Form 990 (Schedule O) ND 2024-2025

Form 990 (Schedule O) ND: What You Should Know

In fact, only two question in the 990 are “expanded” in  Schedule O and the IRS explains this in detail: Existing Forms 990 and 990-EZ are not being updated; The IRS does not require you to expand upon the narrative information in the existing forms; and the expanded Form 990/990-EZ format is necessary to answer new or expanded questions that arose through the application of certain provisions of the Internal Revenue Code, effective 12/31/2014 and to provide additional information to clarify the IRS' interpretation of the existing tax rules. The IRS also explains: Schedule O does not apply to questions or answers on a Form 990-T. It also does not apply to information provided by an organization if that information is: related to material events the organization disclosed in its application for tax-exempt status; a material omission of pertinent information contained in the application; inadvertently filed without disclosing the relevant information that was so contained; contains a material contradiction to the organization's position; or provides the organization with the ability to provide further information that could lead to an accurate, comprehensive response to the questions that the IRS would reasonably ask. Taxpayers using a Form 990 or 990-EZ, even the “explorer” version, should use the Schedule O form for all submissions. AICPA member organizations who choose to use a separate Schedule O as a “spoof” version to supplement existing Form 990, may do so for purposes of providing responses to newly-created Form 990-Z and its successor, 990EZ. Taxpayers are encouraged to use Form 990—Schedule O not only because it provides the required narrative responses to Form 990, but also because it provides a unique opportunity to provide an “explanation” to IRS questions about the organization. In addition, the IRS believes that these responses can help improve the ability of taxpayers to receive tax advice in accordance with the law to prevent tax law mistakes, and provide some relief to organizations who are struggling with complex tax issues. The purpose for using Schedule O is to clarify the IRS' understanding of the relevant elements in the tax law and to assist taxpayers in maintaining consistent reporting to the IRS of certain information from the organization to which the law applies.

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