10 from Part VI on Part  
I, line 8, column (A). Enter the sum of columns 6 and 11 from  
Part VI on Part I, line 8, column (B).  
Also, for trusts and certain corporations, there are limitations  
on income and losses (including from a partnership or an S  
corporation) under section 469 (the PAL and credit limitation  
rules) and section 465 (at-risk limitations). For more information  
on these rules, see the discussion of the application of the  
passive activity loss and at-risk limitations to affected tax-exempt  
organizations in the introductory instructions under Part I.  
Unrelated Trade or Business Income, earlier.  
Investment Income of a Section 501(c)(7), (9), or  
(17) Organization  
Line 9. Enter the sum of amounts from Part VII, column 2, on  
Part I, line 9, column (A). Enter the sum of amounts in Part VII,  
column 5, on Part I, line 9, column (B).  
Exploited Exempt Activity Income, Other Than  
Advertising Income  
Line 10. Enter the amount computed on Part VIII, line 2, on Part  
I, line 10, column (A). Enter the amount computed on Part VIII,  
line 3, on Part I, line 10, column (B).  
Partnerships  
If the organization is a partner in a partnership conducting an  
unrelated trade or business, enter the organization's share  
(whether or not distributed) of the partnership's income or loss  
from the unrelated trade or business. The organization is  
required to notify the partnership of its tax-exempt status. Figure  
the gross income and deductions of the partnership in the same  
way you figure unrelated trade or business income the  
organization earns directly.  
Advertising Income  
Line 11. Enter the amount computed on Part IX, line 2, on Part I,  
line 11, column (A). Enter the amount computed on Part IX,  
line 3, on Part I, line 11, column (B).  
Attach a statement to this return showing the organization's  
share of the partnership's gross income from the unrelated trade  
18  
Instructions for Form 990-T  
         
organization may have current income under section 1293 if the  
PFIC is a QEF with respect to the organization. The organization  
may also have current income under section 1296 if it makes a  
section 1296 mark-to-market election with respect to the PFIC  
stock.  
Include on Schedule A, Part I, line 12, the portion of an  
excess distribution (or gain treated as an excess distribution),  
section 1293 inclusion, or section 1296 inclusion that is taxable  
as UBTI. See Form 8621.  
See the instructions for Form 990-T, Part II, line 4, for  
reporting the deferred tax amount that may be owed by the  
organization with respect to an excess distribution (or gain  
treated as an excess distribution).  
Other Income  
Line 12. Enter on Part I, line 12, any item of unrelated business  
income from a particular trade or business that isn't reportable  
elsewhere on the return. Attach a statement describing the  
sources of the other income and their amounts. Such amounts  
may include:  
Recoveries of bad debts deducted in earlier years under the  
specific charge-off method;  
The amount from Form 6478, Biofuel Producer Credit (if  
applicable);  
The amount from Form 8864, Biodiesel, Renewable Diesel, or  
Sustainable Aviation Fuels Credit (if applicable); and  
Proceeds received from employer-owned life insurance  
contracts issued after August 17, 2006 (complete and attach  
Form 8925); and  
Line 13. Total Unrelated Trade or Business  
Income  
The amount of payroll tax credit taken by an employer on its  
2023 employment tax returns (Forms 941, 943, and 944) for  
qualified paid sick and qualified paid family leave under the  
FFCRA and the ARP (both the nonrefundable and refundable  
portions). These amounts must be included in gross income for  
the tax year that includes the last day of the calendar quarter  
with respect to which the credit is allowed.  
Use the amount from Schedule A, Part I, line 13, column (C), in  
the computation of UBTI in Part II.  
Part II. Deductions Not Taken  
Elsewhere  
If the aggregate sum of the amounts on all Schedules A (Form  
990-T), Part I, line 13, column (A), is $10,000 or less, you don't  
have to complete Schedule A, Part II, lines 1 through 14.  
However, you must complete the remainder of Schedule A, Part  
II and include the larger of each total from Schedule A, Part II,  
line 18, or zero, in the computation of the amount reported on  
Part I, line 1, of Form 990-T.  
Note. A credit is available only if the leave was taken sometime  
after March 31, 2020 and before October 1, 2021, and only after  
the qualified leave wages were paid, which might, under certain  
circumstances, not occur until a quarter after September 30,  
2021, including quarters during 2023.  
Organizations described in section 501(c)(19). Enter the  
net income from an insurance business that was not properly set  
aside. These organizations may set aside income from  
payments received for life, sickness, accident, or health  
insurance for members of the organization or their dependents.  
Note. Only expenses directly connected with the unrelated  
trade or business income reported on the Schedule A for that  
particular unrelated trade or business may be deducted on that  
Schedule A (see Directly connected expenses in Appendix A).  
Don't separately include in Schedule A, Part II, any expenses  
that are reported in Schedule A, Parts III through IX, other than  
excess exempt expenses entered on Schedule A, Part II, line 12,  
and excess readership costs entered on Schedule A, Part II,  
line 13. For example, officers' compensation allocable to  
advertising income is reported on Schedule A, Part IX, only and  
shouldn’t be included on Schedule A, Part X, or Schedule A, Part  
II, line 1.  
1. To provide for the payment of insurance benefits.  
2. For a purpose specified in section 170(c)(4) (religious,  
charitable, scientific, literary, educational, etc.).  
3. For administrative costs directly connected with benefits  
described in (1) and (2) above.  
Amounts set aside and used for purposes other than those in  
(1), (2), or (3) above must be included in UBTI for the tax year if  
they were previously excluded from taxable income.  
Any amount spent for a purpose described in section 170(c)  
(4) is first considered paid from funds earned by the organization  
from insurance activities if the income isn't used for the  
insurance activities.  
Limitations on Deductions  
The following items discuss certain areas in which the deduction  
may be limited.  
Expenditures for lobbying aren't considered section 170(c)(4)  
Activities Lacking a Profit Motive  
expenses.  
In some instances, it is necessary to report income whether or  
not it comes from a trade or business (including interest,  
annuities, royalties, and rents from controlled organizations, and  
income of a section 501(c)(7), (9), or (17) organization other than  
exempt function income). If income is attributable to an activity  
lacking a profit motive, then a net loss from the activity can’t be  
claimed on Form 990-T. Therefore, in Part I, column (B), and Part  
II, the total of deductions for expenses directly connected with  
income from an activity lacking a profit motive is limited to the  
amount of that income. Generally, an activity lacking a profit  
motive is one that isn't conducted for the purpose of producing a  
profit or one that has consistently produced losses when both  
direct and indirect expenses are taken into account.  
Income from property financed with qualified 501(c)(3)  
bonds. If any part of the property is used in a trade or business  
of any person other than a section 501(c)(3) organization or a  
governmental unit, and such use isn't consistent with the  
requirement for qualified 501(c)(3) bonds under section 145, the  
section 501(c)(3) organization is considered to have received  
unrelated business income in the amount of the greater of the  
actual rental income or the fair rental value of the property for the  
period it is used. No deduction is allowed for interest on the  
private activity bond. Report the greater of the actual rent or the  
fair rental value on Schedule A, Part I, line 12. Report allowable  
deductions on Schedule A, Part II. See sections 150(b)(3) and  
(c).  
PFIC shareholders. If the organization is a direct or indirect  
shareholder of a PFIC within the meaning of section 1297, it may  
have income tax consequences under section 1291 upon the  
disposition of the PFIC stock or on the receipt of an excess  
distribution from the PFIC, described in section 1291(a). The  
Deductions Related to Property Leased to  
Tax-Exempt Entities  
For property leased to a governmental or other tax-exempt entity,  
or in the case of property acquired after March 12, 2004, that is  
19  
Instructions for Form 990-T  
             
treated as tax-exempt-use property other than by reason of a  
lease, the organization may not claim deductions related to the  
property when they exceed the organization's income from the  
lease payments. Amounts disallowed may be carried over to the  
next year and treated as a deduction concerning the property.  
See section 470.  
Exceptions. Section 263A doesn’t apply to:  
Personal property acquired for resale if the organization's  
average annual gross receipts for the 3 prior tax years were $10  
million or less;  
Timber;  
Most property produced under long-term contract;  
Certain property produced in a farming business;  
Research and experimental costs under section 174;  
Geological and geophysical costs amortized under section  
Transactions Between Related Taxpayers  
167(h);  
Generally, an accrual basis taxpayer may deduct business  
expenses and interest owed to a related party only in the year  
the payment is included in the income of the related party. See  
sections 163(e)(3) and 267 for limitations on deductions for  
unpaid interest and expenses.  
Intangible drilling costs for oil, gas, and geothermal property;  
Mining exploration and development costs; and  
Inventory of an organization that accounts for inventories in  
the same manner as materials and supplies that aren't  
incidental. See Schedule A, Part III, Cost of Goods Sold, later.  
See Regulations sections 1.263A-1 through 1.263A-3.  
Preference Items  
Travel, Meals, and Entertainment  
Corporations may be required to adjust deductions for depletion  
of iron ore and coal, intangible drilling and exploration and  
development costs, and the amortizable basis of pollution control  
facilities. See section 291 to determine the amount of the  
adjustment.  
Subject to the limitations and restrictions discussed below, an  
organization can deduct ordinary and necessary travel, meals,  
and non-entertainment expenses paid or incurred in its trade or  
business. Generally, entertainment expenses, membership  
dues, and facilities used in connection with these activities can’t  
be deducted. In addition, no deduction is generally allowed for  
qualified transportation fringe benefits. Special rules apply to  
deductions for gifts, luxury water travel, and convention  
expenses. See section 274 and Pub. 463, Travel, Gift, and Car  
Expenses.  
Section 263A Uniform Capitalization Rules  
These rules require organizations to capitalize or include as  
inventory cost certain costs incurred in connection with the  
following.  
Qualified transportation fringes (QTFs). Generally, no  
deduction is allowed under section 274(a)(4) for QTFs provided  
by employers to their employees. QTFs are defined in section  
132(f)(1) and include:  
The production of real property and tangible personal property  
held in inventory or held for sale in the ordinary course of  
business.  
Real property or personal property held in inventory (tangible  
Transportation in a commuter highway vehicle between the  
and intangible) acquired for resale.  
employee's residence and place of employment,  
The production of real property and tangible personal property  
Any transit pass, and  
Qualified parking.  
See section 274, Pub. 15-B, and Pub. 535 for details.  
produced by the organization for use in its trade or business or in  
an activity engaged in for profit.  
Tangible personal property produced by an organization  
includes a film, sound recording, videotape, book, or similar  
property.  
Travel. The organization can’t deduct travel expenses of any  
individual accompanying an organization's officer or employee,  
including a spouse or dependent of the officer or employee,  
unless:  
Indirect expenses. Organizations subject to the section 263A  
uniform capitalization rules are required to capitalize direct costs  
and an allocable part of most indirect costs (including taxes) that  
benefit the assets produced or acquired for resale or are  
incurred by reason of the performance of production or resale  
activities.  
That individual is an employee of the organization, and  
Their travel is for a bona fide business purpose and would  
otherwise be deductible by that individual.  
Meals. Generally, the organization can deduct only 50% of the  
amount otherwise allowable for non-entertainment-related meal  
expenses paid or incurred in an unrelated trade or business.  
Meals not separately stated from entertainment are generally not  
deductible. In addition (subject to exceptions under section  
274(k)(2)):  
For inventory, some of the indirect expenses that must be  
capitalized are:  
Administration expenses;  
Taxes;  
Depreciation;  
Meals mustn’t be lavish or extravagant, and  
Insurance;  
An employee of the organization must be present at the meal.  
Compensation paid to officers attributable to services;  
Rework labor; and  
Membership dues. The organization can deduct amounts paid  
or incurred for membership dues in civic or public service  
organizations, professional organizations (such as bar and  
medical associations), business leagues, trade associations,  
chambers of commerce, boards of trade, and real estate boards.  
However, no deduction is allowed if a principal purpose of the  
organization is to entertain or provide entertainment facilities for  
members or their guests. In addition, organizations can’t deduct  
membership dues in any club organized for business, pleasure,  
recreation, or other social purpose. This includes country clubs,  
golf and athletic clubs, airline and hotel clubs, and clubs  
operated to provide meals under conditions favorable to  
business discussion.  
Contributions to pension, stock bonus, and certain  
profit-sharing, annuity, or deferred compensation plans.  
Regulations section 1.263A-1(e)(3) specifies other indirect  
costs that relate to production or resale activities that must be  
capitalized and those that may be currently deductible.  
Interest expense. Interest expense paid or incurred during the  
production period of designated property must be capitalized  
and is governed by special rules. See Regulations section  
1.263A-8 through 1.263A-15.  
When are section 263A capitalized costs deductible? The  
costs required to be capitalized under section 263A aren't  
deductible until the property (to which the costs relate) is sold,  
used, or otherwise disposed of by the organization.  
20  
Instructions for Form 990-T  
     
