Tax Brief: Form 990, Schedule B: Schedule of Contributors
The purpose of Schedule B Schedule of Contributors in the Form 990 is to report information on contributions the organization recorded during the tax year. The IRS utilizes Schedule B information to match donors’ tax deductions to the organizations they claim to have contributed to in order to weed out potential donor fraud.
This article will provide information for 501(c)(3) organizations with respect to Schedule B reporting and provide an overview of Part I, Part II and Public Inspection requirements of Schedule B. There are additional special rules, and Part III, included in Schedule B that apply exclusively to 501(c)(7), (8), and (10) organizations that will not be addressed in this article.
Which Non-Profit Organizations Must Complete Schedule B?
Organization filing a Form 990, 990-EZ or 990-PF must file Schedule B with their annual filing if they received, during the tax year, contributions totaling $5,000 or more (in money or property) from any individual contributors. The general rule is that 501(c)(3) organizations must report contributor information for contributions totaling $5,000 or more (in money and property). However, there is a special rule for 501(c)(3) organizations that may be applied. For an organization described in section 501(c)(3) filing Form 990 or 990-EZ that met the 33 1/3% support test of the regulations under sections 509(a)(1) and 170(b)(1)(A)(vi), that checked Schedule A (Form 990), Part II, line 13, 16a, or 16b, the threshold for reportable donors is the greater of (1) $5,000; or (2) 2% of the amount on (i) Form 990, Part VII, line 1h; or (ii) Form 990-EZ, line 1.
An organization that does not have contributions reportable under the general rule or special rules does not need to file Schedule B, however, the organization should take care to ensure “No” is answered on Part IV, line 2 of its Form 990; or check the box on line H of its Form 990-EZ or on its Form 990-PF, Part I, line 2, to certify that it does not meet the filing requirements of Schedule B.
Part I – Contributors
In this section, the filing organization reports all contributors who met or exceeded the determined reporting threshold – generally $5,000 unless the organization is a 501(c)(3) meeting the special rule noted above. Information reported here includes the name, address and ZIP of each reportable donor, their total contributions recognized as revenue during the filing year, and the type of contribution received.
There are three types of contribution that can be selected: Person, Payroll, or Noncash. The “Person” box is for contributions that were received directly from a contributor. “Payroll” is to be checked if an employee’s contribution was forwarded by an employer to the filing organization. If an employer withholds contributions from employees’ pay and periodically gives them to the organization, report only the employer’s name and address unless it is known a particular employee gave enough to be listed separately. If “Noncash” is marked, additional information is required to be reported in Part II.
In certain cases, an organization may receive a contribution from a donor who wishes to remain anonymous. An organization should identify a donor as “anonymous” on Schedule B only if the donor’s identity is not known. See the Public Inspection section for further information on inclusion of Schedule B in the public inspection copy of the Form 990.
Part II – Noncash Property
Part II should be completed if a contribution was marked as “Noncash” in Part I. Noncash contributions are contributions of property, tangible or intangible, other than money. These contributions include, but aren’t limited to – stocks, bonds, and other securities, real estate, works of art, clothing and household goods, vehicles, and inventories of food, books or other supplies.
Information reported here includes a reference number to the related contributor in Part I, a description of the noncash property given to the organization, the fair market value (or estimate), and date the noncash contribution was received. If the fair market value cannot be readily determined, an appraised or estimated value may be reported.
Public Inspection
While the Form 990 is required to be made available to the public for inspection, there are special rules applying to Schedule B. For section 527 political organizations filing Form 990 or 990-EZ and organizations filing Form 990-PF, all details of Schedule B are required to be included in the public inspection copy. For all other filing organizations, including 501(c)(3) organizations, the names and addresses of contributors reported in Part I are not required to be made available for public inspection and should be redacted in the public disclosure copy. All other information is to be made available for inspection, unless it clearly identifies the contributor.
If the organization is required to file its Form 990 or 990-EZ with any states, Schedule B should only be included in the attachments if specifically required. States not requiring the information might inadvertently make the schedule available for public inspection along with the rest of the Form 990 or 990-EZ.
Conclusion
The Form 990 is a complex information return. Jones & Roth has a team of experts that specialize in preparing Form 990 and its related schedules and we are happy to assist your organization to ensure tax compliance and to ease your burden.
The purpose of this article is to summarize the major components and reporting requirements of Schedule B (Form 990) and is not intended to be all encompassing or serve as replacement for the IRS issued instructions.
This article is meant to be a resource and provide tools to assist your organization. Please consult your tax advisor regarding your specific tax situation.
