Footnotes · CE course notes · Nonprofits · Schedules A–G
Schedules A–G
At the desk
| A | Every (c)(3). Part I the box; Part II or III the arithmetic from year six; Parts IV–V for supporting organizations; Part VI narrative. Book method, five years. [Final Q28, A; marked] |
| B | Everyone, or certify “No” on Part IV line 2. $5,000 general rule; the greater of $5,000 or 2% of line 1h for a (c)(3) that passes the one-third test; only (c)(3)s and §527s give names. Never goes to the state, never gets posted. |
| C | Any political activity (Part I); any lobbying (Part II-A with a §501(h) election on Form 5768, II-B without); §6033(e) dues notices for (c)(4), (5), (6) (Part III). |
| D | Most organizations with a balance sheet: DAFs, easements, collections, escrow, endowments, fixed assets, investments, other liabilities with the FIN 48 footnote, and the audit-to-return reconciliations. |
| E / F | Schools (the nondiscrimination policy). Foreign activity over $10,000, foreign grants over $5,000, by region. |
| G | Over $15,000 of professional fundraising fees (Part I), event receipts (Part II) or gaming (Part III). Lists the ten highest-paid fundraisers at $5,000 and the states where the organization is registered. |
On this page
- Schedule A 1 note
- Schedule B: contributors 3 notes
- The donor rules behind Schedule B, as they stand for 2026 9 notes
- Schedule C: political campaign and lobbying activities 5 notes
- Schedule D: supplemental financial statements 2 notes
- Schedule E: schools 1 note
- Schedule F: activities outside the United States 2 notes
- Schedule G: fundraising and gaming 3 notes
Schedule A
- The whole of Schedule A is on Public Charity or Private Foundation. Three reminders: the box is re-decided every year; the support schedules follow the book method stated in Part XII, so a cash-basis prior preparer’s columns get restated; and an organization that fails for two consecutive years (lines 18 / 20) files 990-PF and, on the IRS’s current view, a new Form 1023 to come back.
Schedule B: contributors
- Who lists whom. General rule: every contributor whose gifts of money, securities or property aggregate $5,000 or more in the year (count only individual gifts of $1,000 or more toward the $5,000). Special rule for a (c)(3) meeting the §170(b)(1)(A)(vi) one-third test: only contributors above the greater of $5,000 or 2% of Part VIII line 1h — with $700,000 of contributions, 2% is $14,000, and an $11,000 donor is not listed (Ex. 3.4). (c)(7), (8) and (10) organizations: contributors of more than $1,000 for exclusively charitable purposes, with “N/A” for names. Part I name, address, amount, person / payroll / noncash; Part II noncash description and value (listed securities at the mean of high and low on the gift date); Part III for the fraternal-society charitable gifts.
- Disclosure. Names and addresses are not public for 990 and 990-EZ filers and are not reported at all by organizations other than (c)(3)s and §527s (T.D. 9898, 2020; the course’s Rev. Proc. 2018-38 was vacated in Bullock v. IRS, D. Mont. 2019, then re-adopted by regulation). Private foundations’ donor names are public. Amounts and noncash descriptions are public unless they identify the donor. Redact before posting; the IRS strips Schedule B from TEOS images, Candid does the same, but the organization’s own posted copy is its own problem. Americans for Prosperity Foundation v. Bonta, 594 U.S. 595 (2021): a state may not demand the unredacted Schedule B as a condition of registration. [Final Q34, D; corrected in blue] updated 2026
- Payroll giving through an employer: report the employer’s name and total unless a particular employee is known to have given enough to be listed. A partially completed Form 8283 that comes in with a noncash gift gets Part IV (donee acknowledgment) completed and returned so the donor can deduct; keep a copy. Form 8282 if the property is sold within three years.
