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Form 990 Instructions for Schedule A

Instructions for Schedule A (Form 990 or Form 990-EZ), Public Charity Status and Public Support

Rev. 2023

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Department of the Treasury  
Internal Revenue Service  
2023  
Instructions for Schedule A  
(Form 990)  
Public Charity Status and Public Support  
Section references are to the Internal Revenue Code unless  
otherwise noted.  
If the accounting method the organization used in  
completing the 2022 Schedule A (Form 990) was different  
from the accounting method checked on the 2023 Form 990,  
Part XII, line 1, or the 2023 Form 990-EZ, line G, the  
organization shouldn't report in either Part II or Part III the  
amounts reported in the applicable columns of the 2022  
Schedule A (Form 990). Instead, the organization should  
report all amounts in Part II or Part III using the accounting  
method checked on the 2023 Form 990, Part XII, line 1, or the  
2023 Form 990-EZ, line G.  
Future developments. For the latest information about  
developments related to Form 990 and its instructions, such  
as legislation enacted after they were published, go to  
General Instructions  
Note. Terms in bold are defined in the Glossary of the  
Instructions for Form 990, Return of Organization Exempt  
From Income Tax.  
If the organization changed its accounting method  
from a prior year, it should provide an explanation in  
Schedule O (Form 990), Supplemental Information to  
TIP  
Form 990 or 990-EZ.  
Purpose of Schedule  
Example 1. An organization checks “Cash” on Form 990,  
Part XII, line 1. It should report the amounts in Part II or Part III  
using the cash method. If the organization filed a 2022  
Schedule A (Form 990) using the cash method, it should  
report in the 2019 through 2022 columns on the 2023  
Schedule A (Form 990) the same amounts that it reported in  
the 2019 through 2022 columns on the 2022 Schedule A  
(Form 990).  
Example 2. An organization checks “Accrual” on Form  
990, Part XII, line 1. The organization reports grants on Form  
990, Part VIII, line 1, in accordance with the Financial  
Accounting Standards Board FASB ASC 958 (see the  
instructions for Form 990, Part VIII, line 1). During the year,  
the organization receives a grant to be paid in future years.  
The organization should report the grant's present value on  
the 2023 Schedule A (Form 990). The organization should  
report accruals of present value increments to the unpaid  
grant on Schedule A (Form 990) in future years.  
Schedule A (Form 990) is used by an organization that files  
Form 990, Return of Organization Exempt From Income Tax,  
or Form 990-EZ, Short Form Return of Organization Exempt  
From Income Tax, to provide the required information about  
public charity status and public support.  
Who Must File  
An organization that answered “Yes” to Form 990, Part IV,  
line 1, must complete and attach Schedule A (Form 990) to  
Form 990. Any section 501(c)(3) organization (or  
organization treated as such) that files a Form 990-EZ must  
complete and attach this schedule to Form 990-EZ. These  
include:  
Organizations that are described in section 501(c)(3) and  
are public charities;  
Organizations that are described in sections 501(e),  
501(f), 501(j), 501(k), or 501(n); and  
Nonexempt charitable trusts described in section  
4947(a)(1) that aren’t treated as private foundations.  
If an organization isn’t required to file Form 990 or 990-EZ  
but chooses to do so, it must file a complete return and  
provide all of the information requested, including the  
required schedules.  
Specific Instructions  
Part I. Reason for Public Charity  
Status  
Any organization that is exempt from tax under  
section 501(c)(3) but is a private foundation and not a  
public charity shouldn't file Form 990, Form 990-EZ,  
TIP  
Lines 1–12 (in general)  
Check only one of the boxes on lines 1 through 12 to indicate  
the reason the organization is a public charity for the tax  
year. The reason can be the same as stated in the  
organization's tax-exempt determination letter from the IRS  
(“exemption letter”) or subsequent IRS determination letter, or  
it can be different. An organization that doesn't check any of  
the boxes on lines 1 through 12 shouldn't file Form 990, Form  
990-EZ, or Schedule A (Form 990) for the tax year, but  
should file Form 990-PF instead.  
or Schedule A (Form 990), but should file Form 990-PF,  
Return of Private Foundation or Section 4947(a)(1) Trust  
Treated as Private Foundation. See the instructions to Part I.  
Accounting Method  
When completing Schedule A (Form 990), the organization  
must use the same accounting method it checked on Form  
990, Part XII, line 1, or Form 990-EZ, line G. The organization  
must use this accounting method in reporting all amounts on  
Schedule A (Form 990), regardless of the accounting method  
it used in completing Schedule A (Form 990) for prior years,  
except that in Part V, Sections D and E, distributions must be  
reported on the cash receipts and disbursements method.  
If an organization believes there is more than one reason  
why it is a public charity, it should check only one box but can  
explain the other reasons it qualifies for public charity status  
in Part VI. An organization that claims a public charity status  
Nov 14, 2023  
Cat. No. 11294Q  
other than section 170(b)(1)(A)(vi) can also demonstrate that  
it qualifies under section 170(b)(1)(A)(vi) by completing Part  
II; it may want to do so for purposes such as qualifying for the  
first Special Rule in Schedule B (Form 990), Schedule of  
Contributors, by meeting the 331/3% support test.  
509(a)(3). Based on Rev. Proc. 2023-5, the organization  
submitted a Form 8940 request to the IRS to change its  
classification to public charity status under section 509(a)(2).  
For the tax year, it meets the requirements of section 509(a)  
(2). The organization received a determination letter that it  
has been reclassified as a public charity under section 509(a)  
(2). The organization should check the box on line 10 and  
complete Part III.  
Example 5. The organization received an exemption  
letter that it is a public charity under section 170(b)(1)(A)(vi).  
For the tax year, it doesn't meet the requirements for public  
charity status under section 170(b)(1)(A)(vi) or 509(a)(2), or  
as a supporting organization under section 509(a)(3). Nor  
does it meet the requirements for public charity status under  
any other provision of the Internal Revenue Code. The  
organization is a private foundation and shouldn't file Form  
990, Form 990-EZ, or Schedule A (Form 990) for the tax year  
but should file Form 990-PF instead.  
The IRS doesn't update its records on an organization's  
public charity status based on a change the organization  
makes on Schedule A (Form 990). Thus, an organization that  
checks a public charity status different from the reason stated  
in its exemption letter or subsequent determination letter,  
although not required, may submit a request to the IRS  
Exempt Organizations Determinations Office for a  
determination letter confirming that it qualifies for the new  
public charity status if the organization wants the IRS records  
to reflect that new public charity status (also referred to as  
“private foundation status”). See the Instructions for Form  
8940, Request for Miscellaneous Determination. You must  
complete and submit Form 8940 with payment of a user fee  
through Pay.gov. The user fees are listed in Rev. Proc.  
2023-5, 2023-1 I.R.B. 265 (updated annually).  
Example 6. The organization received an exemption  
letter that it is a supporting organization under section  
509(a)(3). The letter doesn't state which type of supporting  
organization it is. The organization should review the  
instructions for lines 12a through 12d to determine which  
type best describes the organization. The organization may  
wish to file Form 8940 to request a determination of type.  
A subordinate organization of a group exemption that  
is filing its own return, but hasn't received its own tax  
exemption determination letter from the IRS, should check  
the public charity status box which most accurately describes  
its public charity status.  
Line 1. Check the box for a church, convention of churches,  
or association of churches. Pub. 1828, Tax Guide for  
Churches and Religious Organizations, lists certain  
characteristics generally attributed to churches. These  
attributes of a church have been developed by the IRS and  
by court decisions. They include: distinct legal existence,  
recognized creed and form of worship, definite and distinct  
ecclesiastical government, formal code of doctrine and  
discipline, distinct religious history, membership not  
associated with any other church or denomination,  
organization of ordained ministers, ordained ministers  
selected after completing prescribed courses of study,  
literature of its own, established places of worship, regular  
congregations, regular religious services, Sunday schools for  
the religious instruction of the young, and schools for the  
preparation of its ministers. The IRS generally uses a  
combination of these characteristics, together with other facts  
and circumstances, to determine whether an organization is  
considered a church for federal tax purposes.  
Line 2. Check the box for a school whose primary function  
is the presentation of formal instruction, which regularly has a  
faculty, a curriculum, an enrolled body of students, and a  
place where educational activities are regularly conducted. A  
private school must have a racially nondiscriminatory policy  
toward its students. For details about these requirements,  
see Schedule E (Form 990), Schools, and its related  
instructions.  
An organization that doesn't know the public charity status  
stated in its exemption letter or subsequent determination  
letter should call the Exempt Organizations Customer  
Account Services toll free at 877-829-5500 or write to:  
Internal Revenue Service  
TE/GE Customer Account Services  
P.O. Box 2508  
Cincinnati, OH 45201  
See the following examples.  
Example 1. The organization received an exemption  
letter that it is a public charity under section 170(b)(1)(A)(vi).  
For the tax year, it meets the requirements for public charity  
status under section 170(b)(1)(A)(vi). The organization  
should check the box on line 7 and complete Part II.  
Example 2. The organization received an exemption  
letter that it is a public charity under section  
170(b)(1)(A)(vi). For the tax year, it doesn't meet the  
requirements for public charity status under section  
170(b)(1)(A)(vi). Instead, it meets the requirements for public  
charity status under section 509(a)(2). The organization  
should check the box on line 10 and complete Part III.  
Example 3. The organization received an exemption  
letter that it is a public charity under section 509(a)(2). For the  
tax year, it doesn't meet the requirements for public charity  
status under section 509(a)(2) or 170(b)(1)(A)(vi). Instead, it  
meets the requirements for public charity status as a  
supporting organization under section 509(a)(3). The  
organization should:  
An organization that checks the box on line 2 must  
also complete Schedule E (Form 990), Schools.  
TIP  
Line 3. Check the box for an organization whose main  
purpose is to provide hospital or medical care. A  
1. Check the box for line 12 and either line 12a, 12b, 12c,  
or 12d;  
rehabilitation institution or an outpatient clinic can qualify as a  
hospital if its principal purposes or functions are the providing  
of hospital or medical care, but the term doesn't include  
medical schools, medical research organizations,  
2. Complete line 12f;  
3. Complete the table on line 12g; and  
4. Complete Part IV and (if applicable) Part V.  
convalescent homes, homes for children or the aged, or  
vocational training institutions for handicapped individuals.  
Example 4. The organization received an exemption  
letter that it is a supporting organization under section  
-2-  
Instructions for Schedule A (Form 990) 2023  
Check the box on line 3 also for a cooperative hospital  
service organization described in section 501(e).  
Line 6. Only a federal, state, or local government or  
governmental unit that has received an exemption letter  
recognizing it as exempt from tax under section 501(c)(3)  
should check this box. See Rev. Rul. 60-384, 1960-2 C.B.  
172.  
Line 7. Check the box and complete Part II if the  
organization meets one of the section 170(b)(1)(A)(vi) public  
support tests. See the instructions for Part II regarding how  
an organization can qualify as a publicly supported  
organization under section 170(b)(1)(A)(vi).  
The definition of hospital for Schedule A (Form 990),  
Part I, is different from the definition for Schedule H  
(Form 990), Hospitals. Accordingly, see Who Must  
TIP  
File in the Instructions for Schedule H (Form 990) about  
whether the organization is also required to complete  
Schedule H (Form 990).  
Line 4. Check the box for an organization whose principal  
purpose or function is to engage in medical research, and  
that is directly engaged in the continuous active conduct of  
medical research in conjunction with a hospital. The hospital  
must be described in section 501(c)(3) or operated by the  
federal government, a state or its political subdivision, a U.S.  
territory or its political subdivision, or the District of Columbia.  
If the organization primarily gives funds to other  
organizations (or grants and scholarships to individuals) for  
them to do the research, the organization isn't a medical  
research organization.  
Line 8. Check the box and complete Part II if the  
organization is a community trust and meets a section  
170(b)(1)(A)(vi) public support test. A community trust is a  
charity that attracts large contributions for the benefit of a  
particular community or area, often initially from a small  
number of donors, and is generally governed by  
representatives of its particular community or area. See  
Regulations sections 1.170A-9(f)(10), (11), and (12).  
A community trust claiming it qualifies as a public  
charity should check the box on line 8 whether it is  
The organization isn't required to be an affiliate of the  
hospital, but there must be a joint effort by the organization  
and the hospital to maintain continuing close cooperation in  
the active conduct of medical research.  
!
CAUTION  
structured as a corporation or as a trust.  
Line 9. Check the box if the organization is an agricultural  
research organization described in section 170(b)(1)(A)(ix)  
operated in conjunction with a land-grant college or university  
or a non-land grant college of agriculture. Enter the name,  
city, and state of the college or university. You don't have to  
complete Part II.  
Line 10. Check the box and complete Part III if the  
organization meets both of the section 509(a)(2) support  
tests. See the instructions for Part III regarding how an  
organization can qualify as a publicly supported organization  
under section 509(a)(2).  