that don't add to the value or appreciably prolong the life of the  
property.  
Entertainment facilities. The organization can’t deduct an  
expense paid or incurred for use of a facility (such as a yacht or  
hunting lodge) for an activity usually considered entertainment,  
amusement, or recreation.  
Bad Debts  
Line 4. Enter the total receivables from an unrelated trade or  
business that were previously included in taxable income and  
that became worthless in whole or in part during the tax year.  
Amounts treated as compensation. The organization may  
generally be able to deduct otherwise non-deductible travel,  
meals, and entertainment expenses if the amounts are treated  
as compensation and reported on Form W-2 for an employee or  
Form 1099-NEC for an independent contractor and if the total  
amount of such compensation isn't unreasonable.  
Interest  
Line 5. Attach a separate statement listing the interest being  
claimed on this line.  
Reducing Certain Expenses for Which Credits  
Are Allowable  
Interest allocation. If the proceeds of a loan were used for  
more than one purpose (for example, to purchase a portfolio  
investment and to acquire an interest in a passive activity), an  
interest allocation must be made. See Temporary Regulations  
section 1.163-8T for the interest allocation rules.  
If the organization claims certain credits, it may need to reduce  
the otherwise allowable deductions for expenses used to figure  
the credit. This applies to credits such as the following.  
Disabled access credit.  
Tax-exempt interest. Don't include interest on indebtedness  
incurred or continued to purchase or carry obligations on which  
the interest income is totally exempt from income tax. For  
exceptions, see section 265(b).  
Employer credit for social security and Medicare taxes paid on  
certain employee tips.  
Credit for employer-provided childcare facilities and services.  
Orphan drug credit.  
Credit for small employer pension plan startup costs.  
Employer credit for paid family and medical leave.  
Prepaid interest. Generally, a cash basis taxpayer can’t deduct  
prepaid interest allocable to years following the current tax year,  
for example, during the tax year a cash basis taxpayer prepaid  
interest on a loan. The taxpayer can deduct only that part of the  
prepaid interest that was for the use of the loaned funds during  
the tax year, not for the use of the loaned funds during the  
subsequent years.  
If the organization has any of these credits, figure each  
current-year credit before figuring the deduction for expenses on  
which the credit is based.  
Business Startup and Organizational Costs  
Straddle interest. Generally, the interest and carrying charges  
on straddles can’t be deducted and must be capitalized. See  
section 263(g).  
For business startup and organizational costs paid or incurred  
after September 8, 2008, an organization can deduct up to  
$5,000 of such costs in the year it begins business (unless the  
organization elects to capitalize the full amount of such costs).  
The $5,000 deduction is reduced (but not below zero) by the  
amount the total costs exceed $50,000. If the total costs are  
$55,000 or more, the deduction is reduced to zero. Any costs not  
deducted must be amortized, as explained below.  
Original issue discount. See section 163(e)(5) for special  
rules for the disqualified portion of original issue discount on a  
high-yield discount obligation.  
Interest on certain underpayments of tax. Don't deduct  
interest paid or incurred on any portion of an underpayment of  
tax that is attributable to an understatement arising from an  
undisclosed listed transaction or an undisclosed reportable  
avoidance transaction (other than a listed transaction) entered  
into in tax years beginning after October 22, 2004.  
Note. For startup and organizational costs paid or incurred after  
September 8, 2008, the organization isn't required to attach a  
statement or specifically identify the amount deducted for the  
election under sections 195(b) and 248(a) to be effective. It is a  
deemed election. Whether an organization deducts a portion of  
its startup and organizational costs under Regulations sections  
1.195-1 and 1.248-1 or elects to amortize the full amount of such  
costs, its election is irrevocable. For startup and organizational  
costs paid or incurred after October 22, 2004, and before  
September 9, 2008, an organization must generally attach the  
statement required by Regulations sections 1.195-1(b) and  
1.248-1(c) to make the election to deduct a portion of such costs  
(as explained above). This election is irrevocable. However, an  
organization can apply the provisions of these regulations to  
costs paid or incurred after October 22, 2004.  
Interest allocable to the production of designated property.  
Don't deduct interest on debt allocable to the production of  
designated property. Interest that is allocable to such property  
produced by an organization for its own use or for sale must be  
capitalized. An organization must also capitalize any interest on  
debt allocable to an asset used to produce the earlier property.  
See section 263A(f) and Regulations sections 1.263A-8 through  
1.263A-15.  
Interest on below-market loans. See section 7872 for special  
rules regarding the deductibility of foregone interest on certain  
below-market-rate loans.  
Amortization. Any costs not deducted under the above rules  
must be amortized ratably over the 180-month period, beginning  
with the month the organization begins business. See the  
Instructions for Form 4562, Depreciation and Amortization, for  
details. If the association elected to amortize business startup  
and organizational costs paid or incurred before October 23,  
2004, over a period of 60 months or more, it must continue to  
amortize those costs over the elected amortization period.  
Report the deductible amount of these costs and any  
Limitation on deduction of business interest. Business  
interest expense is limited to the sum of business interest  
income, 30% of the adjusted taxable income, and floor plan  
financing interest. Business interest expense includes any  
interest paid or accrued on indebtedness properly allocable to  
an unrelated trade or business. A taxpayer, other than a tax  
shelter, that meets the gross receipts test isn’t required to limit  
business interest expense under section 163(j). A taxpayer  
meets the gross receipts test if the taxpayer has average annual  
gross receipts that are taken into account in determining its UBTI  
of $29 million or less for the 3 prior tax years. Gross receipts  
include the aggregate gross receipts from all persons treated as  
a single employer such as a controlled group of corporations,  
commonly controlled partnerships or proprietorships, and  
amortization on Schedule A, Part II, line 14. For amortization that  
began during the tax year, complete and attach Form 4562.  
Repairs and Maintenance  
Line 3. Enter the cost of incidental repairs and maintenance not  
claimed elsewhere on the return, such as labor and supplies,  
21  
Instructions for Form 990-T  
   
affiliated service groups. If the taxpayer fails to meet the gross  
receipts test, Form 8990 is generally required.  
Other Deductions  
Line 14. Enter on this line the deduction taken for amortization  
(see Form 4562) as well as other authorized deductions for  
which no space is provided on the return. Attach a statement  
listing the deductions claimed on this line. On each Schedule A,  
deduct only items directly connected with the unrelated trade or  
business for which income is reported on that Schedule A.  
Taxes and Licenses  
Line 6. Enter taxes and license fees paid or accrued during the  
year, but don't include the following taxes.  
Federal income taxes.  
Foreign or U.S. territory income taxes if a foreign tax credit is  
Extraterritorial income exclusion. Complete Form 8873 and  
include the deduction from line 52 in other deductions reported  
on Part II, line 14.  
Don't deduct fines or penalties paid to a government for  
violating any law. The exclusion was repealed generally for  
transactions after 2004, with some exceptions. See Form 8873  
and its instructions.  
claimed.  
Taxes not imposed on your organization.  
Taxes, including state or local sales taxes, paid or incurred in  
connection with an acquisition or disposition of property. These  
taxes must be treated as part of the cost of the acquired property  
or, in the case of a disposition, as a reduction in the amount  
realized on the disposition.  
Taxes assessed against local benefits that increase the value  
Net Operating Loss (NOL) Deduction Arising in  
Tax Years Beginning On or After January 1, 2018  
of the property assessed (such as for paving, etc.).  
Taxes deducted elsewhere on the return, such as those  
reflected in cost of goods sold.  
See section 164(d) for apportionment of taxes on real  
property between the buyer and seller.  
Line 17. The NOL deduction is the NOL carryover and  
carrybacks that can be deducted in the tax year with regard to  
each separate trade or business. To be deductible, an NOL must  
have been incurred in an unrelated trade or business activity.  
See section 172(a).  
Do not reduce the corporation’s deduction for social  
security and Medicare taxes by the amount claimed on  
!
CAUTION  
its employment tax and refundable portions of the  
FFCRA and ARP credits for qualified sick and family leave  
wages. Instead, report this amount as income on line 10.  
Tax Cuts and Jobs Act amendments to section 172. Section  
13302 of the Tax Cuts and Jobs Act amended section 172 for tax  
years ending after 2017 to eliminate NOL carrybacks except for  
certain farming losses and NOLs of insurance companies other  
than life insurance companies. See section 172(b), as amended  
by the Tax Cuts and Jobs Act. Also see Pub. 225, Farmer’s Tax  
Guide; Pub. 536, Net Operating Losses for Individuals, Estates,  
and Trusts; and Pub. 542, Corporations, for additional  
Depreciation  
Line 7. Besides depreciation, include on line 7 the part of the  
cost, under section 179, that the organization elected to expense  
for certain tangible property placed in service during the tax year  
or carried over from the prior tax year. See Form 4562 and its  
instructions.  
information. The Tax Cuts and Jobs Act also amended section  
172(a)(2) to limit the allowable NOL deduction to 80% of taxable  
income (calculated as described in section 172(a)(2)).  
Depletion  
Line 9. See sections 613 and 613A for percentage depletion  
rates for natural deposits. Attach Form T (Timber), Forest  
Activities Schedules, if a deduction is taken for depletion of  
timber.  
Instructions for line 17. Enter on Schedule A, Part II, line 17,  
the NOL carryover from other tax years attributable to that trade  
or business, but don't enter more than the amount shown on  
Schedule A, Part II, line 16. An organization that claims the  
deduction with respect to any NOL carried through tax years for  
which the organization was not required to file Form 990-T must  
show the amount of the deduction and how it was computed, but  
the organization need not file a Form 990-T in order to preserve  
an NOL carryover. See Regulations section 1.512(a)-6(h)(3) for  
treatment of suspended NOLs resulting from the termination,  
sale, exchange, or other disposition of a separate unrelated  
trade or business. After offsetting any gain resulting from the  
termination, sale, exchange, or disposition of a separate  
Contributions to Deferred Compensation Plans  
Line 10. Employers who maintain pension, profit-sharing, or  
other funded deferred compensation plans are generally  
required to file Form 5500. This requirement applies whether or  
not the plan is qualified under the Code and whether or not a  
deduction is claimed for the current tax year. Section 6652(e)  
imposes a penalty for late filing of these forms. In addition, there  
is a penalty for overstating the pension plan deduction. See  
section 6662(f).  
unrelated trade or business, any NOL remaining is suspended.  
However, the suspended NOLs may be used if that previous  
separate unrelated trade or business is later resumed or if a new  
unrelated trade or business that is accurately identified using the  
same NAICS 2-digit code as the previous separate unrelated  
trade or business is commenced or acquired in a future tax year.  
The amount of an NOL carryover is determined under section  
172. See Regulations section 1.512(b)-1(e) and, for  
organizations with more than one unrelated trade or business,  
Regulations section 1.512(a)-6(h). Attach a statement showing  
the computation of the NOL deduction.  
Employee Benefit Programs  
Line 11. Enter the amount of contributions to employee benefit  
programs (such as insurance, health, and welfare programs) that  
aren't an incidental part of a deferred compensation plan  
included on Schedule A, Part II, line 10.  
Excess Exempt Expenses  
Line 12. Enter the amount computed on Part VIII, line 7 (if  
applicable), on Part II, line 12.  
Unrelated Business Taxable Income  
Excess Readership Costs  
Line 18. Use the greater of the amount computed on line 18 or  
zero in the computation of UBTI on Part I, line 1, of Form 990-T.  
A net loss calculated on any Schedule A, Part II, line 18, can’t be  
used to offset gain on any other Schedule A. Accordingly, a net  
Line 13. Enter the amount computed on Part IX, line 8a (if  
applicable), on Part II, line 13.  
22  
Instructions for Form 990-T  
     