The donor rules behind Schedule B, as they stand for 2026
The course spends thirty pages on the donor’s deduction. The public page on charitable giving covers it for clients; what follows is the exam material with the 2021-only figures replaced. updated 2026
- Qualified organizations (§170(c)): domestic (c)(3)s, governments, war veterans’ organizations, domestic fraternal lodges (for charitable use only), nonprofit cemeteries (not for a particular lot). Gifts to a specific person, to a (c)(4) or (c)(6), of time or services, or of appraisal fees are not deductible; a Canadian or Mexican charity is, under treaty, against income from that country. [SQ 20, D; Review image14, D]
- Limits, from 2026 and permanent: cash to public charities and operating foundations 60% of AGI (the 100% was 2021 only); appreciated capital-gain property to them 30% at fair market value, or 60% if the donor elects to deduct basis; cash to private non-operating foundations, veterans’ groups, lodges and cemeteries 30%; capital-gain property to those 20%; five-year carryovers in each category, current-year gifts first. Ordering: 60%-limit cash first, then the 30% categories, then 20%, each capped by what is left of the 50%/60% ceiling (Ex. 3.14: $50,000 AGI, $2,000 cash and $28,000 of land to the church, $5,000 cash to a private foundation → $2,000 + $15,000 of land this year, $13,000 of land and the $5,000 carried over). [Final Q39, A, updated; Review image15, A]
- New for 2026 (P.L. 119-21): non-itemizers deduct up to $1,000 ($2,000 joint) of cash gifts to public charities (not DAFs, not supporting organizations); itemizers lose the first 0.5% of AGI of total contributions, with the disallowed part carrying over; in the 37% bracket the deduction is worth at most 35 cents on the dollar; corporations lose the first 1% of taxable income and keep the 10% ceiling. The $300 / $600 above-the-line deduction of 2020–2021 is gone. updated 2026
- Benefit events. Deduct only the excess over the value of what is received, and only if the donor meant to give the excess. An established charge is the value of the benefit; with no established charge, the excess over the reasonable value of attending. Using the ticket or not is irrelevant; returning it for resale restores the full deduction. A $65 dinner-dance ticket with a $25 value is a $40 gift (Ex. 3.5); $95 for a $35 dinner is $60 (SQ 18); $3,000 at auction for a week at a beach house worth $3,000 is nothing (Final Q36); a ticket printed “Contribution $40” for an $8 movie is $32. [SQ 18, B; SQ 19, D; Final Q35, B; Q36, A; marked]
- Athletic seating rights: §170(l) since 2018 — no deduction for any payment that gives the right to buy tickets. Ben’s $1,000 to the college for ticket rights deducts $0 (the pre-2018 80% rule is what the exam distractors were built on). [Final Q37, A; corrected in blue]
- Quid pro quo and substantiation. Over $75 partly for goods or services: the organization’s written statement with a good-faith estimate of the value (§6115; $10 per failure, up to $5,000 per event). $250 or more: contemporaneous written acknowledgment (amount, whether anything was given back, its value, or “intangible religious benefits only”) in hand by the earlier of the filing date or the extended due date; each $25 weekly church gift and each payroll deduction stands alone. Under $250: bank record or receipt. Noncash over $500: Form 8283; over $5,000: qualified appraisal and Section B signed by the appraiser and the donee; over $500,000: the appraisal attached. Vehicles over $500: Form 1098-C and the gross sale price unless the charity uses or materially improves the vehicle. Clothing and household goods: good used condition or better; thrift-shop value; no percentage-of-cost formulas.
- Token items and membership benefits (Rev. Proc. 90-12 as indexed): a gift of at least $69.50 may come with an item costing not more than $13.90 bearing the organization’s name, or any goods worth not more than the lesser of 2% of the payment or $139, and the whole payment is deductible; annual membership benefits for $75 or less (frequent-use privileges, members-only events costing under $13.90 a head) are disregarded. 2026 figures (Rev. Proc. 2025-32); the course had $11.30 / $11.70. updated 2026
- Property. Ordinary-income property (inventory, donor-created art, short-term holdings, depreciation recapture) deducts at basis — stock held five months with $800 cost and $1,000 value gives $800 (Ex. 3.10). Depreciated property gives fair market value (SQ, Final Q38). Tangible personal property put to an unrelated use deducts at basis — a painting hung in the library is related, a painting sold for the endowment is not (Ex. 3.11). Bargain sale: split basis in proportion to value; ordinary-income property worth $10,000 with $4,000 basis sold to a church for $2,000 → gift part $8,000, allocated basis $3,200, deduction $3,200 (Ex. 3.12). Qualified appreciated stock to a private foundation deducts at value; other appreciated property at basis. [Final Q38, A; marked]
- Timing. The year of unconditional delivery, cash and accrual donors alike: a mailed check when mailed, a card charge when charged, a stock certificate when delivered to the charity or transferred on the books, a pledge never, a conditional gift only when the condition is met or negligible. [Final Q40, B; marked]
Schedule C: political campaign and lobbying activities
- Part I (Part IV line 3; 990-EZ line 46): political campaign activity — anything supporting or opposing a candidate for elective office, whether or not elected; not nonpartisan voter education or registration. A (c)(3) reporting anything here has a §4955 tax (10% on the organization, 2½% on a knowing manager, 100% / 50% if not corrected) and a revocation problem. (c)(4)s, (5)s and (6)s report their political expenditures and the §527(f) tax on the lesser of net investment income or the political spending.