The definition of medical research for Schedule A  
(Form 990), Part I, is different from the definition for  
TIP  
Schedule H (Form 990), Hospitals. Accordingly,  
research that is medical research for purposes of determining  
whether an organization is a medical research organization  
isn't necessarily medical research for Schedule H (Form 990)  
reporting purposes.  
Assets test/expenditure test. An organization qualifies as  
a medical research organization if its principal purpose is  
medical research, and if it devotes more than half its assets,  
or spends at least 3.5% of the fair market value of its  
endowment, directly in conducting medical research. Either  
test can be met based on a computation period consisting of  
the immediately preceding tax year or the immediately  
preceding 4 tax years.  
If an organization doesn't satisfy either the assets test or  
the expenditure test, it can still qualify as a medical research  
organization based on the circumstances involved.  
These tests are discussed in Regulations sections  
1.170A-9(d)(2)(v) and (vi). Under these tests, value the  
organization's assets as of any day in its tax year using the  
same day every year, and value the endowment at fair market  
value using commonly accepted valuation methods. See  
Regulations section 2031.  
Line 5. Check the box and complete Part II if the  
organization receives and manages property for and expends  
funds to benefit a college or university that is owned or  
operated by one or more states or political subdivisions. The  
school must be an organization described in the instructions  
for line 2.  
Expending funds to benefit a college or university includes  
acquiring and maintaining the campus, its buildings and  
equipment, granting scholarships and student loans, and  
making any other payments in connection with the normal  
functions of colleges and universities.  
Line 11. Check the box only if the organization has received  
a ruling from the IRS that it is organized and operated  
primarily to test for public safety.  
Lines 12 and 12a–12d. If the organization is a supporting  
organization, check the box for line 12 and then check the  
appropriate box for line 12a, 12b, 12c, or 12d to indicate the  
type of supporting organization it is. The organization must  
also complete lines 12e and 12f, the table on line 12g, and  
Part IV. If the organization is a Type III non-functionally  
integrated supporting organization, it must also complete  
Part V.  
For more information about supporting organizations, see  
Regulations section 1.509(a)-4 and sections 509(a)(3) and  
509(f). For a brief overview of the requirements for  
qualification as a supporting organization, and the different  
types of supporting organizations, see Pub. 557, Tax-Exempt  
Status for Your Organization, and visit IRS.gov/Charities-Non-  
Use the information later to determine the supporting  
organization's type. If the organization checks the box on  
line 12e, the letter the organization received from the IRS  
identifies its type. If the box checked on any of lines 12a  
through 12d is different from the type stated in the letter (for  
example, because the organization has made significant  
changes to its structure or operations resulting in it no longer  
qualifying as the type of supporting organization indicated in  
its letter), provide an explanation in Part VI. If the organization  
doesn't check the box on line 12e, it should check the box on  
line 12a, 12b, 12c, or 12d that best describes the type of  
supporting organization it is.  
The organization must meet the same public support test  
described later for line 7. See Rev. Rul. 82-132, 1982-2 C.B.  
107.  
-3-  
Instructions for Schedule A (Form 990) 2023  
All supporting organizations, regardless of type, must  
be responsive to the needs or demands of one or  
more supported organizations, and must constitute  
Line 12e. The organization's exemption letter or subsequent  
determination letter may state the type of supporting  
organization it is. If it does, check the box on this line. If the  
letter doesn't state the type, or if the letter states Type III but  
doesn't specify whether functionally integrated or  
!
CAUTION  
an integral part of, or maintain a significant involvement in,  
the operations of one or more supported organizations.  
Although Type III supporting organizations have specific  
“responsiveness” and “integral part” tests that must be met,  
the relationship between a Type I or Type II supporting  
organization and its supported organization(s) must also  
include these responsiveness and integral part  
non-functionally integrated, leave this line blank.  
A grantor to a section 509(a)(3) supporting organization,  
acting in good faith, can rely on this letter in determining  
whether the organization is a Type I, Type II, Type III  
functionally integrated, or Type III non-functionally integrated  
supporting organization until the IRS makes a public  
announcement of the entity’s change in status. See Rev.  
Proc. 2018-32, 2018-23 I.R.B. 739.  
Line 12f. A supporting organization must be organized and  
operated exclusively to support or benefit one or more  
specified publicly supported organizations. Please write in  
the space provided the number of supported organizations.  
Include all supported organizations that the organization was  
organized to support at any time during the tax year, whether  
or not they actually received support during the tax year.  
characteristics. The ability of the supported organization(s) in  
a Type I or Type II relationship effectively to control the  
supporting organization's board generally ensures that these  
characteristics are present. If they aren't present, however,  
don't check any box for lines 12a through 12d. For more  
information, see Regulations sections 1.509(a)-4(f)(3) and  
(4).  
Type I. A Type I supporting organization is operated,  
supervised, or controlled by one or more publicly supported  
organizations. If the organization otherwise qualifies as a  
supporting organization and can answer “Yes” to the following  
question, check the box for Type I.  
Line 12g. An organization checking a box on line 12a, 12b,  
12c, or 12d must complete the table on line 12g.  
Do the supported organizations have a substantial degree  
of direction over the policies, programs, and activities of the  
supporting organization, typically by ensuring that the  
governing body, officers, or membership of the supported  
organizations may regularly appoint or elect a majority of the  
supporting organization's directors or trustees?  
Columns (i) and (ii). Enter the name and employer  
identification number (EIN) for each supported  
organization counted on line 12f. If the organization had  
more than five supported organizations during the tax year,  
enter the additional organizations on duplicate pages of  
Schedule A (Form 990), Part I. Use as many duplicate copies  
as needed, and number each page.  
Type II. A Type II supporting organization is supervised  
or controlled in connection with one or more publicly  
supported organizations. If the organization otherwise  
qualifies as a supporting organization and can answer “Yes”  
to the following question, check the box for Type II.  
Column (iii). For each supported organization named in  
column (i), enter the line number (from lines 1 through 10  
above) that best describes the foundation status of the  
supported organization.  
Do the same persons, such as directors, trustees, and  
officers, supervise or control the supported organization(s)  
and the supporting organization?  
Example 1. If the supported organization is a hospital,  
then that is an organization described in section 170(b)(1)(A)  
(iii), and you should enter “3” in column (iii).  
Example 2. If the supported organization is a federal,  
state, or local governmental unit, or foreign government, then  
that is an organization described in section 170(b)(1)(A)(v),  
and you should enter “6” in column (iii).  
Example 3. If the supported organization is exempt under  
section 501(c)(4), 501(c)(5), or 501(c)(6), but can be  
supported by a supporting organization (see Regulations  
section 1.509(a)-4(k)), enter the line number (from lines 1  
through 10 above) that would describe the section 501(c)(4),  
501(c)(5), or 501(c)(6) organization if it were a section 501(c)  
(3) organization. Identify the specific code section (501(c)(4),  
501(c)(5), or 501(c)(6)) for each such supported organization  
in Part VI.  
Type III—Functionally integrated. Check this box if the  
organization qualifies as a Type III functionally integrated  
supporting organization by meeting the following  
requirements.  
1. The organization meets the notification requirement  
described in Part IV, Section D, line 1;  
2. The organization meets the responsiveness test (both  
the relationship requirement and the significant voice  
requirement) described in Part IV, Section D, lines 2 and 3;  
and  
3. The organization meets one of the alternative integral  
part tests described in Part IV, Section E.  
Type III—Non-functionally integrated. Check this box if  
the organization qualifies as a Type III non-functionally  
integrated supporting organization by meeting the following  
requirements.  
The only correct entry in column (iii) is a line number  
(from lines 1 through 10) that corresponds to the  
!
CAUTION  
description of the supported organization.  
1. The organization meets the notification requirement  
described in Part IV, Section D, line 1;  
Column (iv). Check “Yes” if the supported organization  
named in column (i) is specifically named as a supported  
organization in the organization's declaration of trust, articles  
of incorporation, or other governing document. If the  
supported organization is not named in the organizing  
documents, check “No” and explain why in Part VI.  
2. The organization meets the responsiveness test (both  
the relationship requirement and the significant voice  
requirement) described in Part IV, Section D, lines 2 and 3;  
and  
3. The organization meets the integral part test by  
meeting either (a) the distribution and attentiveness  
requirements described in Part V, or (b) the alternative  
integral part test for certain trusts in existence on November  
20, 1970, described in Part V, line 1.  
Column (v). Enter the total amount of monetary support  
paid to, or for the benefit of, the supported organization  
named in column (i) during the tax year. Such monetary  
support may include making payments to or for the use of  
individual members of the charitable class benefited by the  
-4-  
Instructions for Schedule A (Form 990) 2023  
supported organization (such as scholarships), and to 501(c)  
(3) public charities operated, supervised, or controlled  
directly by or in connection with the supported organization.  
See Regulations section 1.509(a)-4(e). If no monetary  
support was provided during the tax year, enter “0”.  
admissions, merchandise, services, or the use of facilities in  
a related activity, report the membership fees on line 12. To  
the extent that the membership fees are payments to  
purchase admissions, merchandise, services, or the use of  
facilities in an unrelated business activity, report the  
membership fees on line 9. See Regulations section  
1.170A-9(f)(7)(iv). Include qualified sponsorship payments  
under section 513(i).  
Column (vi). In this column, the organization may (but  
isn't required to) provide an estimate of the fair market value  
of goods, other property, services, and use of facilities that is  
provided to or for the benefit of the supported organizations  
during the tax year. Describe in Part VI any such goods, other  
property, services, and use of facilities, whether or not an  
amount is reported for them in column (vi).  
Noncash contributions. Use any reasonable method to  
determine the value of noncash contributions reported on  
line 1.  
Don't report any donations of services (such as the value  
of donated advertising space or broadcast air time) or  
donations of use of materials, equipment, or facilities, on  
line 1 as gifts, grants, or contributions. Donated services and  
facilities from a governmental unit only are reported on  
line 3.  
Loss on uncollectible pledge. If an organization records  
a loss on an uncollectible pledge that it reported on a prior  
year's Schedule A (Form 990), it should deduct that loss from  
the contribution amount for the year in which it originally  
counted that contribution as revenue. For example, if in the  
prior tax year the organization reported a pledged  
contribution with a then-present value of $50,000 in Part II,  
line 1, column (e), but learned during the current tax year that  
it wouldn't receive any of that pledged contribution, it should  
deduct the $50,000 from the amount reported in Part II,  
line 1, column (d), for the prior tax year.  
Support from a governmental unit. Include on line 1  
support received from a governmental unit. This includes  
contributions, but not gross receipts from exercising or  
performing the organization's tax-exempt purpose or  
function, which should be reported on line 12. An amount  
received from a governmental unit is treated as gross  
receipts from exercising or performing the organization's  
tax-exempt purpose or function if the purpose of the payment  
is primarily to serve the direct and immediate needs of the  
payor governmental unit, and is treated as a contribution, if  
the purpose is primarily to provide a direct benefit to the  
public. For example, a payment to maintain library facilities  
that are open to the public should be treated as a  
Part II. Support Schedule for  
Organizations Described in Sections  
170(b)(1)(A)(iv) and 170(b)(1)(A)(vi)  
If the organization checked a box in Part I, on line 5,  
7, or 8, it should complete Part II and insert the  
!
CAUTION  
appropriate dollar amounts. Don't leave Part II blank  
or report only zeros if the organization had any support during  
the period. If the organization checks the box in Part II, on  
line 13, it should stop there and not complete the rest of Part  
II.  
If the organization checked a box in Part I, on line 5,  
7, or 8 and also checks the box in Part II, on line 18,  
the organization should complete Part III to determine  
TIP  
if it qualifies as a publicly supported organization under  
section 509(a)(2). If it does qualify, the organization should  
instead check the box in Part I, on line 10.  
Public Support Test. For an organization to qualify as a  
publicly supported organization under section 170(b)(1)(A)  
(vi), either:  
331/3% or more of its total support must come from  
governmental units, contributions from the general public,  
and contributions or grants from other public charities; or  
10% or more of its total support must come from  
governmental units, contributions from the general public,  
and contributions or grants from other public charities and the  
facts and circumstances indicate it is a publicly supported  
organization.  
contribution. See Regulations section 1.170A-9(f)(8) and  
Rev. Rul. 81-276, 1981-2 C.B. 128. Refer to the instructions  
for Form 990, Part VIII, lines 1e and 2, for more examples  
addressing the distinction between government payments  
that are contributions and government payments that are  
gross receipts from activities related to the organization's  
tax-exempt purpose or function. Medicare and Medicaid  
payments are treated as gross receipts from patients rather  
than as contributions from the government payor for  
purposes of the public support test. See Rev. Rul. 83-153,  
1983-2 C.B. 48.  
Note. An organization won't meet either of these public  
support tests if almost all of its support comes from gross  
receipts from related activities and an insignificant amount of  
its support comes from governmental units and  
contributions made directly or indirectly by the general  
public.  
Public support is measured using a 5-year computation  
period that includes the current and 4 prior tax years  
(including short years). If the organization's current tax year  
or any of its 4 prior tax years were short years, explain in Part  
VI.  