loss on a Schedule A should be treated as zero to calculate the  
amount reported on Part I, line 1, of Form 990-T  
less than scrap value). Bona fide selling price means actual  
offering of goods during a period ending not later than 30 days  
after inventory date.  
If this is the first year the Last-in First-out (LIFO) inventory  
method was either adopted or extended to inventory goods not  
previously valued under the LIFO method provided in section  
472, attach Form 970, Application To Use LIFO Inventory  
Method, or a statement with the information required by Form  
970.  
If the organization changed or extended its inventory method  
to LIFO and had to write up the opening inventory to cost in the  
year of election, report the effect of this write-up as other income  
(Part I, line 12) proportionately over a 3-year period that begins  
in the tax year the LIFO election was made (section 472(d)).  
Part III. Cost of Goods Sold  
Generally, inventories are required at the beginning and end of  
each tax year if the production, purchase, or sale of merchandise  
is an income-producing factor. See Regulations section 1.471-1.  
However, if the organization is a qualifying taxpayer or a  
qualifying small business taxpayer, it may adopt or change its  
accounting method to account for inventoriable items in the  
same manner as materials and supplies that aren't incidental  
(unless its business is a tax shelter (as defined in section 448(d)  
(3)).  
A qualifying taxpayer is a taxpayer that, for each prior tax year  
ending after December 16, 1998, has average annual gross  
receipts of $1 million or less for the 3-tax-year period ending with  
that prior tax year.  
Line 1. If the organization is changing its method of accounting  
to no longer account for inventories, it must refigure last year's  
closing inventory using the new method of accounting and enter  
the result on line 1. If there is a difference between last year's  
closing inventory and the refigured amount, attach an  
A qualifying small business taxpayer is a taxpayer (a) that has  
average annual gross receipts of $29 million or less for the  
3-tax-year period ending with that prior tax year, and (b) whose  
principal business activity isn't an ineligible activity.  
explanation and take it into account when figuring the  
organization's section 481(a) adjustment (explained earlier).  
Line 4. An entry is required on this line only for organizations  
that have elected a simplified method of accounting.  
Under this accounting method, inventory cost for raw  
materials purchased for use in producing finished goods and  
merchandise purchased for resale are deductible in the year the  
finished goods or merchandise are sold (but not before the year  
the organization paid for the raw materials or merchandise, if it is  
also using the cash method). For additional guidance on this  
method of accounting for inventoriable items, see Pub. 538 and  
the Instructions for Form 3115.  
For organizations that have elected the simplified production  
method, additional section 263A costs are generally those costs,  
other than interest, that are now required to be capitalized under  
section 263A but that weren’t capitalized under the  
organization's method of accounting immediately prior to the  
effective date of section 263A. For details, see Regulations  
section 1.263A-2(b).  
For organizations that have elected the simplified resale  
method, additional section 263A costs are generally those costs  
incurred with respect to the following categories.  
Enter amounts paid for all raw materials and merchandise  
during the tax year on line 2. The amount the organization can  
deduct for the tax year is figured on Schedule A, Part III, line 8.  
Off-site storage or warehousing.  
Purchasing.  
All filers not using the cash method of accounting should see  
Section 263A Uniform Capitalization Rules under Limitations on  
Deductions, earlier, before completing Schedule A. The  
instructions for lines 1, 4, 5, and 7, later, apply to Part III earlier,  
before completing Schedule A.  
Handling, such as processing, assembling, repackaging, and  
transporting.  
General and administrative costs (mixed service costs).  
For details, see Regulations section 1.263A-3(d).  
Inventory valuation methods. Inventories can be valued at:  
Enter on Schedule A, Part III, line 4, the balance of section  
1. Cost, as described in Regulations section 1.471-3,  
263A costs paid or incurred during the tax year not included on  
Schedule A, Part III, lines 2 and 3.  
2. Lower of cost or market, as described in Regulations  
section 1.471-4, or  
Line 5. Enter on Schedule A, Part III, line 5, any costs paid or  
incurred during the tax year not entered on Schedule A, Part III,  
lines 2 through 4. Attach a statement describing the other costs.  
3. Any other method approved by the IRS that conforms to  
the requirements of the applicable regulations cited below.  
Line 7. See Regulations sections 1.263A-1 through 1.263A-3  
for details on figuring the amount of additional section 263A  
costs to be included in ending inventory.  
If the organization accounts for inventories in the same  
manner as materials and supplies that aren't incidental, enter on  
Schedule A, Part III, line 7, the portion of its raw materials and  
merchandise purchased for resale that are included on  
Schedule A, Part III, line 6, and weren’t sold during the year.  
However, if the organization is using the cash method of  
accounting, it is required to use cost.  
A small producer is an organization whose average annual  
gross receipts are $1 million or less. Small producers that  
account for inventories in the same manner as materials and  
supplies that aren't incidental may currently deduct expenditures  
for direct labor and all indirect costs that would otherwise be  
included in inventory costs.  
The average cost (rolling average) method of valuing  
inventories generally doesn’t conform to the requirement of the  
regulations. See Rev. Rul. 71-234, 1971-1 C.B. 148.  
Organizations that use erroneous valuation methods must  
change to a method permitted for federal income tax purposes.  
File Form 3115 to make this change.  
Part IV. Rent Income  
Section 501(c)(7), (9), and (17) organizations, enter gross rents  
on Schedule A, Part I, line 6, and applicable expenses on  
Schedule A, Part II, lines 1 through 14. All rents except those that  
are exempt function income must be included.  
All organizations that have applicable rent income, other than  
section 501(c)(7), (9), and (17) organizations, should complete  
Schedule A, Part IV. For organizations other than section 501(c)  
(7), (9), and (17) organizations, only the following rents are  
taxable on Schedule A, Part I, line 6.  
Inventory may be valued below cost when the merchandise is  
unsalable at normal prices or unusable in the normal way  
because the goods are subnormal because of damage,  
imperfections, shop wear, etc., within the meaning of  
Regulations section 1.471-2(c). The goods may be valued at the  
bona fide selling price, minus direct cost of disposition (but not  
23  
Instructions for Form 990-T  
       
1. Rents from personal property leased with real property, if  
the rents from the personal property are more than 10% of the  
total rents received or accrued under the lease, determined at  
the time the personal property is placed in service.  
For section 514 purposes, don't treat an interest in a  
qualified state tuition program (QSTP) as debt. However,  
a QSTP's investment income is treated as debt-financed  
!
CAUTION  
income if the QSTP incurs indebtedness when acquiring or  
improving income-producing property.  
2. Rents from real and personal property if:  
a. More than 50% of the total rents received or accrued  
A property held to produce income is debt-financed property  
if, at any time during the tax year, there was acquisition  
indebtedness outstanding for the property. When a property held  
for the production of income by an organization is disposed of at  
a gain during the tax year, and there was acquisition  
under the lease are for personal property, or  
b. The amount of the rent depends on the income or profits  
derived by any person from the property leased (except an  
amount based on a fixed percentage of receipts or sales).  
indebtedness outstanding for that property at any time during the  
12-month period before the date of disposition, the property is  
debt-financed property. Securities purchased on margin are  
considered debt-financed property if the liability incurred in  
purchasing them remains outstanding.  
A redetermination of the percentage of rent for personal  
property is required when either:  
1. There is an increase of 100% or more by the placing of  
additional or substitute personal property in service, or  
2. There is a modification of the lease that changes the rent  
charged. Rents from both real and personal property not taxable  
on Schedule A, Part I, line 6, may be taxable on Schedule A, Part  
I, line 8, if the income is from a controlled organization or on  
Schedule A, Part I, line 7, if the property is debt-financed.  
Taxability of the rent must be considered in the following order.  
Acquisition indebtedness is the outstanding amount of  
principal debt incurred by the organization to acquire or improve  
the property. Acquisition indebtedness also includes  
indebtedness incurred:  
1. Before the property was acquired or improved, if the  
indebtedness would not have been incurred but for such  
acquisition or improvement of the property; or  
2. After the property was acquired or improved, if the  
indebtedness would not have been incurred but for such  
acquisition or improvement and the incurrence of such  
indebtedness was reasonably foreseeable at the time of such  
acquisition or improvement. See Regulations section  
1.514(c)-1(a).  
a. Rents not taxed on Schedule A, Part I, line 6, may be  
taxed on Schedule A, Part I, line 8.  
b. Rents not taxed on Schedule A, Part I, line 6 or line 8, may  
be taxed on Schedule A, Part I, line 7.  
Rents from personal property not leased with real property  
should be reported on Schedule A, Part I, line 12.  
See Form 8582 (for trusts) or Form 8810 (for corporations)  
and section 469 for limitations on losses from rental activities.  
With certain exceptions, acquisition indebtedness doesn’t  
include debt incurred by the following.  
Description of Property  
Line 1. Check the box next to the property description if the  
property is used both to carry on exempt activities and to  
conduct unrelated trade or business activities.  
1. A qualified (section 401) trust in acquiring or improving  
real property. See section 514(c)(9).  
2. A tax-exempt school (section 170(b)(1)(A)(ii)) and its  
affiliated support organizations (section 509(a)(3)) for  
indebtedness incurred after July 18, 1984.  
Line 4. For each property, attach a statement describing the  
3. An organization described in section 501(c)(25) in tax  
directly connected deductions and their amounts.  
years beginning after December 31, 1986.  
Part V. Unrelated Debt-Financed  
Income  
4. An obligation, to the extent that it is insured by the Federal  
Housing Administration, to finance the purchase, rehabilitation,  
or construction of housing for low and moderate income  
persons, or indebtedness incurred by a small business  
investment company licensed after October 22, 2004, under the  
Small Business Investment Act of 1958 if such indebtedness is  
evidenced by a debenture issued by such company under  
section 303(a) of that Act, and held or guaranteed by the Small  
Business Administration (see section 514(c)(6)(B) for  
limitations).  
Use Schedule A, Part V, to compute unrelated debt-financed  
income described in sections 512(b)(4) and 514 from  
debt-financed property only to the extent that the income doesn’t  
constitute income from the conduct of an unrelated trade or  
business and isn't specifically taxable under other provisions of  
the Code, such as taxable rents from personal property leased  
with real property reportable on Schedule A, Part IV (and  
Schedule A, Part I, line 6), or taxable interest, annuities,  
royalties, and rents from a controlled entity reportable on  
Schedule A, Part VI (and Schedule A, Part I, line 8). See  
Regulations section 1.514(b)-1(b)(2). Refer to Regulations  
section 1.512(a)-6 when reporting income from one or more  
debt-financed properties and also for rules permitting the  
aggregation of unrelated debt-financed income with other UBTI  
in certain circumstances. Gain or loss from the sale or  
disposition of debt-financed property is reported on Schedule A,  
Part I, line 4.  
5. A retirement income account described in section 403(b)  
(9) in acquiring or improving real property in tax years beginning  
on or after August 17, 2006.  
See Pub. 598 for additional exceptions to the rules for  
debt-financed property.  
Example 1. An exempt organization owns a four-story  
building. Two floors are used for an exempt purpose and two  
floors are rented (as an unrelated trade or business) for $10,000.  
Expenses are $1,000 for depreciation and $5,000 for other  
expenses that relate to the entire building. The average  
acquisition indebtedness is $6,000, and the average adjusted  
basis is $10,000. Both apply to the entire building.  
Section 501(c)(7), (9), and (17) organizations should report  
income from debt-financed property on Schedule A, Part VII  
(and Schedule A, Part I, line 9).  
Example 2. Assume the same facts as in Example 1, except  
the entire building is rented out as an unrelated trade or business  
for $20,000. To complete Schedule A, Part V, for this example,  
enter $20,000 on Schedule A, Part V, line 2; $1,000 and $5,000  
on Schedule A, Part V, lines 3(a) and 3(b), respectively (since  
the entire amount is for debt-financed property); $6,000 and  
When a debt-financed property is held for exempt purposes  
and other purposes, the organization must allocate the basis,  
debt, income, and deductions among the purposes for which the  
property is held. Don't include on Schedule A, Part V, amounts  
allocated to exempt purposes.  
24  
Instructions for Form 990-T  
   
