33 Changes Recommended to Form 990

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The American Institute of CPAs has recommended 33 changes to the IRS  regarding the 2018 version of Form 990, Return of Organization Exempt from Income Tax.

The comments were developed by the AICPA Exempt Organizations Taxation Technical Resource Panel (TRP) and approved by the AICPA Tax Executive Committee. The Exempt Organizations panel members include practitioners who serve tax-exempt organizations.

The letter was sent to the IRS by Annette Nellen, CPA, CGMA, Esq., who is chair of the AICPA Tax Executive Committee. Of the 33 recommended changes, 19 are considered of high importance, 13 are considered "medium" and one is of "low" importance.

The recommendations of "high" importance include changes to the form’s glossary under the new tax law. These terms include:

  • endowment
  • permanent (true) endowment
  • SFAS 116
  • SFAS 117
  • temporarily restricted endowment
  • FIN 48

Additional recommended changes include:

  • the holding of assets in donor-restricted and quasi endowments
  • various issues regarding trigger questions
  • issues regarding Financial Accounting Standards Board ASC 958
  • changes to OMB/Uniform Guidance Rules 
  • endowment fund activity
  • Schedule K instructions
  • updating net assets or fund balances to reflect ASU 2016-14
  • Presentation of Financial Statements of Not-for-Profit Entities

The sole, low-importance item concerns Schedule L instructions. In this instance, the AICPA suggests adding a new example of “reasonable efforts” in Schedule L instructions that considers the difficulty of going back many years to determine which individuals or entities qualify as creators or founders.

About Terry Sheridan

Terry Sheridan

Terry Sheridan is an award-winning journalist who has covered real estate, mortgage finance, health care, insurance, personal finance, and accounting and taxation issues for newspapers, magazines, and websites. A Chicago native and former South Florida resident, she now lives in New England.

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