The Coronavirus Aid, Relief, and Economic Security  
Act (CARES Act) established the Paycheck  
TIP  
Protection Program (PPP) to provide loans to small  
If the organization wasn't a section 501(c)(3) organization  
for the entire 5-year period in Part II, report amounts only for  
the years the organization was a section 501(c)(3)  
organization.  
businesses as a direct incentive to keep their workers on the  
payroll. The loans are forgiven if all employee retention  
criteria are met and the funds are used for eligible expenses.  
Amounts of PPP loans that are forgiven may be reported on  
line 1 as contributions from a governmental unit in the tax  
year when the amounts are forgiven or at such other time as  
provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.  
Line 1. Don't include any “unusual grants.See Unusual  
grants, later. Include membership fees only to the extent to  
which the fees are payments to provide support for the  
organization rather than to purchase admissions,  
Unusual grants. Unusual grants are generally substantial  
contributions and bequests from disinterested persons and  
are:  
merchandise, services, or the use of facilities. To the extent  
that the membership fees are payments to purchase  
-5-  
Instructions for Schedule A (Form 990) 2023  
1. Attracted because of the organization's publicly  
supported nature,  
revenue or assets on Form 990-EZ, explain in Part VI the  
basis for characterizing such transfers as contributions but  
not as revenue or assets. For example, if an organization is a  
community foundation that receives and holds a cash transfer  
for another tax-exempt organization and reports contributions  
of such property on Schedule A (Form 990), Part II, line 1,  
without reporting it on Form 990 as revenue in Part VIII or  
assets in Part X, explain the basis for characterizing the  
property as contributions but not as revenue or assets.  
Line 2. Enter tax revenue levied for the organization's benefit  
by a governmental unit and either paid to the organization  
or expended on its behalf. Report this amount whether or not  
the organization includes this amount as revenue on its  
financial statements or elsewhere on Form 990 or 990-EZ.  
2. Unusual and unexpected because of the amount, and  
3. Large enough to endanger the organization's status as  
normally meeting either the 331/3% public support test or the  
10%-facts-and-circumstances test.  
For a list of other factors to be considered in determining  
whether a grant is an unusual grant, see Regulations section  
1.509(a)-3(c)(4).  
An unusual grant is excluded even if the organization  
receives or accrues the funds over a period of years.  
Don't report gross investment income items as unusual  
grants. Instead, include all investment income on line 8.  
Line 3. Enter the value of services or facilities furnished by a  
governmental unit to the organization without charge. Don't  
include the value of services or facilities generally furnished  
to the public without charge. For example, include the fair  
rental value of office space furnished by a governmental unit  
to the organization without charge but only if the  
See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations  
section 1.170A-9(f)(6)(ii); and Regulations sections  
1.509(a)-3(c)(3) and (4) for details about unusual grants.  
Include in Part VI a list showing the amount, but not the  
grantor, of each unusual grant actually received each year (if  
the cash accounting method is used) or accrued each year (if  
the accrual accounting method is used).  
governmental unit doesn't generally furnish similar office  
space to the public without charge. Report these amounts  
whether or not the organization includes these amounts as  
revenue on its financial statements or elsewhere on Form 990  
or 990-EZ.  
Don't include the names of the grantors because Part  
VI will be made available for public inspection.  
!
CAUTION  
Unusual grants recordkeeping. An organization that  
received any unusual grants during the 5-year period should  
also keep for its records a list showing, for each year, the  
name of the contributor, the date and amount of the grant,  
and a brief description of the grant. If the organization used  
the cash method for the applicable year, show only the  
amounts the organization actually received during that year. If  
the organization used the accrual method for the applicable  
year, show only the amounts the organization accrued for that  
year. An example of this list is given below.  
Line 5. Enter in column (f) the portion of total contributions  
by each individual, trust, or corporation included on line 1 for  
the years reported that exceeds 2% of the amount reported in  
line 11, column (f). In applying the 2% limitation, all  
contributions made by a donor and by any person or persons  
standing in a relationship to the donor that is described in  
sections 4946(a)(1)(C) through (a)(1)(G) and the related  
regulations (for example, spouses and certain other family  
members, and entities where ownership or control interests  
exceed a threshold level) will be treated as made by one  
person. However, the 2% limitation doesn't apply to  
contributions from organizations qualifying as publicly  
supported organizations under section 170(b)(1)(A)(vi),  
governmental units described in section 170(b)(1)(A)(v), and  
other organizations, such as the following, but only if they  
also qualify as publicly supported organizations under  
section 170(b)(1)(A)(vi).  
Don't file this list with the organization's Form 990 or  
990-EZ because it may be made available for public  
!
CAUTION  
inspection.  
Line 1. Example—List of unusual grants  
Description  
Year  
2023  
Churches described in section 170(b)(1)(A)(i),  
Educational institutions described in section 170(b)(1)(A)  
Undeveloped land  
Name  
Mr. Distinguished Donor  
(ii),  
Hospitals described in section 170(b)(1)(A)(iii),  
Date of Grant  
2023  
January 15,  
Organizations operated for the benefit of a college or  
university owned or operated by a governmental unit  
described in section 170(b)(1)(A)(iv), and  
Amount of Grant  
$600,000  
Agricultural research organizations described in section  
170(b)(1)(A)(ix).  
Conservation easements and qualified conservation  
contributions. The organization must report any qualified  
conservation contributions and contributions of conservation  
easements consistently with how it reports revenue from  
such contributions in its books, records, and financial  
statements and in Form 990, Part VIII, Statement of Revenue.  
The organization should keep for its records a list showing  
the name of and amount contributed by each donor (other  
than a governmental unit or publicly supported  
organization) whose total gifts during the years reported  
exceed 2% of the amount reported in line 11, column (f). An  
example of this list is given later.  
Reporting contributions not reported as revenue. If the  
organization reports any contributions on line 1 of  
Don't file this list with the organization's Form 990 or  
990-EZ because it may be made available for public  
!
Schedule A (Form 990), Part I, that it doesn't report on Form  
990 as revenue in Part VIII or as assets in Part X, or as  
CAUTION  
inspection.  
-6-  
Instructions for Schedule A (Form 990) 2023  
Line 5. Example—List of donors other than governmental units and publicly supported organizations  
Assumption: 2% of the amount on Schedule A (Form 990), Part II, line 11, column (f), is $12,000.  
Contributors whose total gifts from 2018 through 2022 were in excess of the 2% limitation  
(a)  
(b)  
(c)  
(d)  
(e)  
(f)  
(g)  
Name  
2019  
2020  
2021  
2022  
2023  
Total  
Excess  
contributions  
(column (f)  
minus the 2%  
limitation)  
XYZ Foundation  
$59,000  
$3,000  
$18,000  
$80,000  
$68,000  
$4,000  
Banana Office  
Supply  
$12,000  
$3,000  
$1,000  
$16,000  
Plum Corporation  
John Smith  
$15,000  
$5,000  
$15,000  
$1,000  
$10,000  
$7,000  
$30,000  
$16,000  
$30,000  
$27,000  
$18,000  
$4,000  
$5,000  
$5,000  
$10,000  
Sue Adams  
$10,000  
$18,000  
$15,000  
Raisin Trade  
Assoc.  
$20,000  
Total. Add the items in column (g). Enter the total here and on Part II, column (f), line 5  
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
.
$127,000  
A trade or business in which substantially all work is  
Line 8. Include the gross income from interest, dividends,  
payments with respect to securities loans (section 512(a)(5)),  
rents, royalties, and income from similar sources. Don't  
include on this line payments that result from activities of the  
organization that further its exempt purpose. Instead, report  
these amounts on line 12.  
Line 9. Enter the organization's net income from conducting  
unrelated business activities, whether or not the activities  
are regularly conducted as a trade or business. See sections  
512 and 513 and the applicable regulations. Include  
membership fees to the extent they are payments to  
purchase admissions, merchandise, services, or the use of  
facilities in an activity that is an unrelated business.  
When calculating unrelated business taxable income  
(UBTI) for this purpose, an exempt organization with more  
than one unrelated trade or business may use either its UBTI  
calculated under section 512(a)(6) or its UBTI calculated in  
the aggregate. If a net loss results, enter “0” on this line.  
Line 10. Include all support as defined in section 509(d) that  
isn't included elsewhere in Part II. Explain in Part VI the  
nature and source of each amount reported. Don't include  
gain or loss from amounts reportable on line 12 or from the  
sale of capital assets.  
Line 12. Enter the total amount of gross receipts the  
organization received from related activities for all years  
reported in Part II. The organization won't be treated as  
meeting the section 170(b)(1)(A)(vi), 331/3% public support  
test or the 10%-facts-and-circumstances public support test,  
if almost all of its support consists of gross receipts from  
related activities and an insignificant amount of its support  
comes from governmental units and public contributions.  
See Regulations section 1.170A-9(f)(7)(iii).  
Include on line 12 gross receipts from admissions, sales of  
merchandise, performance of services, or furnishing of  
facilities in any activity which isn't an unrelated trade or  
business (within the meaning of section 513). See section  
509(d)(2). Include membership fees to the extent they are  
payments to purchase admissions, merchandise, services, or  
the use of facilities in a related activity. For example, include  
on this line gross receipts from:  
performed by volunteers (such as book fairs and sales of gift  
wrap paper). See section 513(a)(1).  
A trade or business carried on by the organization primarily  
for the convenience of its members, students, patients,  
officers, or employees. See section 513(a)(2).  
A trade or business which is the selling of merchandise,  
substantially all of which the organization received as gifts or  
contributions. See section 513(a)(3).  
“Qualified public entertainment activities” or “qualified  
convention and trade show activities” of certain  
organizations. See section 513(d).  
Furnishing certain hospital services. See section 513(e).  
A trade or business consisting of conducting bingo  
games, but only if the conduct of such games is lawful. See  
section 513(f).  
Qualified pole rentals by a mutual or cooperative telephone  
or electric company. See section 513(g).  
The distribution of certain low-cost articles incidental to the  
solicitation of charitable contributions (except to the extent  
such gross receipts are properly treated as charitable  
contributions reportable on line 1 rather than as proceeds of  
a sale or exchange), and exchange and rental of members  
lists. See section 513(h).  
Line 13. An organization that checks this box should stop  
here and shouldn't complete the rest of Part II. It shouldn't  
make a public support computation on line 14 or 15 or check  
any of the boxes on lines 16 through 18.  
Example. An organization receives an exemption letter  
from the IRS that it is exempt from tax under section  
501(c)(3) and qualifies as a public charity under section  
170(b)(1)(A)(vi) effective on its date of incorporation. When  
the organization prepares Part II for each of its first 5 tax  
years as a section 501(c)(3) organization, it should check the  
box on line 13 and shouldn't complete the rest of Part II.  
When the organization prepares Part II for its sixth tax year  
and subsequent years, it shouldn't check the box on line 13  
and should complete the rest of Part II.  
-7-  
Instructions for Schedule A (Form 990) 2023  
An organization in its first 5 years as a section 501(c)  
(3) organization should make the public support  
computations on a copy of Schedule A (Form 990)  
Line 18. If the organization didn't check a box on line 13,  
16a, 16b, 17a, or 17b, it doesn't qualify as a publicly  
supported organization under section 170(b)(1)(A)(iv) or  
170(b)(1)(A)(vi) for the 2023 tax year and should check the  
box on this line. If the organization doesn't qualify as a public  
charity under any of the boxes in Part I, lines 1 through 12, it  
is a private foundation as of the beginning of the 2023 tax  
year for filing purposes and shouldn't file Form 990, Form  
990-EZ, or Schedule A (Form 990) for the 2023 tax year.  
Instead, the organization should file Form 990-PF and check  
Initial return of a former public charity on Form 990-PF, at the  
top of page 1.  
TIP  
that it keeps for itself. An organization should carefully  
monitor its public support on an ongoing basis to ensure that  
it will meet a public support test in the sixth year and  
succeeding years.  
Line 14. Round to the nearest hundredth decimal point in  
reporting the percentage of public support. For example, if  
the organization calculates its public support percentage as  
58.3456%, this percentage would be rounded to 58.35%  
when reported on line 14.  
Line 15. For 2023, enter the public support percentage from  
the 2022 Schedule A (Form 990), Part II, line 14. Round to  
the nearest hundredth decimal point in reporting the  
percentage of public support.  
Line 16a. If the organization didn't check the box on line 13,  
and line 14 is 331/3% or more, check the box on this line  
and don't complete the rest of Part II. The organization  
qualifies as a publicly supported organization for 2023 and  
2024.  
If Form 990 or 990-EZ is for the organization's sixth  
tax year as a section 501(c)(3) organization, the  
organization should figure the public support  
TIP  
percentage on its Form 990 or 990-EZ for its first 5 tax years  
before it checks the box on line 18. If its public support  
percentage for its first 5 tax years is 331/3% or more, or if it  
meets the 10%-facts-and-circumstances test for its first 5 tax  
years, it will qualify as a public charity for its sixth tax year. If  
the organization qualifies under the 10% test, explain in Part  
VI.  