$10,000 on Schedule A, Part V, lines 4 and 5 (since the entire  
amount is for debt-financed property); 60% on Schedule A, Part  
V, line 6; $12,000 on Schedule A, Part V, line 7; and $3,600 on  
Schedule A, Part V, line 9.  
Line 6. Divide each property's average acquisition  
indebtedness for the tax year by that property's average adjusted  
basis during the period it is held in the tax year. This percentage  
cannot be more than 100%.  
Line 1. Enter the address of the debt-financed property. If the  
debt-financed property isn’t real property, enter the address  
where the property is located and describe the property in Part  
XI, Supplemental Information.  
Check the box next to the property description if the property  
is used both to carry on exempt activities and to conduct  
unrelated trade or business activities.  
Line 7. The amount of income from debt-financed property  
included in unrelated trade or business income is figured by  
multiplying the property's gross income by the percentage  
computed on line 6.  
Line 8 . Enter on line 8 the sum of amounts computed for each  
property on line 7. Also enter this amount on Part I, line 7,  
column (A).  
Line 2. Enter the gross income from debt financed property,  
excluding income otherwise included in UBTI. For example, don't  
include rents from personal property shown on Schedule A, Part  
IV, or rents and interest from controlled organizations shown on  
Schedule A, Part VI.  
Line 9. For each debt-financed property, multiply the total  
deductions directly connected to the income (including the  
dividends-received deductions allowed by sections 243, 244,  
and 245) by the percentage computed on line 6. However, if the  
debt-financed property is depreciable property, figure the  
depreciation deduction by the straight line method only and enter  
the amount on Schedule A, Part V, line 3a.  
Line 3. For amounts shown on line 3a, attach a statement  
showing, for each property:  
1. The cost or salvage value,  
2. The year acquired,  
For each debt-financed property, attach statements showing  
separately a computation of the depreciation deduction (if any)  
reported on Schedule A, Part V, line 3a, (as described earlier)  
and a breakdown of the expenses included on Schedule A, Part  
V, line 3b. Corporations owning stock that is unrelated  
debt-financed property should see Schedule C (Dividends and  
Special Deductions) of Form 1120, U.S. Corporation Income Tax  
Return, to determine the dividends-received deductions to  
include on Schedule A, Part V, line 3b.  
When a capital loss for the tax year may be carried back or  
carried over to another tax year, the amount to carry over or back  
is figured by using the percentage determined above. However,  
in the year to which the amounts are carried, don't apply the  
debt-basis percentage to determine the deduction for that year.  
3. The property’s useful life (rounded to a whole number if  
necessary),  
4. The years remaining (rounded to a whole number if  
necessary),  
5. The annual depreciation expense amount, and  
6. The allowable depreciation expense amount.  
Line 4. Average acquisition indebtedness for any tax year is the  
average amount of the outstanding principal debt during the part  
of the tax year the property is held by the organization. To figure  
the average amount of acquisition debt, determine the amount of  
the outstanding principal debt on the first day of each calendar  
month during that part of the tax year that the organization holds  
the property. Add these amounts together, and divide the result  
by the total number of months during the tax year that the  
organization held the property. See section 514(a) and the  
related regulations for property acquired for an indeterminate  
price.  
Line 10. On line 10, enter the sum of amounts computed for  
each property on line 9. Also enter this amount on Part I, line 7,  
column (B).  
Line 11. Enter the total dividends-received deductions (after  
reduction, when applicable, by the debt-basis percentage(s))  
included on Schedule A, Part V, line 9.  
1. The average amount of acquisition debt,  
2. The percent allocable to debt-financed income, and  
3. The product of (1) multiplied by (2).  
Part VI. Interest, Annuities, Royalties,  
and Rents From Controlled  
Organizations  
Line 5. The average adjusted basis for debt-financed property  
is the average of the adjusted basis of the property on the first  
and last days during the tax year that the organization holds the  
property. Determine the adjusted basis of property under section  
1011. Adjust the basis of the property by the depreciation for all  
earlier tax years, whether or not the organization was exempt  
from tax for any of these years. Similarly, for tax years during  
which the organization is subject to tax on UBTI, adjust the basis  
of the property by the entire amount of allowable depreciation,  
even though only a part of the deduction for depreciation is taken  
into account in figuring UBTI.  
Under section 512(b)(13), interest, annuities, royalties, and rents  
received or accrued (directly or indirectly) by a controlling  
organization from a controlled organization are subject to tax,  
whether or not the activity conducted by the controlling  
organization to earn these amounts is a trade or business or is  
regularly conducted. However, see Regulations section  
1.512(b)-1(l)(5) regarding amounts taxable under other  
provisions of the Code.  
Controlled organization. An entity is a “controlled  
organization” if the controlling organization owns:  
By vote or value, more than 50% of a corporation's stock (for  
Attach a statement showing, for each property:  
1. A brief description of the property,  
2. The adjusted basis,  
3. The percent allocable to debt-financed income, and  
4. The product of (3) multiplied by (4).  
an organization that is a corporation);  
More than 50% of a partnership's profits or capital interests  
(for an organization that is a partnership); or  
More than 50% of the beneficial interests in an organization  
(for an organization other than a corporation or partnership).  
To determine the ownership of stock in a corporation, apply  
the principles of section 318 (constructive ownership of stock).  
Apply similar principles to determine the ownership of interests  
in a partnership or any other organization.  
If no adjustments to the basis of property under section 1011  
apply, the basis of the property is cost.  
See section 514(d) and the related regulations for the basis of  
debt-financed property acquired in a complete or partial  
liquidation of a corporation in exchange for its stock.  
25  
Instructions for Form 990-T  
   
organization and buys other property used for the organization's  
exempt function within a period beginning 1 year before the date  
of the sale, and ending 3 years after the date of the sale, the gain  
from the sale will be recognized only to the extent that the sales  
price of the old property is more than the cost of the other  
property. The other property need not be similar in type or use to  
the old property. The organization must notify the IRS of the sale  
by a statement attached to the return, or other written notice.  
Column 3. Enter the net unrelated income (or net unrelated  
loss) of each controlled entity listed that is exempt from tax under  
section 501(a).  
Column 7. Enter the taxable income of each nonexempt  
controlled organization.  
Column 8. Enter the net unrelated income (or net unrelated  
loss) of each controlled entity listed that isn't exempt from tax  
under section 501(a). Net unrelated income is that portion of the  
controlled entity's taxable income that would be UBTI if the entity  
were exempt under section 501(a) and had the same exempt  
purposes as the controlling organization. Net unrelated loss is  
the controlled organization's NOL adjusted under rules similar to  
those used to determine net unrelated income.  
To compute the gain on the sale of depreciable property, see  
the instructions for Part V, line 5, to determine the adjusted basis  
of the property.  
Column 3. Deduct only those expenses that are directly  
connected to the net investment income. Allocate deductions  
between exempt activities and other activities where necessary.  
The organization may not take the dividends-received  
deductions in figuring net investment income because they aren't  
treated as directly connected with the production of gross  
income.  
Column 4 or 9. For each controlled organization, enter the total  
of specified payments received from each controlled  
organization. If the organization received both specified  
payments and qualifying specified payments from a controlled  
organization, enter specified payments on one line and  
qualifying specified payments on another so that there are dual  
entries for that controlled organization.  
Column 4. Section 501(c)(7), (9), and (17) organizations may  
set aside income that would otherwise be taxable under section  
512(a)(3). However, income derived from an unrelated trade or  
business may not be set aside and thus can’t be exempt function  
income. In addition, any income set aside and later used for  
other purposes must be included in income.  
Column 5 or 10. For specified payments, enter the portion of  
column 4 or 9 to the extent that the payment reduced the net  
unrelated income (or increased the net unrelated loss) of the  
controlled entity.  
Section 501(c)(7), (9), and (17) organizations won't be taxed  
Column 6 or 11. Enter only those deductions directly  
on income set aside for:  
connected with the income entered in column 5 or 10.  
1. Religious, charitable, scientific, literary, or educational  
purposes, or for the prevention of cruelty to children or animals  
(and reasonable administration costs directly connected to such  
purposes); or  
2. The payment of life, sickness, accident, or other benefits  
(and reasonable administration costs directly connected to such  
benefits) by a section 501(c)(9) or (17) organization. The amount  
allowed as a set-aside may not exceed a limit determined using  
section 512(a)(3)(E). See sections 512(a)(3)(E) and 419A for  
details.  
With respect to qualifying specified payments, enter only that  
portion of expenses directly connected to the amounts included  
in column 5 or 10, that is, the excess of the payment over the  
FMV amount, as determined in accordance with section 482.  
Don't enter any expenses relating to the portion of such payment  
that isn't includible in income under this special rule.  
For valuation misstatements regarding qualifying  
specified payments, there is a 20% addition to tax. See  
!
CAUTION  
section 512(b)(13)(E)(ii).  
Excess qualifying specified payments. Excess qualifying  
specified payments received or accrued from a controlled entity  
(that is, the amount of qualifying specified payments in excess of  
what would have been paid or accrued if the payments had been  
determined under section 482) are included in a controlling  
exempt organization's UBTI.  
Report income set aside on Schedule A, Part VII, column 4.  
Attach a statement listing:  
1. The amount set aside for charitable purposes;  
2. The amount set aside for reasonable administration costs  
directly connected with such amount;  
3. The amount set aside for payment of life, sickness,  
accident, or other benefit; and  
Part VII. Investment Income of a  
Section 501(c)(7), (9), or (17)  
Organization  
4. The amount set aside for reasonable administration costs  
directly connected with the payment of such benefits.  
Amounts set aside aren't deductible under section 170 or any  
other section of the Code.  
The organization may elect to treat income set aside by the  
date for filing the return, including any extension of time, as  
income set aside in the tax year for which the return is filed. The  
income set aside must have been includible in gross income for  
that earlier tax year.  
Although set-aside income may be accumulated, any  
accumulation that is unreasonable will be evidence that the set  
aside wasn’t for the purposes previously mentioned.  
Net investment income set aside must be specifically  
earmarked as such, or placed in a separate account or fund  
(except for a section 501(c)(9) or (17) organization which, by the  
terms of its governing instrument, must use its net investment  
income for the payment of life, sickness, accident, or other  
benefits, and reasonable administration costs).  
Generally, for section 501(c)(7), (9), or (17) organizations,  
unrelated trade or business income includes all gross income  
from nonmembers with certain modifications. See section 512(a)  
(3)(A). Report on Schedule A, Part VII, all income from  
investments in securities and other similar investment income  
from nonmembers, including 100% of income and directly  
connected expenses from debt-financed property. Don't report  
nonmember income from debt-financed property on Schedule A,  
Part V.  
All section 501(c)(7), (9), and (17) organizations figure their  
investment income using Schedule A, Part VII. Don't include  
interest on state and local governmental obligations described in  
section 103(a).  
Investment income includes all income from debt-financed  
property.  
If a section 501(c)(7), (9), or (17) organization (or a title  
holding corporation, described earlier) sells property that was  
used for the exempt function of the section 501(c)(7), (9), or (17)  
These rules apply to a corporation described in section  
501(c)(2) (title holding corporation) whose income is payable to  
an organization described in section 501(c)(7), (9), or (17) if it  
26  
Instructions for Form 990-T  
 
