The new Form 990 has three sections: An 11-page Core Form, with 11 separate sections that must be filled out by every tax-exempt organization; 16 separate Schedules, six of which, at the bare minimum, you will likely need to complete; and an Instructions section, which contains a glossary on page 41 and several appendices to help you navigate around the redesigned form.
The two areas where you will notice the most changes in reporting requirements include governance and compensation. Part VI in the Core Form is a brand new section that asks questions about the organization’s governance structure (such as the size of your board, the number of committees, and questions about minutes-keeping), policies (such as whether or not your company has a conflict-of-interest policy, document retention policy, and whistle-blower policy) and disclosure practices (such as who gets to see your 990 once it has been filed).
Part VII of the Core Form also contains important changes. While companies have always had to report on compensation of the highest-ranking people within the organization, you must now report on compensation information for all officers, directors, and trustees, as well as the top-five highest-paid employees making over $100,000. Additionally, a key employee is now defined as anyone who makes over $150,000 in a calendar year. Also be prepared to report on what types of non-salary compensation you provide to these key employees such as housing subsidies, expense accounts, transportation reimbursements, and other benefits. Finally, be prepared to report calendar year compensation on this part of the Core Form and fiscal year compensation on the Statement of Functional Expenses (Part IX).
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