Line 16b. If the organization didn't check a box on line 13 or  
16a, and line 15 is 331/3% or more, check the box on this  
line and don't complete the rest of Part II. The  
organization qualifies as a publicly supported organization for  
2023.  
If the organization doesn't qualify as a publicly  
supported organization under section 170(b)(1)(A)  
TIP  
(vi), it can complete Part III to determine if it qualifies  
as a publicly supported organization under section 509(a)(2).  
Line 17a. If the organization didn't check a box on line 13,  
16a, or 16b, and line 14 is 10% or more, and if the  
organization meets the facts-and-circumstances test, check  
the box on this line and don't complete the rest of Part  
II. The organization qualifies as a publicly supported  
organization for 2023 and 2024.  
If this box is checked, explain in Part VI how the  
organization meets the facts-and-circumstances test in  
Regulations section 1.170A-9(f)(3). Include the following  
information.  
Part III. Support Schedule for  
Organizations Described in Section  
509(a)(2)  
If an organization checked the box in Part I, for  
line 10, it should complete Part III and insert the  
TIP  
appropriate dollar amounts. Don't leave Part III blank  
or report only zeros if the organization had any support during  
the period. If the organization checks the box in Part III, for  
line 14, it should stop there and not complete the rest of Part  
III.  
Explain whether the organization maintains a continuous  
and bona fide program for solicitation of funds from the  
general public, community, membership group involved,  
governmental units, or other public charities.  
If the organization checked the box in Part I, for  
line 10, and also checks the box in Part III, for line 20,  
the organization should complete Part II to determine  
TIP  
List all other facts and circumstances, including the  
sources of support, whether the organization has a  
governing body that represents the broad interests of the  
public, and whether the organization generally provides  
facilities or services directly for the benefit of the general  
public on a continuing basis.  
if it qualifies as a publicly supported organization under  
section 170(b)(1)(A)(vi). If it does qualify, the organization  
should instead check the box in Part I, for line 5, 7, or 8,  
whichever applies.  
If the organization is a membership organization, explain  
Public Support Test. For an organization to qualify as a  
whether the solicitation for dues-paying members is designed  
to enroll a substantial number of persons from the  
publicly supported organization under section 509(a)(2):  
More than 331/3% of its support normally must come from  
community, whether dues for individual members have been  
fixed at rates designed to make membership available to a  
broad cross-section of the interested public, and whether the  
activities of the organization will likely appeal to persons  
having some broad common interest or purpose.  
gifts, grants, contributions, membership fees, and gross  
receipts from admissions, sales of merchandise,  
performance of services, or furnishing of facilities in an  
activity which isn't an unrelated trade or business under  
section 513; and  
Line 17b. If the organization didn't check a box on line 13,  
16a, 16b, or 17a, and line 15 is 10% or more, and if the  
organization meets the facts-and-circumstances test, check  
the box on this line and don't complete the rest of Part  
II. The organization qualifies as a publicly supported  
No more than 331/3% of its support normally must come  
from gross investment income and net unrelated business  
income (less section 511 tax) from businesses acquired by  
the organization after June 30, 1975.  
Public support is measured using a 5-year computation  
period that includes the current and 4 prior tax years  
(including short years). If the organization's current tax year  
or any of its 4 prior tax years were short years, explain in Part  
VI.  
organization for 2023. If this box is checked, explain in Part VI  
how the organization meets the facts-and-circumstances test  
in Regulations section 1.170A-9(f)(3). Include the same  
information identified in the instructions for Line 17a, earlier.  
-8-  
Instructions for Schedule A (Form 990) 2023  
In Part III, if the organization wasn't a section 501(c)(3)  
organization for the entire 5-year period, report amounts only  
for the years the organization was a section 501(c)(3)  
organization.  
than as contributions from the government payor for  
purposes of the public support test. See Rev. Rul. 83-153,  
1983-2 C.B. 48.  
The Coronavirus Aid, Relief, and Economic Security  
Line 1. Don't include any “unusual grants.See Unusual  
grants, later. Include membership fees only to the extent to  
which the fees are payments to provide support for the  
organization rather than to purchase admissions,  
merchandise, services, or the use of facilities. To the extent  
that the membership fees are payments to purchase  
admissions, merchandise, services, or the use of facilities in  
a related activity, include the membership fees on line 2. See  
Regulations section 1.509(a)-3(h). To the extent that the  
membership fees are payments to purchase admissions,  
merchandise, services, or the use of facilities in an activity  
that isn't an unrelated business under section 513, report  
the membership fees on line 3. To the extent that the  
membership fees are payments to purchase admissions,  
merchandise, services, or the use of facilities in an activity  
that is an unrelated business, report the net amount either on  
line 10b or 11, as appropriate.  
Act (CARES Act) established the Paycheck  
TIP  
Protection Program (PPP) to provide loans to small  
businesses as a direct incentive to keep their workers on the  
payroll. The loans are forgiven if all employee retention  
criteria are met and the funds are used for eligible expenses.  
Amounts of PPP loans that are forgiven may be reported on  
line 1 as contributions from a governmental unit in the tax  
year when the amounts are forgiven or at such other time as  
provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.  
Unusual grants. Unusual grants are generally substantial  
contributions and bequests from disinterested persons and  
are:  
1. Attracted because of the organization's publicly  
supported nature,  
2. Unusual and unexpected because of the amount, and  
3. Large enough to endanger the organization's status as  
Noncash contributions. Use any reasonable method to  
determine the value of noncash contributions reported on  
line 1.  
normally meeting the 331/3% public support test.  
For a list of other factors to be considered in determining  
whether a grant is an unusual grant, see Regulations section  
1.509(a)-3(c)(4).  
Don't report any donations of services (such as the value  
of donated advertising space or broadcast air time) or  
donations of use of materials, equipment, or facilities on  
line 1 as gifts, grants, or contributions. Donated services and  
facilities from a governmental unit are reported on line 5.  
Loss on uncollectible pledge. If an organization records  
a loss on an uncollectible pledge that it reported on a prior  
year's Schedule A (Form 990), it should deduct that loss from  
the contribution amount for the year in which it originally  
counted that contribution as revenue. For example, if in the  
prior tax year the organization reported a pledged  
An unusual grant is excluded even if the organization  
receives or accrues the funds over a period of years.  
Don't report gross investment income items as unusual  
grants. Instead, include all investment income on line 10a.  
See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations  
section 1.170A-9(f)(6)(ii); and Regulations sections  
1.509(a)-3(c)(3) and (4) for details about unusual grants.  
Include in Part VI a list showing the amount, but not the  
grantor, of each unusual grant actually received each year (if  
the cash accounting method is used) or accrued each year (if  
the accrual accounting method is used).  
contribution with a then-present value of $50,000 in Part III,  
line 1, column (e), but learned during the current tax year that  
it wouldn't receive any of that pledged contribution, it should  
deduct the $50,000 from the amount reported in Part III,  
line 1, column (d), for the prior tax year.  
Support from a governmental unit. Include on line 1  
support received from a governmental unit. This includes  
contributions, but not gross receipts from exercising or  
performing the organization's tax-exempt purpose or  
function, which should be reported on line 2. Contributions  
are sometimes difficult to distinguish from such gross  
receipts—the label on the agreement isn't controlling. An  
amount received from a governmental unit is treated as gross  
receipts from exercising or performing the organization's  
tax-exempt purpose or function if the purpose of the payment  
is primarily to serve the direct and immediate needs of the  
payor governmental unit. An amount is treated as a  
Don't include the names of the grantors because Part  
VI will be made available for public inspection.  
!
CAUTION  
Unusual grants recordkeeping. An organization that  
received any unusual grants during the 5-year period, should  
also keep for its records a list showing, for each year, the  
name of the contributor, the date and amount of the grant,  
and a brief description of the grant. If the organization used  
the cash method for the applicable year, show only amounts  
the organization actually received during that year. If the  
organization used the accrual method for the applicable year,  
show only amounts the organization accrued for that year. An  
example of this list is given below.  
Don't file this list with the organization's Form 990 or  
contribution if the purpose of the payment is primarily to  
provide a direct benefit to the public. For example, if a state  
government agency pays an organization to operate an  
institute to train agency employees in the principles of  
management and administration, the funds received should  
be included on line 2 as gross receipts. See Regulations  
section 1.509(a)-3(g). Refer to the instructions for Form 990,  
Part VIII, lines 1e and 2, for more examples addressing the  
distinction between government payments that are  
990-EZ because it may be made available for public  
!
CAUTION  
inspection.  
contributions and government payments that are gross  
receipts from activities related to the organization's  
tax-exempt purpose or function. Medicare and Medicaid  
payments are treated as gross receipts from patients rather  
-9-  
Instructions for Schedule A (Form 990) 2023  
Line 7a. Example—List of amounts received from disqualified persons  
Disqualified Person  
(a) 2019  
(b) 2020  
(c) 2021  
(d) 2022  
(e) 2023  
(f) Total  
David Smith  
Anne Parker  
Total  
$7,000  
$6,000  
$2,000  
$4,000  
$6,000  
$15,000  
$16,000  
$31,000  
$5,000  
$5,000  
$7,000  
$7,000  
$7,000  
$6,000  
A trade or business consisting of conducting bingo  
Line 1. Example—List of unusual grants  
games, but only if the conduct of such games is lawful. See  
section 513(f).  
Description  
Year  
2023  
Qualified pole rentals by a mutual or cooperative telephone  
Undeveloped land  
or electric company. See section 513(g).  
Name  
Mr. Distinguished Donor  
The distribution of certain low-cost articles incidental to the  
solicitation of charitable contributions (except to the extent  
such gross receipts are properly treated as charitable  
contributions reportable on line 1 rather than as proceeds of  
a sale or exchange), and exchange and rental of members  
lists. See section 513(h).  
Date of Grant  
2023  
January 15,  
Amount of Grant  
$600,000  
While the activity of soliciting and receiving qualified  
sponsorship payments is also excluded from unrelated  
business (see section 513(i)), the qualified sponsorship  
payments themselves are treated as charitable contributions  
reportable on line 1.  
Line 4. Enter tax revenue levied for the organization's benefit  
by a governmental unit and either paid to the organization  
or expended on its behalf. Report this amount whether or not  
the organization includes this amount as revenue on its  
financial statements or elsewhere on Form 990 or 990-EZ.  
Line 5. Enter the value of services or facilities furnished by a  
governmental unit to the organization without charge. Don't  
include the value of services or facilities generally furnished  
to the public without charge. For example, include the fair  
rental value of office space furnished by a governmental unit  
to the organization without charge, but only if the  
Conservation easements and qualified conservation  
contributions. The organization must report any qualified  
conservation contributions and contributions of conservation  
easements consistently with how it reports revenue from  
such contributions in its books, records, and financial  
statements and in Form 990, Part VIII, Statement of Revenue.  
Reporting contributions not reported as revenue. If the  
organization reports any contributions on Schedule A (Form  
990), Part III, line 1, that it doesn't report on Form 990, as  
revenue in Part VIII or as assets in Part X, or as revenue or  
assets on Form 990-EZ, explain in Part VI the basis for  
characterizing such transfers as contributions but not as  
revenue or assets. For example, if an organization is a  
community foundation that receives and holds a cash transfer  
for another tax-exempt organization and reports contributions  
of such property on Schedule A (Form 990), Part III, line 1,  
without reporting it on Form 990, as revenue in Part VIII or  
assets in Part X, explain the basis for characterizing the  
property as contributions but not as revenue or assets.  
governmental unit doesn't generally furnish similar office  
space to the public without charge. Report these amounts  
whether or not the organization includes these amounts as  
revenue on its financial statements or elsewhere on Form 990  
or 990-EZ.  
Line 7a. Enter the amounts that are included on lines 1, 2,  
and 3 that the organization received from disqualified  
persons. See the definition of disqualified person in the  
Glossary of the Instructions for Form 990.  
For amounts included on lines 1, 2, and 3 that were  
received from a disqualified person, the organization should  
keep for its records a list showing the name of, and total  
amounts received in each year from, each disqualified  
person. Enter the total of such amounts for each year on  
line 7a. See an example of this list above.  
Line 2. Include gross receipts from admissions,  
merchandise sold, services performed, or facilities furnished  
in any activity that is related to the organization's tax-exempt  
purpose (such as charitable, educational, etc.).  
To the extent that membership fees are payments to  
purchase admissions, merchandise, services, or the use of  
facilities in a related activity, include the membership fees on  
this line 2. See Regulations section 1.509(a)-3(h).  
Line 3. Include gross receipts from activities that aren't an  
unrelated trade or business under section 513, such as:  
A trade or business in which substantially all work is  
performed by volunteers (such as book fairs and sales of gift  
wrap paper). See section 513(a)(1).  