files a consolidated return with the section 501(c)(7), (9), or (17)  
organization.  
of advertising income over direct advertising costs, no loss is  
allowable. See Regulations section 1.512(a)-1(f)(2)(ii)(b).  
For allocating membership receipts to circulation income, see  
Rev. Rul. 81-101, 1981 C.B. 352.  
Part VIII. Exploited Exempt Activity  
Income, Other Than Advertising  
Income  
Consolidated periodicals. If an organization publishes two or  
more periodicals, it may elect to treat the gross income for all  
(but not less than all) periodicals, and deductions directly  
connected with those periodicals (including excess readership  
costs) as if the periodicals were one to determine its UBTI. This  
rule only applies to periodicals published for the production of  
income. A periodical is considered published for the production  
of income if gross advertising income of the periodical is at least  
25% of the readership costs, and the periodical is an activity  
engaged in for profit.  
If periodicals are consolidated, check the box next to the  
periodical name, and attach a statement showing the name of  
each periodical in the consolidated group. The attached  
statement should include the amounts that correspond to  
information for lines 2 through 4. Attach a separate statement for  
the consolidated group of publications that includes the amounts  
corresponding to the information for lines 5 through 8.  
Exempt organizations that have gross income from an unrelated  
trade or business activity that exploits an exempt activity (other  
than periodical advertising income reportable on Schedule A,  
Part IX) should complete Schedule A, Part VIII. See Regulations  
section 1.513-1(d)(4)(iv) for a definition of exploited exempt  
activity. Report income from advertising other than in a periodical  
on Schedule A, Part VIII.  
Line 1. Briefly describe the exempt activity being exploited in  
an unrelated trade or business activity.  
Line 3. An exempt organization may take all deductions directly  
connected with the gross income from the unrelated trade or  
business activity.  
Line 4. Subtract directly connected deductions from the gross  
unrelated business income. If unrelated business income  
exceeds the directly connected deduction, the exempt  
organization may take into account all deductible items  
attributable to the exploited exempt activity, with the following  
limitations.  
Part X. Compensation of Officers,  
Directors, and Trustees  
Complete columns 1 through 4 for those officers, directors, and  
trustees whose salaries or other compensation are allocable to  
unrelated business gross income. Don't include in column 4  
compensation that is deducted on Schedule A, Part II, lines 2  
and 14, or any line of Schedule A, Parts III through IX.  
1. Reduce the deductible items of the exempt activity by the  
income from the activity.  
2. Limit the net amount of deductible items arrived at in item  
1 above for the exempt activity to the net unrelated business  
income from the exploited exempt activity.  
3. Exclude income and expenses of the exempt activity in  
figuring a loss carryover or carryback from the unrelated trade or  
business activity exploiting the exempt activity.  
4. Exclude deductible items of the exempt activity in figuring  
unrelated trade or business income from an activity that isn't  
exploiting the same exempt activity.  
Part XI. Supplemental Information  
Use Part XI to explain the organization’s operations, to provide  
information for lines that don’t have an embedded attachment to  
capture the information to supplement information provided on  
an embedded attachment, or to provide any other information in  
support of amounts reported on Schedule A. An organization  
that associated unrelated trade or business activity with a  
different NAICS or Business Activity Code in a prior year than the  
NAICS or Business Activity Code shown on the Schedule A for  
the current tax year can enter the explanation for the change  
here.  
As a result, the net includible exploited exempt activity  
income is the UBTI minus the excess of the exempt activity  
expenses over the exempt activity income. If the income from the  
exempt activity exceeds the exempt activity expenses, don't add  
that profit to the net income from the unrelated business activity.  
Attach a separate statement showing the computation.  
For each entry in Part XI, include the Schedule A Part and line  
number, a brief description, and the amount (if any). If necessary,  
you may also attach a PDF document to provide supplemental  
information.  
Part IX. Advertising Income  
An exempt organization that earned gross income from the sale  
of advertising in an exempt organization periodical must  
complete Schedule A, Part IX. The part of the advertising income  
taken into account is determined as follows.  
Paperwork Reduction Act Notice  
We ask for the information on these forms to carry out the  
Internal Revenue laws of the United States. You are required to  
give us the information. We need it to ensure that you are  
complying with these laws and to allow us to figure and collect  
the right amount of tax. You are not required to provide the  
information requested on a form that is subject to the Paperwork  
Reduction Act unless the form displays a valid OMB control  
number. Books or records relating to a form or its instructions  
must be retained as long as their contents may become material  
in the administration of any Internal Revenue law. Generally, tax  
returns and return information are confidential, as required by  
section 6103.  
1. If direct advertising costs (expenses directly connected  
with advertising income) are more than advertising income  
(unrelated business income), deduct that excess in figuring UBTI  
from any other unrelated trade or business activity conducted by  
the organization.  
2. If advertising income is more than direct advertising costs,  
and circulation income (exempt activity income) equals or  
exceeds readership costs (exempt activity expenses), then UBTI  
is the excess of advertising income over direct advertising costs.  
3. If advertising income is more than direct advertising costs,  
and readership costs are more than circulation income, then  
UBTI is the excess of total income (advertising income and  
circulation income) over total periodical costs (direct advertising  
costs and readership costs).  
Estimates of Taxpayer Burden. These include forms in the  
990 series and attachments; and Forms 1023, 1024, 1028,  
5578, 5884-C, 8038, 8038-B, 8038-CP, 8038-G, 8038-GC,  
8038-R, 8038-T, 8038-TC, 8328, 8718, 8282, 8453-TE, 8453-X,  
8868, 8870, 8871, 8872, 8879-TE, 8886-T, and 8899 and their  
schedules; and all the forms tax-exempt organizations attach to  
their tax returns. Time spent and out-of-pocket costs are  
4. If the readership costs are more than the circulation  
income, and the net readership costs are more than the excess  
27  
Instructions for Form 990-T  
             
presented separately. Time burden includes the time spent  
preparing to file and to file, with recordkeeping representing the  
largest component. Out-of-pocket costs include any expenses  
incurred by taxpayers to prepare and submit their tax returns.  
Examples include tax return preparation and submission fees,  
postage and photocopying costs, and tax preparation software  
costs. Note that these estimates do not include burden  
associated with post-filing activities. IRS operational data  
indicate that electronically prepared and filed returns have fewer  
arithmetic errors, implying lower post-filing burden.  
Reported time and cost burdens are national averages and  
do not necessarily reflect a “typical” case. Most taxpayers  
experience lower than average burden, with taxpayer burden  
varying considerably by taxpayer type. For instance, the  
estimated average time burden for all taxpayers filing Forms 990,  
990-EZ, 990-PF, 990-T, and 990-N and related forms is 32.8  
hours, with an average cost of $921 per return. This average  
includes all associated forms and schedules, across all  
preparation methods and taxpayer activities.  
Fiscal Year 2024 Form 990 Series Tax Compliance Cost Estimates  
Form 990  
Form 990-EZ  
Form 990-PF  
Form 990-T  
Form 990-N  
Projections of the  
Number of Returns  
to be Filed with IRS 351,100  
251,000  
69  
130,100  
53  
233,200  
42  
733,100  
5
Estimated Average  
Total Time (Hours) 107  
Estimated Average  
Total  
Out-of-Pocket  
Costs  
$2,900  
$600  
$2,200  
$2,200  
$20  
Estimated Average  
Total Monetized  
Burden  
$9,900  
$1,700  
$4,600  
$5,700  
$100  
Estimated Total  
Time (Hours)  
37,710,000  
17,400,000  
6,940,000  
9,790,000  
3,660,000  
Estimated Total  
Out-of-Pocket  
Costs  
$1,023,200,000  
$152,200,000  
$425,200,000  
$282,600,000  
$594,600,000  
$506,400,000  
$14,000,000  
$71,400,000  
Estimated Total  
Monetized Burden $3,466,900,000  
$1,324,000,000  
Note: Amounts above are for FY2024. Reported time and cost burdens are national averages and don’t necessarily reflect a  
“typical” case. Most taxpayers experience lower-than-average burden, with taxpayer burden varying considerably by taxpayer type.  
Detail may not add due to rounding.  
Comments and suggestions, We welcome your comments  
about this publication and suggestions for future editions. You  
can send us comments through IRS.gov/FormComments. Or  
you can write to:  
Phone help, If you have questions and/or need help completing  
this form, call 877-829-5500. This toll-free telephone service is  
available Monday through Friday.  
Internet, You can access the IRS website 24 hours a day, 7  
days a week, at IRS.gov to do the following.  
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Download forms and publications.  
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Order IRS products online.  
Research your tax questions online.  
Search publications online by topic and keyword.  
Use online Internal Revenue Code (IRC), Regulations, or  
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received, we do appreciate your feedback and will consider your  
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other official guidance.  
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Getting tax forms, instructions, and publications, Go to  
IRS.gov/Forms to download current and prior-year forms,  
instructions, and publications.  
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Photographs of missing children selected by the Center may  
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28  
Instructions for Form 990-T  
Industry Classification System (NAICS) commonly used  
by tax-exempt organizations. If you don’t see a code for  
the activity you need to categorize in the list below, refer  
to the full list of NAICS codes at Census.gov/NAICS.  
Business Activity Codes  
The codes listed below that begin with the digits 1  
through 8 are a selection from the North American  
513110 Newspaper publishers  
532289 All other consumer goods rental  
621500 Medical and diagnostic  
laboratories  
Agriculture, Forestry, Hunting,  
513120 Periodical publishers  
513130 Book publishers  
532420 Office machinery and equipment  
rental and leasing  
533110 Lessors of nonfinancial  
intangible assets (except  
copyrighted works)  
621610 Home health care services  
621910 Ambulance services  
and Fishing  
Code  
513140 Directory & mailing list publishers  
513190 Other publishers  
621990 All other ambulatory health care  
110000 Agriculture, forestry, hunting, and  
services  
fishing  
516100 Radio & television broadcasting  
623000 Nursing and residential care  
facilities  
Professional, Scientific, and  
Technical Services  
stations  
111000 Crop production  
516210 Media streaming, social  
networks, & other content  
providers  
Mining  
Code  
623990 Other residential care facilities  
624100 Individual and family services  
624110 Child & youth services  
Code  
517000 Telecommunications (including  
wired, wireless, satellite, cable &  
other program distribution,  
resellers, agents, other  
541100 Legal services  
211100 Oil and gas extraction  
211120 Crude petroleum extraction  
211130 Natural gas extraction  
212000 Mining (except oil and gas)  
624200 Community food and housing,  
and emergency and other relief  
services  
541200 Accounting, tax preparation,  
bookkeeping, and payroll  
services  
telecommunications, & Internet  
service providers)  
624210 Meal delivery programs, soup  
541300 Architectural, engineering, and  
kitchens, or food banks  
related services  
Utilities  
Data Processing, Web Search  
Portals, & Other Information  
Services  
624310 Vocational rehabilitation services  
624410 Childcare services  
541380 Testing laboratories & services  
Code  
541511 Custom computer programming  
221000 Utilities  
services  
Arts, Entertainment, and  
Recreation  
541519 Other computer-related services  
541610 Management consulting services  
Construction  
Code  
230000 Construction  
236000 Construction of buildings  
Code  
541700 Scientific research and  
518210 Computing infrastructure  
providers, data processing, web  
hosting, & related services  
Code  
development services  
711110 Theater companies and dinner  
541800 Advertising, public relations, &  
related services  
theaters  
519200 Web search portals, libraries,  
Manufacturing  
711120 Dance companies  
archives, & other info. services  
541860 Direct mail advertising  
711130 Musical groups and artists  
711190 Other performing arts companies  
Code  
541900 Other professional, scientific,  
Finance and Insurance  
Code  
310000 Manufacturing  
and technical services  
711210 Spectator sports (including  
323100 Printing and related support  
541990 Consumer Credit Counseling  
Services  
sports clubs and racetracks)  
activities  
522100 Depository credit intermediation  
(including commercial banking,  
savings institutions, and credit  
unions)  
711300 Promoters of performing arts,  
sports, and similar events  
339110 Medical equipment and supplies  
manufacturing  
Management of Companies and  
713110 Amusement and theme parks  
713200 Gambling industries  
Enterprises  
Wholesale Trade  
522200 Nondepository credit  
Code  
intermediation  
Code  
713910 Golf courses and country clubs  
551111 Offices of bank holding  
522210 Credit card issuing  
522220 Sales financing  
522291 Consumer lending  
522292 Real estate credit  
423000 Merchant wholesalers, durable  
713940 Fitness and recreational sports  
companies  
goods  
centers  
551112 Offices of other holding  
companies  
424000 Merchant wholesalers,  
nondurable goods  
713990 All other amusement and  
recreation industries (including  
skiing facilities, marinas, and  
bowling centers)  
Administrative and Support  
522299 Intl. secondary market, & other  
Retail Trade  
nondepository credit  
Services  
Code  
Code  
intermediation  
Accommodation and Food  
Services  
441100 Automobile dealers  
523000 Securities, commodity contracts,  
and other financial investments  
and related activities  
444100 Building materials and supplies  
561000 Administrative and support  
dealers  
services  
Code  
523940 Portfolio management &  
445100 Grocery & convenience retailers  
445200 Specialty food retailers  
561300 Employment services  
721000 Accommodation  
investment advice  
561439 Other business service centers  
721110 Hotels (except casino hotels)  
524113 Direct life insurance carriers  
(including copy shops)  
449100 Furniture and home furnishings  
and motels  
524114 Direct health and medical  
retailers  
561499 All other business support  
services  
721210 RV (recreational vehicle) parks  
and recreational camps  
insurance carriers  
455000 General merchandise retailers  
456110 Pharmacies & drug retailers  
524126 Direct property and casualty  
insurance carriers  
561500 Travel arrangement and  
721310 Rooming and boarding houses,  
reservation services  
dormitories, and workers’ camps  
456199 All other health and personal  
524130 Reinsurance carriers  
561520 Tour operators  
care retailers  
722320 Caterers  
524292 Pharmacy benefit management  
561700 Services to buildings and  
458000 Clothing, clothing accessories,  
shoe, & jewelry retailers  
722410 Drinking places (alcoholic  
& other third-party administration  
dwellings  
beverages)  
524298 All other insurance-related  
activities  
459110 Sporting goods retailers  
722511 Full-service restaurants  
Waste Management and  
Remediation Services  
Code  
562000 Waste management and  
remediation services (sanitary  
services)  
459120 Hobby, toy, & game retailers  
722513 Limited-service restaurants  
525100 Insurance and employee benefit  
459130 Sewing, needlework, & piece  
722514 Cafeterias, grill buffets, and  
funds  
goods retailers  
buffets  
525920 Trusts, estates, and agency  
accounts  
459140 Musical instrument & supplies  
retailers  
722515 Snack and non-alcoholic  
beverage bars  
525990 Other financial vehicles  
459210 Book retailers & news dealers  
(including mortgage REITs)  
Other Services  
(including newsstands)  
Educational Services  
Real Estate and Rental and  
Leasing  
Code  
Code  
459310 Florists  
Code  
811000 Repair and maintenance  
459410 Office supplies & stationery  
retailers  
611420 Computer training  
812300 Dry cleaning and laundry  
services  
459420 Gift, novelty, and souvenir  
retailers  
611430 Professional and management  
531110 Lessors of residential buildings  
and dwellings (including equity  
REITs)  
development training  
812900 Other personal services  
812930 Parking lots and garages  
459510 Used merchandise retailers  
459900 Other miscellaneous retailers  
611600 Other schools and instruction  
(other than elementary and  
secondary schools or colleges  
and universities, which should  
select a code to describe their  
unrelated activities)  
531120 Lessors of nonresidential  
buildings (except  
Transportation and  
Warehousing  
miniwarehouses)(including  
equity REITs)  
531130 Lessors of miniwarehouses &  
self-storage units (including  
equity REITs)  
611710 Educational support services  
Healthcare and Social  
Assistance  
Code  
480000 Transportation  
485000 Transit and ground passenger  
531190 Lessors of other real estate  
transportation  
property (including equity REITs)  
493000 Warehousing and storage  
531310 Real estate property managers  
531320 Offices of real estate appraisers  
Code  
621110 Offices of physicians  
Information  
Code  
531390 Other activities related to real  
621300 Offices of other health  
estate  
practitioners  
512000 Motion picture and sound  
532000 Rental and leasing services  
621400 Outpatient care centers  
recording industries  
29  
 
Additional codes  
Additional codes listed below that begin  
with “9” are not part of the NAICS and are  
not listed on the NAICS website  
Trade or business. A trade or business  
is any activity conducted for the  
Appendix A. Definitions  
production of income from selling goods  
or performing services. An activity must  
be conducted with intent to profit to  
constitute a trade or business. An activity  
doesn’t lose its identity as a trade or  
business merely because it is conducted  
within a larger group of similar activities  
that may or may not be related to the  
exempt purpose of the organization. If,  
however, an activity conducted for profit  
is an unrelated trade or business, no part  
of it can be excluded from this  
Section 501(c)(3) organization.  
Section 501(c)(3) describes certain  
organizations which are exempt from  
taxation under section 501(a). A 501(c)  
(3) organization is an organization  
organized and operated exclusively for  
charitable purposes. See Regulations  
section 1.501(c)(3)-1(a).  
Census.gov/NAICS. The non-NAICS  
business activity codes are for use on  
Form 990-T to identify various types of  
investments, including certain  
partnership and S corporation interests,  
reported as separate trades or  
businesses under section 512(a)(6)  
without regard to the specific trade or  
business engaged in by the partnership  
or S corporation. See Regulations  
section 1.512(a)-6.  
Annual return. An annual return (for  
purposes of the public inspection rules  
discussed below) is an exact copy of the  
Form 990-T that was filed with the IRS,  
including all schedules and attachments.  
It also includes any amendments to the  
original return (amended return).  
classification merely because it doesn’t  
result in profit.  
Non-NAICS Business  
Activity Codes  
Separate trade or business. An  
organization with more than one  
unrelated trade or business should refer  
to Regulations section 1.512(a)-6 to  
determine if two or more trades or  
businesses are separate trades or  
businesses for purposes of calculating  
UBTI.  
In the codes below that include “###”  
replace “#” with numbers to identify each  
interest (nonqualified S corporation or  
passive income activity). For example, if  
four Schedules A are being filed to report  
unrelated trade or business income from  
four separate nonqualifying S corporation  
interests, the business activity code  
entered in item C at the top of the four  
Schedules A would be 904001, 904002,  
904003, and 904004, respectively.  
By annual return (for purposes of the  
public inspection rules discussed below),  
we mean any annual return (defined  
above) that isn't more than 3 years old  
from the later of:  
The date the return is required to be  
filed (including extensions), or  
Unrelated trade or business income.  
Unrelated trade or business income is the  
gross income derived from any trade or  
business (defined above) regularly  
The date that the return is actually  
filed.  
Directly connected expenses. To be  
deductible in computing UBTI, expenses,  
depreciation, and similar items must  
qualify as deductions allowed by section  
162, section 167, or other sections, and  
must be directly connected with the  
conduct of unrelated trade or business  
activity.  
To be directly connected with the  
conduct of an unrelated trade or business  
activity, expenses, depreciation, and  
similar items must bear a proximate and  
primary relationship to the conduct of the  
activity. For example, where facilities  
and/or personnel are used both to  
conduct exempt activities and to conduct  
an unrelated trade or business, expenses  
and similar items attributable to such  
facilities and/or personnel must be  
allocated between the two uses on a  
reasonable basis. The portion of any  
such item allocated to the unrelated trade  
or business must bear a proximate and  
primary relationship to that unrelated  
trade or business.  
carried on and not substantially related to  
(defined above) the organization's  
901101. Investment activities, including:  
Debt-financed income (512(b)(4));  
Qualifying partnership interests;  
exempt purpose or function (aside from  
the organization's need for income or  
funds or the use it makes of the profits).  
Qualifying S corporation interests; and  
Certain gross income of organizations  
Generally, for section 501(c)(7), (9), or  
(17) organizations, unrelated trade or  
business income is derived from  
nonmembers with certain modifications  
(see section 512(a)).  
For a section 511(a)(2)(B) state  
college or university, or a corporation  
wholly owned by such a college or  
university, unrelated trade or business  
income is derived from activities not  
substantially related to exercising or  
performing any purpose or function  
described in section 501(c)(3).  
subject to section 512(a)(3), or 501(c)(7),  
(9), or (17).  
901301. Insurance income derived from  
controlled foreign corporations (section  
512(b)(17)).  
903###. Passive income activities with  
controlled organizations.  
904###. Nonqualifying S corporation  
interests.  
You must report each separate  
unrelated trade or business using the first  
two digits of the NAICS code that most  
accurately describes the unrelated trade  
or business based on the more specific  
NAICS code, such as at the 6-digit level.  
Investment activities reported as  
An unrelated trade or business  
doesn’t include a trade or business:  
1. In which substantially all the work  
is performed for the organization without  
compensation; or  
2. That is conducted by a section  
501(c)(3) or 511(a)(2)(B) organization  
mainly for the convenience of its  
members, students, patients, officers, or  
employees; or  
separate trades or businesses that are  
identified with a non-NAICS business  
activity code should use the 6-digit code  
from the list above. See Regulations  
section 1.512(a)-6(b)(1).  
Not substantially related to. “Not  
substantially related to” means the  
activity that produces the income doesn’t  
contribute importantly to the exempt  
purposes of the organization, other than  
the need for funds. Whether an activity  
contributes importantly depends in each  
case on the facts involved.  
Item C at the top of Schedule A  
requires a 6-digit entry. Enter a 2-digit  
NAICS code by entering the first digits  
followed by four zeros.  
3. That sells items of work-related  
equipment and clothes, and items  
normally sold through vending machines,  
food dispensing facilities or by snack  
bars, by a local association of employees  
described in section 501(c)(4), organized  
before May 27, 1969, if the sales are for  
For details, see Pub. 598, Tax on  
Unrelated Business Income of Exempt  
Organizations.  
30  
 