Don't file this list with the organization's Form 990 or  
A trade or business carried on by the organization primarily  
990-EZ because it may be made available for public  
!
for the convenience of its members, students, patients,  
CAUTION  
inspection.  
officers, or employees. See section 513(a)(2).  
A trade or business that is the selling of merchandise,  
Line 7b. For any gross receipts included on lines 2 and 3  
from related activities received from a person or from a  
bureau or similar agency of a governmental unit, other than  
from a disqualified person, that exceed the greater of  
$5,000 or 1% of the amount on line 13 for the applicable year,  
enter the excess on line 7b. The organization should keep for  
its records a list showing, for each year, the name of the  
person or government agency, the amount received during  
substantially all of which the organization received as gifts or  
contributions. See section 513(a)(3).  
“Qualified public entertainment activities” or “qualified  
convention and trade show activities” of certain  
organizations. See section 513(d).  
Furnishing certain hospital services. See section 513(e).  
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Instructions for Schedule A (Form 990) 2023  
Line 7b. Example—List of amounts received from other than disqualified persons  
Year 2023  
(a) Name  
(b) Amount received in  
2023  
(c) 1% of amount on  
line 13 in 2023  
(d) Enter the larger of  
column (c) or $5,000  
(e) 2023 excess  
(column (b) minus  
column (d))  
Word Processing, Inc.  
$25,000  
$2,000  
$5,000  
$20,000  
$20,000  
Enter on Schedule A (Form 990), column (e), line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  
the applicable year, the larger of $5,000 or 1% of the amount  
on line 13 for the applicable year, and the excess, if any. See  
an example of this list above.  
Example. An organization receives an exemption letter  
from the IRS that it is exempt from tax under section  
501(c)(3) and qualifies as a public charity under section  
509(a)(2) effective on its date of incorporation. When the  
organization prepares Part III for its first 5 tax years, it should  
check the box on line 14 and shouldn't complete the rest of  
Part III. When the organization prepares Part III for its sixth  
tax year and subsequent years, it shouldn't check the box on  
line 14 and should complete the rest of Part III.  
Don't file this list with the organization's Form 990 or  
990-EZ because it may be made available for public  
!
CAUTION  
inspection.  
Line 10a. Include the gross income from interest, dividends,  
payments received on securities loans (section 512(a)(5)),  
rents, royalties, and income from similar sources. Don't  
include on this line payments that result from activities of the  
organization that further its exempt purpose. Instead, report  
these amounts on line 2.  
Line 10b. Enter the excess of the organization's unrelated  
business taxable income (UBTI) (as defined in section  
512) from trades or businesses that it acquired or  
commenced after June 30, 1975, over the amount of tax  
imposed on this income under section 511. Include  
membership fees to the extent they are payments to  
purchase admissions, merchandise, services, or the use of  
facilities in an unrelated business activity that is a trade or  
business that was acquired or commenced after June 30,  
1975.  
An organization in its first 5 years as a section 501(c)  
(3) organization should make the public support and  
investment income computations on a copy of  
TIP  
Schedule A (Form 990) that it keeps for itself. An organization  
should carefully monitor its public support on an ongoing  
basis to ensure that it will meet the public support tests in the  
sixth year and succeeding years.  
Line 15. Round to the nearest hundredth decimal point in  
reporting the percentage of public support. For example, if  
the organization calculates its public support percentage as  
58.3456%, this percentage would be rounded to 58.35%  
when reported on line 15.  
Line 16. For 2023, enter the public support percentage from  
2022 Schedule A (Form 990), Part III, line 15. Round to the  
nearest hundredth decimal point in reporting the percentage  
of public support.  
When calculating UBTI for this purpose, an exempt  
organization with more than one unrelated trade or business  
may use either its UBTI calculated under section 512(a)(6) or  
its UBTI calculated in the aggregate.  
Line 17. Round to the nearest whole percentage.  
Line 18. For 2023, enter the investment income percentage  
from the 2022 Schedule A (Form 990), Part III, line 17. Round  
to the nearest whole percentage.  
Line 19a. If the organization didn't check the box on line 14,  
line 15 is more than 331/3%, and line 17 isn't more than  
331/3%, check the box on this line and don't complete  
the rest of this schedule. The organization qualifies as a  
publicly supported organization for 2023 and 2024.  
Line 19b. If the organization didn't check the box on line 14  
or 19a, line 16 is more than 331/3%, and line 18 isn't more  
than 331/3%, check the box on this line and don't  
complete the rest of this schedule. The organization  
qualifies as a publicly supported organization for 2023.  
Line 20. If the organization didn't check the box on line 14,  
19a, or 19b, it doesn't qualify as a publicly supported  
organization under section 509(a)(2) for the 2023 tax year  
and should check the box on this line. If the organization  
doesn't qualify as a public charity under any of the boxes on  
Schedule A (Form 990), Part I, lines 1 through 12, it is a  
private foundation for filing purposes as of the beginning of  
the tax year and shouldn't file Form 990, Form 990-EZ, or  
Schedule A (Form 990) for the 2023 tax year. Instead, the  
organization should file Form 990-PF, and check Initial return  
of a former public charity on Form 990-PF, at the top of  
page 1.  
Line 11. Enter the organization's net income from  
conducting unrelated business activities not included on  
line 10b, whether or not the activities are regularly conducted  
as a trade or business. Don't include net income from  
conducting trades or businesses acquired or commenced by  
the organization prior to July 1, 1975. See sections 512, 513,  
and 514, and the applicable regulations. Include membership  
fees to the extent they are payments to purchase admissions,  
merchandise, services, or the use of facilities in an activity  
that is an unrelated business not included on line 10b.  
When calculating UBTI for this purpose, an exempt  
organization with more than one unrelated trade or business  
may use either its UBTI calculated under section 512(a)(6) or  
its UBTI calculated in the aggregate. If a net loss results,  
enter “0” on this line.  
Line 12. Include all support as defined in section 509(d) that  
isn't included elsewhere in Part III. Explain in Part VI the  
nature and source of each amount reported. Don't include  
gain or loss from the sale of capital assets.  
Line 14. An organization that checks this box should stop  
here and shouldn't complete the rest of Part III. It shouldn't  
make a public support computation on line 15 or 16 or an  
investment income computation on line 17 or 18, or check  
any of the boxes for line 19 or 20.  
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Instructions for Schedule A (Form 990) 2023  
If Form 990 or 990-EZ is for the organization's sixth  
tax year as a section 501(c)(3) organization and it  
checked the box on line 20, it should figure the public  
Regulations section 1.509(a)-4(k) and the instructions for  
Part III. If the organization supports a section 501(c)(4), (5),  
or (6) organization, check “Yes” for line 3a.  
TIP  
support percentage and the investment income percentage  
on its Form 990 for its first 5 tax years. If its public support  
percentage for its first 5 tax years is more than 331/3% and  
the investment income percentage for its first 5 tax years isn't  
more than 331/3%, it will qualify as a public charity for its sixth  
tax year. If the organization qualifies in this manner, explain in  
Part VI.  
Line 3b. If the organization confirmed that the supported  
organization qualified under section 501(c)(4), (5), or (6) and  
met the section 509(a)(2) public support test for its most  
recent tax year, check “Yes” and describe in Part VI how the  
organization made this determination. For example, the  
organization may ask its section 501(c)(4), (5), or (6)  
supported organization to furnish a copy of its IRS  
determination letter and to complete annually a pro forma  
Schedule A (Form 990), Part III, and keep the letter and  
support calculation in the supporting organization’s files.  
If the organization doesn't qualify as a publicly  
supported organization under section 509(a)(2), it  
TIP  
can complete Part II to determine if the organization  
If the supporting organization doesn't annually confirm that  
its supported organization satisfies the section 509(a)(2)  
public support test, it must explain in Part VI how it knows that  
the supported organization would’ve been described in  
section 509(a)(2) if it were described in section 501(c)(3)  
during the tax year.  
Line 3c. Support given to a supported section 501(c)(4), (5),  
or (6) organization must be used solely for charitable  
purposes. If the supporting organization has put into place  
measures to ensure that such support is used solely for  
charitable purposes, check “Yes” and describe those  
measures in Part VI. If not, check “No” and describe in Part VI  
how the supporting organization ensured during the tax year  
that its assets were used solely for charitable purposes.  
qualifies as a publicly supported organization under section  
170(b)(1)(A)(vi).  
Part IV. Supporting Organizations  
Complete the sections of Part IV that correspond below with  
the type of supporting organization indicated on line 12a,  
12b, 12c, or 12d of Part I.  
Type I: Sections A and B;  
Type II: Sections A and C;  
Type III Functionally Integrated: Sections A, D, and E; and  
Type III Non-Functionally Integrated: Sections A and D,  
and Part V.  
Section A. All Supporting Organizations  
Line 4a. A supporting organization can't qualify for Type III  
status in the tax year if any supported organization wasn't  
organized in the United States.  
Lines 4b and 4c. A supporting organization must exercise  
control and discretion over funds granted to an organization  
that isn't exempt under section 501(c)(3). See Rev. Rul.  
68-489, 1968-2 C.B. 210. Also, a domestic charity must  
generally exercise control and discretion over funds granted  
to a foreign organization. See Rev. Rul. 63-252, 1963-2 C.B.  
101, and Rev. Rul. 66-79, 1966-1 C.B. 48.  
Line 1. The organization's articles of incorporation or trust  
instrument must designate the publicly supported  
organization(s) on whose behalf the supporting organization  
is operated. The articles of a Type I or Type II supporting  
organization may designate its supported organization(s)  
either by class or purpose or by name. The articles of a Type  
III supporting organization must designate the supported  
organization(s) by name, unless a historic and continuing  
relationship exists between the organizations.  
Check “Yes” only if the organization supports no  
organization other than those listed by name in its governing  
instrument. If the organization supports any organization not  
specifically listed, check “No” and describe in Part VI how the  
supported organizations are designated. If designated by  
class or purpose, describe the class or purpose. If the  
organization and its supported organization(s) have a historic  
and continuing relationship, explain that relationship. If  
support of one or more organizations is subject to certain  
future contingencies, explain those contingencies, and  
explain what organizations will be supported or benefited if  
those contingencies occur.  
Line 2. If the organization supported any domestic or foreign  
organization (other than an organization described in section  
501(c)(4), (5), or (6)) that didn't have an IRS determination of  
status under section 509(a)(1) or (2), check “Yes” and explain  
in Part VI how the organization determined that the supported  
organization was described in section 509(a)(1) or (2) and  
why the supported organization doesn't have such an IRS  
determination (for example, because it has applied for but not  
yet received such a determination, or it isn't required to obtain  
recognition of its public charity status because it is a church,  
a state university, or described in section 4948(b)).  
Explain in Part VI how the organization retained such  
control and discretion despite being controlled or supervised  
by or in connection with such foreign supported  
organization(s). Also, explain what controls the organization  
used to ensure that all support to the foreign supported  
organization(s) was used exclusively for charitable,  
educational, etc., purposes described in section 170(c)(2)(B)  
if the foreign supported organization doesn't have an IRS  
determination under sections 501(c)(3) and 509(a)(1) or (2).  
Line 5. Supporting organizations may add, substitute, or  
remove supported organizations only in certain limited  
situations. See Regulations section 1.509(a)-4(d). Generally,  
a Type I or Type II supporting organization may add or  
substitute particular supported organizations within the class  
or classes designated in its articles, but may not add or  
substitute supported organizations outside of the designated  
class(es). A Type III supporting organization, which must  
specify its supported organizations by name, may only  
substitute supported organizations if such substitution is  
conditioned upon the occurrence of an event that is beyond  
the control of the supporting organization (such as a  
supported organization’s lapse into private foundation  
status).  
Line 3a. A supporting organization may support an  
organization described in section 501(c)(4), (5), or (6), if the  
supported organization satisfies the public support tests  
applicable to a section 509(a)(2) organization. See  
If the organization has added, substituted, or removed any  
supported organization during the tax year, check “Yes” and  
provide detail in Part VI, including (i) the names and EINs of  
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Instructions for Schedule A (Form 990) 2023  
the organizations added, substituted, or removed; (ii) the  
reasons for each addition, substitution, or removal; (iii) the  
authority under the organization’s organizing document for  
each addition, substitution, or removal; and (iv) an  
explanation of how the action was accomplished (such as by  
amendment to the organizing document substituting a new  
supported organization).  
Line 6. A supporting organization must engage solely in  
activities that support or benefit its supported organization(s).  
In addition to making grants and providing services and  
facilities directly to its supported organization(s), a supporting  
organization may also generally make grants or provide  
services or facilities to (1) individual members of the  
charitable class benefited by its supported organization(s), or  
(2) other supporting organizations that also support or benefit  
its supported organization(s). See Regulations section  
1.509(a)-4(e). If the organization made any grants or  
provided any benefits to any other organization or individual,  
check “Yes” and provide detail in Part VI.  
Lines 7 and 8. Under section 4958(c)(3), any grant, loan,  
compensation, or other similar payment provided by a  
supporting organization to a substantial contributor (defined  
in section 4958(c)(3)(C)), to a family member (defined in  
section 4958(f)(4)), and to a 35% controlled entity of such  
persons, is considered a per se excess benefit in its entirety,  
regardless of the fairness or reasonableness of the payment,  
and is subject to tax under section 4958(a). The same is true  
of any loan by a supporting organization to a disqualified  
person under section 4958 (other than loans to certain  
exempt organizations). If the organization made any such  
payment or loan during the tax year, check “Yes” and report  
the transaction on Schedule L (Form 990), Transactions With  
Interested Persons, Part I. For more information on excess  
benefit transactions generally, see the Instructions for  
Schedule L (Form 990).  
Line 9. A supporting organization may not be controlled by  
disqualified persons, as defined in section 4946. Section  
509(a)(1) or (2) organizations, and foundation managers who  
are disqualified persons only as a result of being foundation  
managers, aren't treated as disqualified persons for this  
purpose. Impermissible control may be direct or indirect. If a  
disqualified person holds any of the interests described on  
line 9b or 9c, or derives personal benefit from any such  
assets, provide detail in Part VI.  
organization loses its status as a supporting organization.  
Such supporting organization must file Form 990-PF unless it  
qualifies as a public charity under section 509(a)(1) or (2).  
Section B. Type I Supporting Organizations  
Line 1. A Type I supporting organization must be operated,  
supervised, or controlled by one or more of its supported  
organizations (the “controlling supported organizations”).  
This means that the controlling supported organizations must  
have a substantial degree of direction over the policies,  
programs, and activities of the supporting organization, and  
the supporting organization in turn must be responsive to the  
needs or demands of the controlling supported  
organizations, and must constitute an integral part of, or  
maintain a significant involvement in, the operations of the  
controlling supported organizations. This relationship is most  
clearly established when one or more supported  
organizations (through their officers, directors, trustees, or  
membership) have the unconditional power to remove and  
replace at least a majority of the supporting organization’s  
directors or trustees at any time. The relationship is also  
commonly established when one or more supported  
organizations have the power to appoint or elect at least a  
majority of the supporting organization’s directors or trustees  
at regular intervals. However, there may be other ways to  
establish this relationship. If the organization relies on other  
ways to establish the relationship, check “No” and describe in  
Part VI how the necessary relationship is established.  
Line 2. The supporting organization may benefit  
organizations that don't participate in the control relationship  
described on line 1, but only if such activity carries out the  
purposes of the controlling supported organizations.  
Section C. Type II Supporting Organizations  
Line 1. A Type II supporting organization must be  
supervised or controlled in connection with its supported  
organization(s). This means that there must be common  
supervision or control by the persons supervising or  
controlling both the supporting organization and the  
supported organization(s) to ensure that the supporting  
organization will be responsive to the needs and  
requirements of the supported organization(s). This  
relationship is most clearly established when the same  
persons serve as all or a majority of the directors or trustees  
of all of the organizations involved. However, there may be  
other ways to establish this relationship. If the organization  
relies on other than overlap of at least a majority of directors  
or trustees of all organizations involved, check “No” and  
describe in Part VI how the necessary relationship is  
established.  
Line 10. Under section 4943(f), a Type II supporting  
organization that accepts a contribution from a person who  
controls the governing body of a supported organization (or  
from a family member of such person, or from a 35%  
controlled entity of such person) is subject to the excess  
business holdings tax under section 4943. All Type III  
non-functionally integrated supporting organizations are also  
generally subject to the tax. For more information about  
excess business holdings, see the Instructions for Form  
4720, Return of Certain Excise Taxes Under Chapters 41 and  
42 of the Internal Revenue Code.  
Section D. All Type III Supporting Organizations  
Line 1. A Type III supporting organization must supply  
annually a written notice, addressed to a principal officer of  
each supported organization, which includes the following.  
1. A description of the type and amount of all support the  
Line 11. Section 509(f)(2) prohibits Type I and Type III  
supporting organizations from accepting a gift or contribution  
from certain persons associated with a supported  
supporting organization provided to the supported  
organization during the supporting organization’s tax year  
preceding the tax year in which the notice is provided.  
organization of such supporting organization. Specifically, if a  
Type I or Type III supporting organization accepts a  
contribution after August 16, 2006, from a person who  
controls the governing body of a supported organization (or  
from a family member of such person, or from a 35%  
controlled entity of such person), then the supporting  
2. A copy of the supporting organization’s most recently  
filed Form 990 (the supporting organization may redact the  
names and addresses of contributors).  
3. A copy of the supporting organization’s updated  
governing documents (including articles of organization,  
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Instructions for Schedule A (Form 990) 2023  
bylaws, and any amendments), to the extent not previously  
provided.  
Support of governmental entity. A Type III supporting  
organization meets the integral part test for a functionally  
integrated supporting organization if it (1) supports at least  
one supported organization that is a governmental entity to  
which the supporting organization is responsive (as  
discussed in the instructions for Section D, Lines 2 and 3,  
earlier), and (2) engages in activities for or on behalf of such  
governmental supported organization that performs the  
functions or carries out the purposes of such governmental  
supported organization and that, but for the involvement of  
the supporting organization, would normally be engaged in  
by the governmental supported organization itself. See  
Notice 2014-4. A Type III supporting organization that claims  
to meet the integral part test for a functionally integrated  
supporting organization by supporting a governmental entity  
must describe in Part VI how it met these requirements for the  
tax year.  
See Regulations section 1.509(a)-4(i)(2). The notice must be  
submitted by the last day of the fifth month of the supporting  
organization's tax year being reported (May 31 for  
calendar-year filers). An organization that doesn't timely  
submit the required information in the required manner  
doesn't qualify as a Type III supporting organization for the  
tax year in which it fails to timely submit.  
State whether during the tax year being reported the  
organization provided a timely notice with the required  
information in the required manner.  
Lines 2 and 3. A Type III supporting organization must be  
responsive to the needs or demands of a supported  
organization. An organization meets this responsiveness test  
with regard to a particular supported organization if:  
Line 2. Activities Test. To meet the activities test of a Type  
III functionally integrated supporting organization,  
substantially all of the supporting organization’s activities  
must (1) directly further the exempt purposes of the  
supported organization(s) to which the supporting  
organization was responsive, and (2) be activities that such  
supported organization(s) would normally be engaged in but  
for the supporting organization’s involvement.  
Direct furtherance. Substantially all of the supporting  
organization’s activities must be “direct furtherance”  
activities. Direct furtherance activities are conducted by the  
supporting organization itself, rather than by a supported  
organization. Holding title to exempt-use assets and  
managing them are direct furtherance activities. Fundraising,  
investing and managing non-exempt-use assets,  
grant-making to organizations, and grant-making to  
individuals (unless it meets the requirements of Regulations  
section 1.509(a)-4(i)(4)(ii)(D)) aren't direct furtherance  
activities.  
But for. In addition, the direct furtherance activities must  
be activities in which, but for the supporting organization’s  
involvement, the supported organization would normally be  
involved.  
Examples include holding and managing facilities used by  
a church for its religious purposes, operating a food pantry for  
a group of churches that normally would operate food  
pantries themselves, and maintaining local parks for a  
community foundation that otherwise would maintain those  
parks. See Regulations section 1.509(a)-4(i)(4)(v) for more  
detailed examples.  
1. The supported organization has an adequate  
relationship with the supporting organization because:  
a. The supported organization regularly appoints or  
elects (whether or not during the tax year) at least one  
officer, director, or trustee of the supporting organization;  
b. At least one member of the governing body of the  
supported organization also serves as an officer, director,  
or trustee of the supporting organization; or  
c. The officers, directors, or trustees of the supporting  
organization and of the supported organization maintain a  
close and continuous working relationship; and  
2. Because of this relationship, the supported  
organization has a significant voice in the supporting  
organization’s investment policies, timing of grants, manner  
of making grants, selection of grant recipients, and other use  
of income or assets (the “significant voice” test).  
In the case of a supporting organization that supported a  
supported organization before November 20, 1970,  
additional facts and circumstances such as a historic and  
continuing relationship between the organizations may also  
be taken into account in considering the responsiveness test.  
If the organization has an adequate relationship with at  
least one supported organization only by means of a “close  
and continuous working relationship” or a “historic and  
continuing relationship,then in Part VI explain the  
relationship and how it has been maintained. Also, all Type III  
supporting organizations that claim to meet the significant  
voice test must describe in Part VI the voice or role of the  
supported organization(s) in directing the supporting  
organization’s use of its income or assets.  
Line 3. Parent of Supported Organizations. To qualify as  
the parent of all the supported organizations, a supporting  
organization must (1) have the power to appoint or elect,  
directly or indirectly, a majority of the officers, directors, or  
trustees of every supported organization; and (2) exercise a  
substantial degree of direction over the policies, programs,  
and activities of every supported organization.  
Section E. Type III Functionally Integrated  
Supporting Organizations  
Line 1. A Type III supporting organization must constitute an  
integral part of one or more of its supported organizations by  
maintaining significant involvement in its operations and  
providing support on which the supported organization is  
dependent. To satisfy this requirement as a Type III  
functionally integrated supporting organization, an  
organization may (a) pass an Activities Test (see the  
instructions for Line 2, later), (b) be the parent of its  
supported organizations (see the instructions for Line 3,  
later), or (c) support one or more governmental entities (see  
Support of governmental entity, later). If the organization  
can't satisfy any of these tests, it may still qualify as a Type III  
non-functionally integrated supporting organization (see Part  
V, later).  
Part V. Type III Non-Functionally  
Integrated 509(a)(3) Supporting  
Organizations  
A Type III supporting organization (other than a Type III  
functionally integrated supporting organization) must  
generally satisfy a distribution requirement described in  
Regulations section 1.509(a)-4(i)(5)(ii) along with an  
attentiveness requirement described in Regulations section  
1.509(a)-4(i)(5)(iii) to meet the integral part test for a Type III  
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Instructions for Schedule A (Form 990) 2023  
relationship. To satisfy the distribution requirement, the  
organization must make a minimum amount (distributable  
amount) of distributions to or for the use of one or more  
supported organizations. Carryovers of excess distributions  
from certain prior years may be used for this purpose.  
Adjusted basis. The adjusted basis for purposes of  
determining gain from the sale or other disposition of  
property is the greater of:  
1. The fair market value of such property on August 17,  
2006, plus or minus all adjustments thereafter and before the  
date of disposition under sections 1011–1023, if the property  
was held continuously from August 17, 2006, to the date of  
disposition.  
2. The adjusted basis under sections 1011–1023, without  
regard to section 362(c). If assets acquired before August 17,  
2006, were subject to depreciation or depletion, to determine  
the adjustments to basis between the date of acquisition and  
August 17, 2006, straight-line depreciation or cost depletion  
must be taken into account. Any other adjustments that  
would’ve been made during such period (such as a change in  
useful life based upon additional data or a change in facts)  
must also be taken into account.  
Sections A through E of Part V show whether the  
organization has satisfied its distribution and attentiveness  
requirements for its tax year. Sections A and B determine the  
organization’s adjusted net income and minimum asset  
amount. These amounts are used in determining the  
distributable amount in Section C. Section D determines the  
organization’s distributions that count toward the distributable  
amount and determines whether the attentiveness  
requirement is met. Section E determines whether the  
distributable amount is satisfied through current distributions  
and prior-year carryovers, and determines carryovers to  
future years.  
A trust is excepted from the general distribution and  
attentiveness requirements (and need not complete Sections  
A through E) if on November 20, 1970, it met and continues  
to meet the requirements set forth in Regulations section  
1.509(a)-4(i)(9). A trust that claims this status by checking  
the box on line 1 at the beginning of Part V must explain in  
Part VI how it meets each of the requirements. A trust that  
has obtained a ruling from the IRS on this issue must so  
indicate in Part VI.  
The adjusted basis for purposes of determining loss is only  
the amount described in item 2 above.  
Line 2. Recoveries of prior-year distributions include the  
following.  
Repayments received of amounts which were taken into  
account as a distribution counting toward the distribution  
requirement in a prior tax year.  
Proceeds from the sale or disposition of property to the  
extent that acquisition of such property was taken into  
account as a distribution counting toward the distribution  
requirement in a prior tax year.  
Section A. Adjusted Net Income  
The principles of section 4942(f) and Regulations section  
53.4942(a)-2(d) apply in determining adjusted net income.  
See Regulations section 1.509(a)-4(i)(5)(ii)(B).  
Prior and current year columns. The organization’s  
adjusted net income for the prior tax year is used in  
determining the organization’s distributable amount for the  
current tax year. The form also allows for reporting the  
organization’s adjusted net income for the current tax year for  
use in next year’s calculations; this reporting is optional but  
may be helpful if the organization anticipates being required  
to complete Part V next year.  
An amount set aside and taken into account as a  
distribution counting toward the distribution requirement in a  
prior tax year to the extent it is determined that such amount  
isn't necessary for the purposes for which it was set aside.  