the convenience of its members at their  
usual place of employment; or  
4. That sells merchandise  
substantially all of which was received by  
the organization as gifts or contributions;  
or  
December 31, 1997. Generally, qualified  
sponsorship payment means any  
payment to a tax-exempt organization by  
a person engaged in a trade or business  
in which there is no arrangement or  
expectation of any substantial return  
benefit by that person other than the use  
or acknowledgment of that person's  
name, logo, or product lines in  
2. For contributions to other  
organizations, the amount claimed may  
not be more than the smaller of:  
a. 30% of UBTI figured without this  
deduction; or  
b. The amount by which 50% of the  
UBTI is more than the contributions  
allowed in (1) above.  
5. That consists of qualified public  
entertainment activities regularly  
conducted by a section 501(c)(3), (4), or  
(5) organization as one of its substantial  
exempt purposes (see section 513(d)(2)  
for the meaning of qualified public  
entertainment activities); or  
An increased limitation may be  
available for cash contributions under  
section 170(b)(1)(G).  
connection with the activities of the  
tax-exempt organization. See section  
513(i).  
Contributions not allowable in  
whole or in part because of the  
!
6. That consists of qualified  
convention or trade show activities  
regularly conducted by a section 501(c)  
(3), (4), (5), or (6) organization as one of  
its substantial exempt purposes (see  
section 513(d)(3) for the meaning of  
qualified convention and trade show  
activities); or  
CAUTION  
limitations may not be deducted  
Appendix B. Charitable  
Contribution Deduction  
Charitable contributions. Filers should  
use the following information regarding  
the charitable contribution deduction to  
complete Form 990-T, Part I, line 4.  
as a business expense but may be  
carried over to the next 5 tax years.  
Substantiation requirements.  
Generally, no deduction is allowed for any  
contribution of $250 or more, unless the  
organization gets a written  
Corporations. The total amount claimed  
normally can’t be more than 10% of UBTI  
figured without regard to the following.  
7. That furnishes one or more  
acknowledgment from the donee  
organization that shows the amount of  
cash contributed, describes any property  
contributed, and either gives a  
services described in section 501(e)(1)  
(A) by a hospital to one or more hospitals  
subject to conditions in section 513(e); or  
Any deduction for contributions.  
Any capital loss carryback to the tax  
description and a good faith estimate of  
the value of any goods or services  
provided in return for the contribution or  
states that no goods or services were  
provided in return for the contribution.  
The acknowledgment must be obtained  
by the due date (including extensions) of  
the organization's return, or, if earlier, the  
date the return is filed. However, see  
section 170(f)(8) and the related  
8. That consists of qualified pole  
rentals, as defined in section 501(c)(12)  
(D), by a mutual or cooperative telephone  
or electric company; or  
9. That includes activities relating to  
the distribution of low-cost articles, each  
costing $12.50 (IRC 1 per Rev. Proc.  
2022-38, section 3.34(1)) or less, by an  
organization described in section 501  
and contributions to which are deductible  
under section 170(c)(2) or (3) if the  
distribution is incidental to the solicitation  
of charitable contributions; or  
10. That includes the exchange or  
rental of donor or membership lists  
between organizations described in  
section 501 and contributions to which  
are deductible under section 170(c)(2) or  
(3); or  
11. That consists of bingo games as  
defined in section 513(f). Generally, a  
bingo game isn't included in any  
unrelated trade or business if:  
year under section 1212(a)(1).  
Corporations on the accrual basis can  
elect to deduct contributions paid by the  
15th day of the 4th month after the end of  
the tax year if the contributions are  
authorized by the board of directors  
during the tax year. Attach a declaration  
statement to the return stating that the  
resolution authorizing the contributions  
was adopted by the board of directors  
during the tax year. The declaration  
statement must also include the date the  
resolution was adopted. See Regulations  
section 1.170A-11.  
Charitable contributions over the 10%  
limitation can’t be deducted for the tax  
year, but may be carried over to the next  
5 tax years.  
In figuring the charitable contributions  
deduction, if the corporation has an NOL  
carryover to the tax year, the 10% limit is  
applied using the taxable income after  
taking into account any deduction for the  
NOL.  
regulations for exceptions to this rule.  
Don't attach the acknowledgment to the  
return but keep it with the organization's  
records.  
Note. For contributions of cash, check,  
or other monetary gifts (regardless of the  
amount), the organization must maintain  
a bank record, or a receipt, letter, or other  
written communication from the donee  
organization indicating the name of the  
organization, the date of the contribution,  
and the amount of the contribution.  
Contributions of property other than  
cash. If an organization contributes  
property other than cash and claims over  
a $500 deduction for the property, it must  
attach a statement to the return  
a. Wagers are placed, winners are  
determined, and prizes are  
distributed in the presence of all  
persons wagering in that game; and  
b. The game doesn’t compete with  
bingo games conducted by for-profit  
businesses in the same jurisdiction;  
and  
To figure the amount of any remaining  
NOL carryover to later years, taxable  
income must be modified. See section  
172(b). To the extent charitable  
describing the kind of property  
contributed and the method used to  
determine its FMV. All organizations must  
generally complete and attach Form  
8283, Noncash Charitable Contributions,  
to their returns for contributions of  
contributions are used to reduce taxable  
income for this purpose and increase an  
NOL carryover, a contributions carryover  
isn't allowed. See section 170(d)(2)(B).  
c. The game doesn’t violate state or  
local law; or  
Trusts. In general.  
property (other than money) if the total  
claimed deduction for all property  
12. That consists of conducting any  
game of chance by a nonprofit  
1. For contributions to organizations  
described in section 170(b)(1)(A), the  
amount claimed may not be more than  
50% of the UBTI figured without this  
deduction; and  
contributed was more than $5,000.  
Special rules apply to the contribution of  
certain property. See the instructions for  
Form 8283. A donee organization must  
use Form 8282, Donee Information  
Return, to report information to the IRS  
and donors about dispositions of certain  
organization in the state of North Dakota  
and the conducting of the game doesn’t  
violate any state or local law; or  
13. That consists of soliciting and  
receiving qualified sponsorship payments  
that are solicited or received after  
31  
 
charitable deduction property made  
within 3 years after the donor contributed  
the property. See the instructions for  
Form 8282.  
How does a 501(c)(3) organization  
make its annual returns available for  
public inspection? A 501(c)(3)  
organization must make its annual returns  
available in two ways.  
Appendix C. Public  
Inspection of Form  
990-T Returns Filed by  
Section 501(c)(3)  
Organizations  
Public inspection requirements of  
section 501(c)(3) organizations.  
Under section 6104(d), a section 501(c)  
(3) organization that files Form 990-T  
must make its entire annual exempt  
organization business income tax return  
(including amended returns) available for  
public inspection.  
Special rules for contributions of cer-  
tain easements in registered historic  
districts. The following rules apply to  
certain contributions of real property  
interests located in a registered historic  
district.  
By office visitation.  
By providing copies or making them  
widely available.  
Public inspection by office visitation.  
A 501(c)(3) organization must make its  
annual returns available for public  
inspection without charge at its principal,  
regional, and district offices during  
regular business hours.  
A deduction is allowed for the qualified  
real property interest, if the exterior of the  
building (including the front, side, rear,  
and space above the building) is  
preserved and no portion of the exterior  
is changed in a manner that is  
Conditions that may be set for public  
inspection at the office. A 501(c)(3)  
organization:  
inconsistent with its historical character.  
See section 170(h)(4)(B).  
The Form 990-T and related  
May have an employee present,  
A deduction is allowed on the building  
schedules must be made available for  
public inspection for a period of 3 years  
from the date the Form 990-T is required  
to be filed, including any extension.  
Must allow the individual conducting  
only (no deduction is allowed for a  
structure or land) if located in a registered  
historic district. However, if listed in the  
National Register, a deduction is also  
allowed for structures or land areas. See  
section 170(h)(4)(C).  
the inspection to take notes freely during  
the inspection, and  
Must allow an individual to make  
photocopies of documents at no charge  
but only if the individual brings  
photocopying equipment to the place of  
inspection.  
What schedules and attachments to  
Form 990-T must be made available  
for public inspection? Only schedules,  
attachments (statements), and  
The organization must also include the  
following information with the tax return.  
supporting documents that relate to the  
imposition of tax on UBTI must be made  
available for public inspection when  
attached to a section 501(c)(3)  
Determining if a site is a regional or  
district office. A regional or district  
office is any office of a 501(c)(3)  
organization, other than its principal  
office, that has paid employees whose  
total number of paid hours a week are  
normally 120 hours or more. Include the  
hours worked by part-time (as well as  
full-time) employees in making that  
determination.  
What sites aren't considered a  
regional or district office. A site isn't  
considered a regional or district office if:  
1. The only services provided at the  
site further the organization's exempt  
purposes (for example, daycare, health  
care, or scientific or medical research);  
and  
1. A qualified appraisal (as defined in  
section 170(f)(11)(E)) of the qualified  
property interest.  
2. Photographs of the entire exterior  
organization's Form 990-T filed after  
August 17, 2006.  
of the building.  
3. A description of all restrictions on  
the development of the building. See  
section 170(h)(4)(B)(iii).  
The following documents, when  
attached to a section 501(c)(3)  
organization's Form 990-T filed after  
August 17, 2006, aren't required to be  
made available for public inspections.  
The organization's deduction may be  
reduced if rehabilitation credits were  
claimed on the building. See section  
170(f)(14).  
Form 926, Return by a U.S. Transferor  
of Property to a Foreign Corporation.  
Form 5471, Information Return of U.S.  
A $500 filing fee may apply to certain  
Persons With Respect to Certain Foreign  
Corporations.  
deductions over $10,000. See section  
170(f)(13).  
Form 8271, Investor Reporting of Tax  
Reduced deductions for contributions  
for certain property. The organization  
must reduce its deduction for  
Shelter Registration Number.  
Form 8594, Asset Acquisition  
2. The site doesn’t serve as an office  
for management staff, other than  
managers who are involved only in  
managing the exempt function activities  
at the site.  
Statement Under Section 1060.  
contributions of certain capital gain  
property and qualified appreciated stock.  
See sections 170(e)(1) and 170(e)(5).  
Form 8621, Information Return by a  
Shareholder of a Passive Foreign  
Investment Company or Qualified  
Electing Fund.  
Special rules for corporations. A  
larger deduction is allowed for certain  
contributions of:  
Form 8832, Entity Classification  
What if the 501(c)(3) organization  
doesn’t maintain a permanent office?  
If the 501(c)(3) organization doesn’t  
maintain a permanent office, it will  
comply with the public inspection by  
office visitation requirement by making  
the annual returns available at a  
Election.  
Form 8858, Information Return of U.S.  
Inventory and other property to certain  
Persons With Respect to Foreign  
Disregarded Entities.  
organizations for use in the care of the ill,  
needy, or infants (including contributions  
of apparently wholesome food (see  
section 170(e)(3)(C))); and  
Form 8865, Return of U.S. Person With  
Respect to Certain Foreign Partnerships.  
Form 8886, Reportable Transaction  
Scientific equipment used for research  
reasonable location of its choice. It must  
permit public inspection:  
Disclosure Statement.  
Form 8913, Credit for Federal  
to institutions of higher learning or to  
certain scientific research organizations  
(see section 170(e)(4)).  
Within a reasonable amount of time  
Telephone Excise Tax Paid.  
after receiving a request for inspection  
(normally, not more than 2 weeks), and  
Form 8925, Report of  
See section 170, the related  
regulations, and Pub. 526, Charitable  
Contributions.  
Employer-Owned Life Insurance  
Contracts.  
At a reasonable time of day.  
Optional method of complying. If a  
Form 8941, Credit for Small Employer  
501(c)(3) organization that doesn’t have  
a permanent office wishes not to allow an  
inspection by office visitation, it may mail  
Health Insurance Premiums.  
Form 8975, Country-by-Country  
Report.  
32  
 