Line 3. Report all other gross income. Gross income  
includes all amounts derived from, or in connection with,  
property held by the organization (except as specified  
otherwise in the instructions for Line 1). Include income from  
any related or unrelated trade or business. Include income  
from tax-exempt bonds. Don't include the following.  
Gifts, grants, or contributions received.  
Definition. Adjusted net income is gross income for the tax  
year less deductions allowable to a corporation subject to tax  
under section 11, with certain modifications discussed in the  
line instructions later. In computing gross income and  
deductions, the principles of the income tax provisions of the  
Code apply (except to the extent inconsistent with section  
4942 or the underlying regulations), but exclusions,  
Long-term capital gains or losses or net short-term capital  
losses.  
Income received from an estate, unless the estate is  
considered terminated due to a prolonged period of  
administration.  
Distributions from a trust created and funded by another  
person.  
deductions, and credits aren't allowed unless expressly  
provided for under section 4942 or the underlying  
Certain amounts received by an organization in the  
redemption of stock in a corporate disqualified person in  
order to avoid excess business holdings, which are treated as  
not essentially equivalent to a dividend under section 302(b)  
(1) (and thus as amounts received in exchange for the stock,  
giving rise to long-term capital gain or loss) if the conditions  
of Regulations section 53.4942(a)-2(d)(2)(iv) are met.  
regulations. See Regulations section 53.4942(a)-2(d)(1).  
Line 1. Report the organization’s net short-term capital gain,  
if any. Long-term capital gains and losses from the sale or  
disposition of property aren't taken into account in  
determining adjusted net income (unless reportable on line 2  
as recoveries of prior-year distributions). Net short-term  
capital loss can't be carried back or forward to other tax  
years. Amounts treated as long-term capital gains include  
capital gain dividends from a regulated investment company  
and net section 1231 gains (but net section 1231 losses are  
treated as ordinary losses and thus taken into account). If the  
fair market value of property distributed for charitable  
purposes exceeds adjusted basis, the excess isn't deemed  
includible in income.  
Line 5. The deduction for depreciation under section 167 is  
allowed, but only on the basis of the straight-line method. The  
deduction for depletion under section 611 is allowed, but  
without regard to section 613 (percentage depletion).  
Lines 6 and 7. No deduction is allowed except ordinary and  
necessary expenses paid or incurred for the production or  
collection of gross income, or for the management,  
conservation, or maintenance of property held for the  
production of income. Such expenses may include operating  
expenses such as compensation of officers and employees,  
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Instructions for Schedule A (Form 990) 2023  
interest, rent, and taxes. Where only a portion of property  
produces income (or is held for the production of income)  
and the remainder is used for charitable purposes, the  
expenses must be apportioned between exempt and  
non-exempt use on a reasonable basis.  
reasonable method to make this determination if consistently  
used. For example, a value for a particular month might be  
determined by the closing price on the first or last trading day  
of the month or an average of the closing prices on the first  
and last trading days of the month. Market quotations are  
considered readily available if a security is any of the  
following.  
Don't deduct the following.  
Net losses from a related business or other charitable  
Listed on the New York or American Stock Exchange or  
activity that produces gross income (no deduction in excess  
of the income from such activity).  
any city or regional exchange in which quotations appear on  
a daily basis, including foreign securities listed on a  
recognized foreign national or regional exchange;  
Charitable contributions under section 170 or 642.  
Net operating loss carrybacks and carryovers under  
Regularly traded in the national or regional  
section 172.  
over-the-counter market for which published quotations are  
available; or  
Dividends under section 241 and the sections following it  
(the dividends-received deductions for corporations).  
Locally traded, for which quotations can be readily  
Net capital losses (short-term or long-term).  
obtained from established brokerage firms.  
Expenses and interest relating to tax-exempt income under  
section 265 are deductible.  
If securities are held in trust for, or on behalf of, a supporting  
organization by a bank or other financial institution that  
values those securities periodically using a computer pricing  
system, the organization may use that system to determine  
the value of the securities. The system must be acceptable to  
the IRS for federal estate tax purposes.  
Section B. Minimum Asset Amount  
The rules for determining the supporting organization’s  
minimum asset amount are set forth in Regulations sections  
1.509(a)-4(i)(5)(ii)(C) and 1.509(a)-4(i)(8), using valuation  
methods described in Regulations section 53.4942(a)-2(c).  
Line 1b. Figure cash balances on a monthly basis by  
averaging the amount of cash on hand on the first and last  
days of each month. Include all cash balances and amounts,  
even if they may be used for charitable purposes (see the  
instructions for Line 4, later) or set aside and taken as a  
distribution (see the instructions for Section D, Line 5, later).  
Line 1c. The fair market value of assets other than securities  
for which market quotations are readily available is  
determined annually except as described later. The valuation  
may be made by supporting organization employees or by  
any other person even if that person is a disqualified person.  
If the IRS accepts the valuation, it is valid only for the tax year  
for which it is made. A new valuation is required for the next  
tax year.  
Valuation date. An asset required to be valued annually  
may be valued as of any day in the supporting organization's  
tax year, provided the organization values the asset as of that  
date in all tax years. However, a valuation of real estate  
determined on a 5-year basis by a certified, independent  
appraisal (discussed later) may be made as of any day in the  
first tax year of the organization to which the valuation  
applies.  
Proration of value of assets held for part of year or in a  
short tax year. The value of an asset held less than a full  
tax year is prorated by multiplying the value of the asset by a  
fraction, of which the numerator is the number of days the  
organization held the asset during its tax year, and the  
denominator is 365 (366 if the tax year includes February  
29). If the supporting organization has a short tax year, the  
value of all assets is accordingly prorated.  
Prior and current year columns. The organization’s  
minimum asset amount for the prior tax year is used in  
determining the organization’s distributable amount for the  
current tax year. The form also allows for reporting the  
organization’s minimum asset amount for the current tax year  
for use in next year’s calculations; this reporting is optional  
but may be helpful if the organization anticipates being  
required to complete Part V next year.  
Definition. In figuring the minimum asset amount, include  
only assets of the supporting organization that aren't used or  
held for use by the supporting organization (or by a  
supported organization, if the supporting organization  
provides the asset free of charge or at nominal rent) to carry  
out the exempt purposes of the supported organization(s).  
Assets held for the production of income or for investment  
aren't considered to be used directly for charitable functions  
even though the income from the assets is used for charitable  
functions. It is a factual question whether an asset is held for  
the production of income or for investment rather than used  
or held for use directly by the supporting organization or a  
supported organization for charitable purposes. For example,  
an office building used to provide offices for employees  
engaged in managing endowment funds for the supporting  
organization or supported organization isn't considered an  
asset used for charitable purposes.  
Dual-use property. When property is used for both  
charitable and other purposes, the property is considered  
used entirely for charitable purposes if 95% or more of its  
total use is for that purpose. If less than 95% of its total use is  
for charitable purposes, a reasonable allocation must be  
made between charitable and noncharitable use.  
Excluded property. Certain assets (in addition to  
exempt-use assets) are excluded entirely from the  
computation of the minimum asset amount. These include  
charitable pledges and interests in an estate or trust (created  
and funded by another person) prior to distribution to the  
supporting organization.  
5-year valuation for real estate. A written, certified, and  
independent appraisal of the fair market value of any real  
estate, including any improvements, may be determined on a  
5-year basis by a qualified person. The qualified person may  
not be a disqualified person with respect to the supporting  
organization or an employee of the supporting organization.  
Commonly accepted valuation methods must be used in  
making the real estate appraisal. A valuation based on  
acceptable methods of valuing property for federal estate tax  
purposes will be considered acceptable.  
Line 1a. Report on line 1a the average monthly fair market  
value of securities (such as common and preferred stock,  
bonds, and mutual fund shares) for which market quotations  
are readily available. A supporting organization may use any  
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The real estate appraisal must include a closing statement  
that, in the appraiser's opinion, the appraised assets were  
valued according to valuation principles regularly employed  
in making appraisals of such property, using all reasonable  
valuation methods. The supporting organization must keep a  
copy of the independent appraisal for its records. If a  
valuation is reasonable, the organization may use it for the  
tax year for which the valuation is made and for each of the 4  
following tax years.  
Any valuation of real estate by a certified independent  
appraisal may be replaced during the 5-year period by a  
subsequent 5-year certified independent appraisal or by an  
annual valuation, as described earlier. The most recent  
valuation should be used to figure the organization's  
minimum asset amount.  
If the valuation is made according to the above rules, the  
IRS will continue to accept it during the 5-year period for  
which it applies even if the actual fair market value of the real  
estate changes during the period.  
Line 1e. If the fair market value of any securities, real estate  
holdings, or other assets reported on lines 1a and 1c reflects  
a blockage discount, marketability discount, or other  
reduction from full fair market value because of the size of the  
asset holding or any other factor, enter on line 1e the  
aggregate amount of the discounts claimed. Provide an  
explanation in Part VI that includes the following information  
for each asset or group of assets involved.  
necessary to pay expenses and disbursements, then the  
organization may enter the larger amount instead (prorated in  
the case of a short tax year). If the organization uses a larger  
amount, explain why in Part VI.  
Line 7. Enter the amount of recoveries (if any) reportable on  
Section A, line 2.  
Section C. Distributable Amount  
The organization’s distributable amount for the current tax  
year is ordinarily the greater of:  
1. 85% of its adjusted net income for the prior tax year or  
2. Its minimum asset amount for the prior tax year,  
less income taxes imposed on the organization during the  
prior tax year. See Regulations section 1.509(a)-4(i)(5)(ii)(B).  
First tax year. The distributable amount for the first tax year  
that an organization is treated as a non-functionally  
integrated Type III supporting organization is zero rather than  
the amount as ordinarily determined. Such an organization  
should check the box on line 7. For purposes of determining  
whether the organization has an excess of distributions in its  
tax year that can be carried over to future years, the  
distributable amount as ordinarily determined applies to  
every non-functionally integrated Type III supporting  
organization (including an organization that checked the box  
on line 7 for the current year). The distributable amount as  
ordinarily determined is reported in Sections C and E.  
1. A description of the asset or asset group (for example,  
Emergency temporary reduction. In cases of disaster or  
emergency, the IRS may provide for a temporary reduction in  
the distributable amount by publication in the Internal  
Revenue Bulletin. In these cases, the reduced amount should  
be reported on line 6 and the reduction noted in Part VI.  
20,000 shares of XYZ, Inc., common stock);  
2. For securities, the percentage of the total issued and  
outstanding securities of the same class that is represented  
by the organization's holding;  
3. The fair market value of the asset or asset group  
Section D. Distributions  
before any claimed blockage discount or other reduction;  
Section D sets forth the supporting organization’s  
distributions that count toward its distribution requirement,  
and determines whether the attentiveness requirement is  
met. The amount of a distribution made to a supported  
organization is the amount of cash or fair market value of  
property on the date of distribution. The organization must  
use the cash method of accounting for this purpose. See  
Regulations section 1.509(a)-4(i)(6).  
Line 1. Report amounts paid to supported organizations to  
accomplish their exempt purposes. Distributions furthering  
the “exempt” purposes of supported organizations not  
described in section 501(c)(3) refer solely to distributions for  
section 501(c)(3) purposes.  
4. The amount of the discount claimed; and  
5. An explanation of the reason for the discount.  
In the case of securities, there are certain limitations on  
the size of the reduction in value that can be claimed. The  
organization may reduce the fair market value of securities  
only to the extent that it can establish that the securities could  
only be liquidated in a reasonable period of time at a price  
less than the fair market value because:  
The securities are such a large block that liquidation would  
depress the market,  
The securities are in a closely held corporation, or  
The sale would result in a forced or distress sale.  
Any reduction in value of securities may not exceed 10% of  
the fair market value (determined without regard to any  
reduction in value).  
Line 2. Report amounts paid to perform any activity that  
directly furthers exempt purposes of supported organizations  
and that would otherwise normally be engaged in by the  
supported organizations, but only to the extent that expenses  
from the activity exceed income from the activity. See the  
Schedule A (Form 990), Part IV, Section E, Line 2,  
Line 2. Enter the total acquisition indebtedness that applies  
to assets included on line 1 (prorated in the case of assets  
held for a portion of the year or in a short tax year). For details  
on acquisition indebtedness, see section 514(c)(1).  
instructions on “direct furtherance” activities.  
Line 4. Supporting organizations may exclude from the  
minimum asset amount the reasonable cash balances  
necessary to cover current administrative expenses and  
other normal and current disbursements directly connected  
with the charitable, educational, or other similar activities.  
The amount of cash that may be excluded is generally 1.5%  
of the fair market value of all assets (minus any acquisition  
indebtedness). However, if under the facts and  
Line 3. Report reasonable and necessary administrative  
expenses paid to accomplish exempt purposes of supported  
organizations. Don't include expenses incurred in the  
production of investment income.  
Line 4. Report amounts paid to acquire exempt-use assets.  