a copy of the requested documents  
instead of allowing an inspection.  
However, it must mail the documents  
within 2 weeks of receiving the request  
and may charge for copying and postage  
only if the requester consents to the  
charge.  
501(c)(3) organizations with a  
permanent office but limited or no  
hours. Even if a 501(c)(3) organization  
has a permanent office but no office  
hours or very limited hours during certain  
times of the year, it must still meet the  
office visitation requirement. To meet this  
requirement during those periods when  
office hours are limited or not available,  
follow the rules under What if the 501(c)  
(3) organization doesn’t maintain a  
permanent office, earlier.  
must immediately provide the local  
agent's name, address, and telephone  
number to the requester.  
Requests for parts of a document  
copy. A person can request all or any  
specific part or schedule of the annual  
returns and the 501(c)(3) organization  
must fulfill their request for a copy.  
Can an agent be used to provide  
copies? A 501(c)(3) organization can  
use an agent to provide document copies  
for the written requests it receives.  
However, the agent must provide the  
document copies under the same  
The local agent must:  
Be located within reasonable proximity  
to the principal, regional, or district office  
where the individual makes the request;  
and  
Provide document copies within the  
same time frames as the 501(c)(3)  
organization.  
conditions that are imposed on the 501(c)  
(3) organization itself. Also, if an agent  
fails to provide the documents as  
Written requests for document cop-  
ies. If a 501(c)(3) organization receives  
a written request for a copy of its annual  
returns (or parts of these documents), it  
must give a copy to the requester.  
However, this rule only applies if the  
request:  
required, the 501(c)(3) organization will  
continue to be subject to penalties.  
Example. The ABC Organization  
retained an agent to provide copies for all  
written requests for documents. However,  
the ABC Organization received a request  
for document copies before the agent  
did.  
The deadline for providing a response  
is referenced by the date that the ABC  
Organization received the request and  
not when the agent received it. If the  
agent received the request first, then a  
response would be referenced to the date  
that the agent received it.  
Can a fee be charged for providing  
copies? A 501(c)(3) organization may  
charge a reasonable fee for providing  
copies. Also, it can require the fee to be  
paid before providing a copy of the  
requested document.  
What is a reasonable fee? A fee is  
reasonable only if it is no more than the  
per-page copying fee charged by the IRS  
for providing copies, plus no more than  
the actual postage costs incurred to  
provide the copies.  
What forms of payment must the  
501(c)(3) organization accept? The  
form of payment depends on whether the  
request for copies is made in person or in  
writing.  
Cash and money orders must be  
accepted for in-person requests for  
document copies. The 501(c)(3)  
organization, if it wishes, may accept  
additional forms of payment.  
Is addressed to a 501(c)(3)  
organization's principal, regional, or  
district office;  
Public Inspection—Providing  
Copies  
Is delivered to that address by mail,  
A 501(c)(3) organization must provide  
copies of its annual returns to any  
electronic mail (email), facsimile (fax), or  
a private delivery service approved by the  
IRS (see Private Delivery Service, earlier,  
for a list); and  
individual who makes a request for a  
copy in person or in writing unless it  
makes these documents widely available.  
Gives the address to which the  
document copies should be sent.  
How and when a written request is  
fulfilled.  
In-person requests for document cop-  
ies. A 501(c)(3) organization must  
provide copies to any individual who  
makes a request in person at the 501(c)  
(3) organization's principal, regional, or  
district office during regular business  
hours on the same day that the individual  
makes the request.  
Accepted delay in fulfilling an  
in-person request. If unusual  
circumstances exist and fulfilling a  
request on the same day places an  
unreasonable burden on the 501(c)(3)  
organization, it must provide copies by  
the earlier of:  
Requested document copies must be  
mailed within 30 days from the date the  
501(c)(3) organization receives the  
request.  
Unless other evidence exists, a  
request or payment that is mailed is  
considered to be received by the 501(c)  
(3) organization 7 days after the postmark  
date.  
If an advance payment is required,  
copies must be provided within 30 days  
from the date payment is received.  
If the 501(c)(3) organization requires  
The next business day following the  
payment in advance and it receives a  
request without payment or with  
day that the unusual circumstances end,  
or  
insufficient payment, it must notify the  
requester of the prepayment policy and  
the amount due within 7 days from the  
date it receives the request.  
The fifth business day after the date of  
the request.  
Examples of unusual circumstances  
include:  
A request that is transmitted to the  
Receipt of a volume of requests (for  
501(c)(3) organization by email or fax is  
considered received the day the request  
is transmitted successfully.  
document copies) that exceeds the  
501(c)(3) organization's daily capacity to  
make copies,  
Certified check, money order, and  
either personal check or credit card must  
be accepted for written requests for  
document copies. The 501(c)(3)  
Requested documents can be emailed  
Requests received shortly before the  
instead of the traditional method of  
mailing if the requester consents to this  
method.  
end of regular business hours that require  
an extensive amount of copying, or  
organization, if it wishes, may accept  
additional forms of payment.  
Requests received on a day when the  
A document copy is considered as  
501(c)(3) organization's managerial staff  
capable of fulfilling the request is  
Other fee information. If a 501(c)(3)  
organization provides a requester with  
notice of a fee and the requester doesn’t  
pay the fee within 30 days, the 501(c)(3)  
organization may ignore the request.  
provided on the:  
Postmark date,  
conducting official duties (for example,  
student registration or attending an  
off-site meeting or convention) instead of  
its regular administrative duties.  
Private delivery date,  
Registration date for certified or  
registered mail,  
If a requester's check doesn’t clear on  
deposit, the 501(c)(3) organization may  
ignore the request.  
Postmark date on the sender's receipt  
Use of local agents for providing  
copies. A 501(c)(3) organization may  
use a local agent to handle in-person  
requests for document copies. If a 501(c)  
(3) organization uses a local agent, it  
for certified or registered mail, or  
Day the email is successfully  
transmitted (if the requester agreed to  
this method).  
If a 501(c)(3) organization doesn’t  
require prepayment and the requester  
33  
doesn’t prepay, the 501(c)(3)  
1. The Internet posting requirement  
is met if:  
Takes reasonable precautions to  
organization must receive consent from  
the requester if the copying and postage  
charge exceeds $20.  
prevent alteration, destruction, or  
accidental loss of the document when  
posted on its page; and  
The document is posted on an Internet  
page that the 501(c)(3) organization  
establishes and maintains, or  
Corrects or replaces the document if a  
501(c)(3) organizations subject to a  
harassment campaign. If the IRS  
determines that a 501(c)(3) organization  
is being harassed, it isn't required to  
comply with any request for copies that it  
reasonably believes is part of the  
harassment campaign.  
A group of requests for a 501(c)(3)  
organization's annual return is indicative  
of a harassment campaign if the requests  
are part of a single coordinated effort to  
disrupt the operations of the 501(c)(3)  
organization rather than to collect  
information about it.  
The document is posted as part of a  
posted document is altered, destroyed, or  
lost.  
database of like documents of other  
tax-exempt organizations on an Internet  
page established and maintained by  
another entity.  
4. The notice requirement is met if a  
501(c)(3) organization notifies any  
individual requesting a copy of its annual  
return where the documents are available  
(including the Internet address). If the  
request is made in person, the 501(c)(3)  
organization must notify the individual  
immediately. If the request is in writing, it  
must notify the individual within 7 days of  
receiving the request.  
2. An additional posting information  
requirement is met if:  
The Internet page through which the  
document is available clearly informs  
readers that the document is available  
and provides instructions for downloading  
the document;  
After it is downloaded and viewed, the  
Penalties  
web document exactly reproduces the  
image of the annual return as it was  
originally filed with the IRS, except for any  
information permitted by statute to be  
withheld from public disclosure; and  
Requests that may be disregarded  
without IRS approval. A 501(c)(3)  
organization may disregard any request  
for copies of all or part of any document  
beyond the first two received within any  
30-day period or the first four received  
within any 1-year period from the same  
individual or the same address.  
A penalty may be imposed on any person  
who doesn’t make the annual returns  
(including all required attachments)  
available for public inspection according  
to the section 6104(d) rules discussed  
earlier. If more than one person fails to  
comply, each person is jointly and  
severally liable for the full amount of the  
penalty. The penalty amount is $20 for  
each day during which a failure occurs.  
The maximum penalty that may be  
imposed on all persons for any one  
annual return is $10,000.  
Any individual with access to the  
Internet can access, download, view, and  
print the document without special  
computer hardware or software required  
for that format (except software that is  
readily available to members of the public  
without payment of any fee) and without  
payment of a fee to the 501(c)(3)  
Making the Annual Returns  
Widely Available  
A 501(c)(3) organization doesn’t have to  
provide copies of its annual returns if it  
makes these documents widely available.  
However, it must still allow public  
organization or to another entity  
maintaining the web page.  
Any person who willfully fails to  
comply with the section 6104(d) public  
inspection requirements is subject to an  
additional penalty of $5,000.  
3. The reliability and accuracy  
requirements are met if the entity  
maintaining the Internet page:  
inspection by office visitation.  
How does a 501(c)(3) organization  
make its annual returns widely availa-  
ble? A 501(c)(3) organization's annual  
returns are widely available if it meets all  
four of the following requirements.  
Has procedures for ensuring the  
reliability and accuracy of the document  
that it posts on the page;  
34  
Index  
A
Estimated Tax Payments 12  
Estimated Tax Penalty 13  
Exceptions and special rules:  
Other tax amounts:  
Excess distribution from a passive  
foreign investment company  
(PFIC) 10  
Accounting method 6  
Accounting Period 7  
Member income of mutual or  
cooperative electric companies.:  
Alcohol and Cellulosic Biofuel Fuels  
P
Income from qualifying shipping  
activities. 15  
Credit 19  
Partnerships 18  
Alternative Minimum Tax (Trusts  
Passive loss and at-risk  
limitations. 15  
Only) 11  
Passive foreign investment company  
(PFIC) shareholders 19  
Amortization 21  
Exploited Exempt Activity Income,  
Payment card and third party network  
Annual return 30  
Other Than Advertising Income 27  
transactions 16  
Appendix A. Definitions 30  
Proxy Tax 10  
Appendix B. Charitable Contribution  
F
Public Inspection Requirements of  
Deduction 31  
Section 501(c)(3) 8  
Foreign Organizations 12  
Foreign Tax Credit 11  
Appendix C. Public Inspection of  
Form 990-T Returns Filed by  
Purpose of Form 1  
Section 501(c)(3) Organizations 8  
R
G
B
Recapture of investment credit:  
Gain or loss on disposition of certain  
Backup Withholding 12  
brownfield property 17  
Recapture of low-income housing  
credit:  
Biodiesel and Renewable Diesel Fuels  
General Business Credit:  
Credit 19  
Interest due under the look-back  
method. 11  
Refundable small employer tax  
credit 11  
Recoveries of bad debts deducted 19  
Rent Income 23  
C
Gross Receipts or Sales:  
Advance payments:  
Installment sales  
Capital Gain Net Income 17  
Reporting 990-T Information on Other  
Capital Loss Deduction for Trusts 18  
Returns 8  
Certain Activities and Other  
Rounding Off to Whole Dollars 8  
I
Information:  
Signature or other authority over a  
financial account in a foreign  
country:  
Income from property financed with  
S
qualified 501(c)(3) bonds 19  
S Corporations:  
Income or (Loss) From a Partnership  
Report of Foreign Bank and  
Financial Accounts (FBAR)  
or an S Corporation 18  
Qualified tax-exempts:  
Exception 18  
Interest 21  
Change in address:  
Archer MSA 8  
Interest, Annuities, Royalties, and  
Rents From Controlled  
Organizations:  
Section 199A Deduction 10  
Section 263A Uniform Capitalization  
Coverdell ESA 8  
Rules:  
IRA, SEP, or SIMPLE 8  
Qualified ABLE Program 8  
Qualified State Tuition Program 8  
Roth IRA 8  
Controlled organization 25  
Qualifying specified payment 25  
Specified payment 25  
Indirect expenses 20  
Interest expense 20  
Section 481(a) adjustment 7  
Section 501(c)(3) organization 30  
Section 965 Payments:  
Net tax liability in installments 12  
Separate trades or businesses:  
Dual-use property:  
L
Charitable contributions 31  
Charitable Contributions 9  
Limitations on Deductions:  
Compensation of Officers, Directors,  
Activities Lacking a Profit Motive 19  
and Trustees 27  
Deductions Related to Property  
Leased to Tax-Exempt Entities 19  
Consolidated periodicals 27  
Cost of Goods Sold 23  
Which Parts to Complete 14  
Substantiation requirements 31  
Supplemental Information:  
Signature:  
Preference Items 19  
Credit for Prior Year Minimum Tax 11  
Section 263A Uniform Capitalization  
Rules 19  
Credit for Small Employer Health  
Insurance Premiums:  
Transactions Between Related  
Taxpayers 19  
Paid preparer 13  
Tax-exempt eligible small  
employer 12  
Special rule for IRA trusts 13  
N
T
D
Name and Address:  
Tax and Payments 11  
Tax Due:  
Debt-financed property  
Change of name. 8  
disposition 17  
Net Gain or (Loss) 18  
Pay by credit or debit card:  
IRS.gov/E-pay 13  
Deduction for Net Operating Loss 9  
Deductions Not Taken Elsewhere:  
Directly connected expenses 19  
Depletion 22  
Net Operating Loss (NOL) 22  
Nonaccrual experience method 17  
Tax on Noncompliant Facility  
Income 11  
O
Tax Rate Schedule for Trusts 10  
Disposition of property received from  
Total of Unrelated Business Taxable  
Income Computed From all  
Organizations described in section  
taxable subsidiary 17  
501(c)(19) 19  
Disregarded entity 2  
Unrelated Trades or Businesses 9  
Organizations Taxable as  
Total Tax 12  
Corporations. 10  
E
Total Unrelated Business Taxable  
Other Credits 11  
Employer-owned life insurance  
Income 9  
Other Deductions:  
contracts 19  
Travel, Meals, and Entertainment 20  
Extraterritorial income exclusion 22  
35  
 
Trust filers only:  
Unrelated Trade or Business Income:  
Who Must File 1  
Qualified Business Income Deduction:  
Purpose of the Schedule 14  
Determines the unrelated business  
income separately for each  
W
unrelated trade or business 10  
When are section 263A capitalized  
costs deductible:  
U
Exceptions 20  
Unrelated Debt-Financed Income 24  
36