Such assets must be used (or held for use) to carry out the  
exempt purposes of the supported organizations. The assets  
may be used or held by either the supporting organization or  
one or more supported organizations; if the latter, the  
circumstances an amount larger than the deemed amount is  
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supporting organization must make the asset available to the  
supported organization(s) free of charge or for nominal rent.  
See Regulations section 53.4942(a)-2(c)(3) for further  
discussion of exempt-use assets.  
Line 5. Report qualified amounts set aside for a specific  
project that accomplishes the exempt purposes of a  
supported organization to which the supporting organization  
is responsive. A qualified set-aside counts toward the  
distribution requirement in the tax year set aside but not  
again when paid.  
Approval required. For each set-aside, a supporting  
organization must obtain the written approval of both the  
pertinent supported organization(s) and the IRS. The  
supporting organization must apply to the IRS for approval  
(using Form 8940) before the end of its tax year in which the  
amount is set aside. Explain in Part VI whether the  
organization has requested and obtained the necessary  
approvals for the set-aside. See Regulations section  
1.509(a)-4(i)(6)(v) for more information.  
Line 6. Report any other distributions not described above  
that the organization claims are for the use of its supported  
organizations, and describe such distributions in detail in Part  
VI.  
2. The amount of support received from the supporting  
organization is necessary to avoid the interruption of a  
particular function or activity of the supported organization.  
3. The amount of support received from the supporting  
organization is a sufficient part of the supported  
organization’s total support to ensure attentiveness, based on  
all pertinent facts, including the number of supported  
organizations, the length and nature of the relationship  
between the supporting organization and supported  
organization, and the purpose to which the funds are put. The  
attentiveness of a supported organization is normally  
influenced by the amounts received from the supporting  
organization, but evidence of actual attentiveness to the  
operations (including investments) of the supporting  
organization is of almost equal importance. Where the  
supporting organization supports a particular department or  
school of a university, hospital, or church, the department’s or  
school’s total support is considered instead of the supported  
organization’s total support.  
Amounts received from a supporting organization that are  
held in a donor-advised fund of the supported organization  
are disregarded in determining attentiveness.  
See the examples in Regulations section 1.509(a)-4(i)(5)  
(iii)(D).  
Lines 8–10. Report on line 8 the amount of distributions  
reported on line 1 to supported organizations that met the  
attentiveness and responsiveness tests, discussed later, and  
provide in Part VI the supplemental information, discussed  
later.  
Responsiveness test. A supporting organization is  
“responsive” to the needs and demands of a supported  
organization if it meets the responsiveness test set forth in  
the instructions for Part IV, Section D, Lines 2 and 3, with  
respect to the supported organization.  
A Type III non-functionally integrated supporting  
organization must distribute at least one-third of its  
distributable amount each tax year to one or more supported  
organizations that are “attentive” to its operations and to  
which the supporting organization is “responsive” (as  
described later); thus, the line 10 amount must be at least  
0.333. Carryovers of excess distributions from prior years  
don't count toward the attentiveness requirement.  
If the line 10 amount is less than one-third (that is, the  
amount of distributions to supported organizations that met  
both the attentiveness test and responsiveness test is less  
than one-third of the distributable amount), then the  
organization doesn't qualify as a Type III non-functionally  
integrated supporting organization for the tax year. See  
Regulations sections 1.509(a)-4(i)(5)(i) and (iii). If the  
organization doesn't otherwise qualify as a public charity,  
then the organization is a private foundation and must file  
Form 990-PF for the tax year.  
Supplemental information required. In Part VI, identify  
each of the supported organizations listed in Part I, line 12g,  
column (i), that met both of the following conditions for the tax  
year.  
1. The supporting organization was responsive to the  
supported organization, and  
2. The supported organization was attentive to the  
supporting organization. With respect to each of the identified  
supported organizations, set forth the facts that show how  
both the attentiveness test and the responsiveness test were  
met by the supporting organization and the supported  
organization.  
Section E. Distribution Allocations  
Section E determines whether the distributable amount for  
the current tax year (and any underdistribution for reasonable  
cause in a prior year) is satisfied through current-year  
distributions and carryovers of prior-year excess distributions.  
Section E also determines carryovers of excess distributions  
to future years. Several lines in Section E aren't yet applicable  
during the phase-in period of the new regulations for Type III  
non-functionally integrated supporting organizations. Those  
lines are grayed out.  
Attentiveness test. A supported organization is  
“attentive” to the operations of a supporting organization if,  
during the tax year, at least one of the following requirements  
is satisfied.  
1. The supporting organization distributes to the  
supported organization at least 10% of the supported  
organization’s total support in its tax year ending before the  
beginning of the supporting organization’s tax year. For  
example, if the supporting organization and the supported  
organization both use a calendar year, and the supported  
organization has total support of $X in a year, then the  
supporting organization’s support in the following year must  
be at least 10% of $X. Where the supporting organization  
supports a particular department or school of a university,  
hospital, or church, the department’s or school’s total support  
is considered instead.  
In applying distributions, there are three basic steps.  
1. First, apply distributions to eliminate any  
underdistribution for reasonable cause in a prior tax year.  
2. Second, apply distributions to satisfy the distributable  
amount for the current year.  
3. Third, carry over to future years any remaining excess  
distributions.  
Apply the oldest distributions first. Carryovers of excess  
distributions from prior years are always applied in full before  
current-year distributions (unlike the rules for qualifying  
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distributions by private foundations), and older carryovers are  
applied before newer carryovers. Excess distributions of a  
given year can't be carried over for more than 5 years.  
Line 2. An organization that is treated as a Type III  
non-functionally integrated supporting organization for the  
first time in its 2022 tax year will have a distributable amount  
of zero during the 2022 tax year.  
Example 1. X is a Type III non-functionally integrated  
supporting organization that for its tax year including  
December 28, 2020, and through its following 2021 tax year  
meets the requirements of Regulations section 1.509(a)-4(i)  
(3)(iii) as in effect prior to December 28, 2020. Under  
transition rules, X is deemed to meet its distribution  
requirement for 2021, but its distributable amount is  
calculated in the ordinary manner to determine its excess  
distributions. For 2021, X had a distributable amount, as  
ordinarily determined, of $80,000 and distributions of  
$100,000. Accordingly, X had excess distributions of  
$20,000. For 2022, X had a distributable amount of $95,000  
and distributions of $85,000. X first applied its 2021 excess  
distributions carryover of $20,000 to the 2022 distributable  
amount of $95,000. Then, X applied $75,000 of its 2022  
distributions of $85,000 to the remaining 2022 distributable  
amount. Accordingly, X has excess distributions of $10,000  
from 2022 (2022 distributions of $85,000 minus $75,000  
applied to the 2022 distributable amount), which it may carry  
over to 2023. For 2023, X has a distributable amount of  
$100,000 and distributions of $150,000. X applies the  
$10,000 excess distribution carryover from 2022 to the 2023  
distributable amount. Then, X applies $90,000 of its 2023  
distributions to the remaining 2023 distributable amount.  
Section E will show $0 carryovers for 2021 and 2022  
(because the excess carryovers for each of those years were  
previously applied). In addition, Section E will show excess  
distributions of $60,000 in 2023 (2023 distributions of  
$150,000 minus $90,000 applied to the 2023 distributable  
amount), which it may carry over in the next 5 tax years until  
applied.  
If the organization had any underdistributions for a prior  
tax year (2021 or 2022), then it didn't qualify as a Type III  
non-functionally integrated supporting organization in that tax  
year and subsequent years (and would be classified as a  
private foundation unless it met the requirements of another  
public charity status) unless it met the requirements of the  
reasonable cause exception or the judicial proceeding  
exception discussed in the instructions for Lines 5 and 6,  
later. If the organization met either of these exceptions,  
explain in detail in Part VI how the organization met the  
requirements for the exception.  
Line 3. On lines 3d and 3e, enter the amounts reported on  
lines 8d and 8e, respectively, from the organization's return  
for the 2022 tax year. The sum of the amounts on lines 3d  
and 3e is also reported on line 3f. The amount reported on  
line 3f is then applied in the following priority.  
1. First to any prior-year underdistributions on line 3g,  
2. Second (if any remaining amount) to the current-year  
distributable amount on line 3h, and  
3. Third (if any remaining amount) on line 3j for carryover  
to future years.  
Excess distributions can't be carried over for more than 5 tax  
years immediately following the tax year in which the excess  
amount is created, and thus are forfeited if not used in the  
fifth year of carryover. Such amounts are set forth on line 3i  
(not applicable to the 2023 tax return).  
Line 4. Apply the current-year distributions (from Section D,  
line 7) in the same order of priority as described in the  
instructions for Line 3 to any prior-year underdistributions  
(line 4a) and current-year distributable amount (line 4b)  
remaining after applying carryovers on line 3. Any remaining  
distributions are reported on line 4c for carryover to future  
years.  
Lines 5 and 6. If the current-year distributable amount is  
greater than the sum of the excess distributions carryover  
from the prior year plus the current-year distributions, then  
the organization doesn't meet the distribution requirement  
and can't qualify as a Type III non-functionally integrated  
supporting organization for the tax year, unless an exception  
applies. If the organization doesn't qualify as a supporting  
organization or otherwise as a public charity for the tax year,  
then it is a private foundation and must file Form 990-PF for  
the tax year and subsequent years until private foundation  
status is terminated under section 507. If either the  
Example 2. Y is a Type III supporting organization that for  
its tax year including December 28, 2020, meets the  
requirements of Regulations section 1.509(a)-4(i)(3)(iii) as in  
effect prior to such date, but doesn't meet such requirements  
in its following 2021 tax year (because of underdistributions  
for which the prior regulation didn't expressly provide a  
reasonable cause exception). Therefore, Y didn't benefit from  
the transition rule for its 2021 tax year. Y's distributable  
amount was $120,000 for 2021. Y made distributions of that  
amount and had no excess distributions to carry over to  
2022. Y calculated that its distributable amount was  
$150,000 for 2022 and made distributions of exactly that  
amount in 2022. Early in its 2023 tax year, Y discovers that its  
distributable amount for 2022 actually was $200,000. Within  
180 days, Y makes a $110,000 distribution ($50,000 to cover  
the underdistribution for 2022 and $60,000 as part of its 2023  
distributions). Later in the 2023 tax year, Y makes additional  
distributions totaling $200,000. Y’s distributable amount in  
the 2023 tax year is $190,000. In its 2023 Form 990, Y claims  
reasonable cause for the 2022 underdistribution due to a  
clerical error. Under these circumstances, Y first applies  
$50,000 of its 2023 distributions of $310,000 to the 2022  
underdistribution of $50,000 ($200,000 minus $150,000),  
then applies $190,000 of its remaining 2023 distributions of  
$260,000 ($310,000 minus $50,000) to satisfy its 2023  
distributable amount. Y’s remaining $70,000 of distributions  
in 2023 ($310,000, minus $50,000 allocated to 2022, and  
minus $190,000 allocable to 2023) are excess distributions  
that may be carried over to future years.  
reasonable cause or judicial proceeding exception applies,  
then explain in detail in Part VI how the organization met the  
requirements for the exception.  
Reasonable cause exception. An organization that fails  
to distribute its distributable amount won't be classified as a  
private foundation for the year of the failure if the organization  
establishes to the satisfaction of the IRS that:  
1. The failure was due to unforeseen events or  
circumstances beyond its control, a clerical error, or an  
incorrect valuation of assets;  
2. The failure was due to reasonable cause and not to  
willful neglect; and  
Line 1. Report the distributable amount for 2023 from  
3. The distribution requirement is met within 180 days  
Section C, line 6.  
after the organization is first able to distribute its distributable  
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Instructions for Schedule A (Form 990) 2023  
amount notwithstanding the unforeseen events or  
distributable amount (and not already carried over for 5 tax  
years). The organization may carry over these amounts to  
future years. Prior-year carryovers are applied before  
current-year distributions.  
circumstances, or within 180 days after the clerical error or  
incorrect valuation was or should have been discovered.  
Amounts paid to meet a distribution requirement of a prior tax  
year can't also be counted toward the distribution  
requirement for the tax year in which paid.  
Judicial proceeding exception. An organization is  
excused from meeting the distribution requirements to the  
extent of a conflicting mandatory provision in its governing  
instrument, if a judicial proceeding is pending to reform a  
governing instrument that prohibits compliance, under the  
circumstances set forth in Regulations section 1.509(a)-4(i)  
(11)(ii)(E).  
Part VI. Supplemental Information  
Use Part VI to provide narrative information required by these  
instructions or to supplement responses to questions on  
Schedule A (Form 990). Identify the specific part and line  
number that the response supports, in the order in which they  
appear on Schedule A (Form 990). Part VI can be duplicated  
if more space is needed.  
Don't include in Part VI the names of any donors,  
grantors, or contributors because Part VI will be  
!
Lines 7 and 8. Enter on line 7 the prior-year carryover and  
the current-year distributions to the extent not applied to  
prior-year underdistributions and the current-year  
CAUTION  
made available for public inspection.  
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Instructions for Schedule A (Form 990) 2023