- Part II-A (Form 5768 on file): the §501(h) expenditure test. Lobbying nontaxable amount = 20% of the first $500,000 of exempt-purpose expenditures, 15% of the next $500,000, 10% of the next $500,000, 5% of the rest, capped at $1,000,000; grassroots nontaxable amount = 25% of that. Over either limit in a year: §4911 tax of 25% of the excess. Over 150% of either limit on a four-year average: exemption lost. The election is made on Form 5768 by filing it any time in the year, is good until revoked, and is unavailable to churches and private foundations. Exempt-purpose expenditures include program spending, allocable administration, all lobbying, depreciation and in-house fundraising, but not fees paid to a separate fundraising unit or outside fundraisers. added 2026 (the dollar steps)
- Direct lobbying: a communication with a legislator or a government official who helps write legislation that refers to specific legislation and reflects a view on it. Grassroots lobbying: a communication with the public that refers to specific legislation, reflects a view, and encourages action — says “contact your legislator,” gives the address or phone, provides a postcard or petition, or names the legislators who are undecided or opposed. Member communications about legislation of direct interest to the organization and its members are not lobbying unless they urge members to lobby (then direct) or to urge others (then grassroots). Not lobbying: nonpartisan analysis, study or research made available to the public even if it takes a side, so long as it gives a full and fair exposition of the facts; responding to a committee’s written request for technical advice; self-defense communications about the organization’s own existence, powers, exempt status or deductibility. Affiliated organizations (one bound by the other’s legislative decisions, or interlocking boards) are measured as one. [Final Q42, A; Q45, B; SQ 22, C; Review image16, C]
- Part II-B (no election): the “no substantial part” test. Check each method used (volunteers, paid staff, media, mailings, publications, grants to other lobbyists, direct contact, rallies) with the amounts, and describe in Part IV. There is no safe number; Treasury and the courts have treated 5% as safe and 16–20% as substantial, and the IRS counts time and effort as well as dollars. Line 2a asks whether the organization lost its exemption for substantial lobbying. The course’s advice stands: make the election.
- Part III: (c)(4), (5) and (6) organizations and the §6033(e) notice to members of the nondeductible share of dues, or the proxy tax at 21% on Form 990-T instead; in-house lobbying under $2,000 and organizations whose dues are mostly from members who cannot deduct them anyway (the $147-or-less-dues test for 2026) are excused check.
Schedule D: supplemental financial statements
- Seven Part IV questions (6–12) trigger it, so most organizations with a balance sheet file some part. Part I donor-advised funds (a separately identified fund the sponsor owns and controls, over which the donor expects advisory privileges) versus other funds and accounts, with the certification that the sponsor told donors the assets are the sponsor’s. Part II conservation easements: number, acreage, historic structures, modifications, monitoring hours and cost, whether each satisfies §170(h)(4)(B)(i) and (ii). Syndicated easements have been a listed transaction since Notice 2017-10 and a statutory disallowance under §170(h)(7) since December 2022 (deductions over 2.5 times the partners’ basis) added 2026. Part III collections of art and historical treasures, capitalized or not under ASC 958-360. Part IV escrow and custodial arrangements — a credit counseling agency holding debtors’ money for creditors (Ex. 3.15). Part V endowments: five-year roll-forward, board-designated versus permanent versus term (a term endowment provides income for a specified period), and the UPMIFA representation. [Final Q43, A; marked]
- Parts VI–IX: fixed assets; other securities and program-related investments (each at 5% of total assets; a program-related investment is made primarily to accomplish the exempt purpose rather than to produce income — student loans, below-market loans to other charities); other assets. Part X other liabilities, with the ASC 740 / FIN 48 uncertain-tax-position footnote reproduced verbatim (“the Organization believes it has no uncertain tax positions” is the usual text; the parts about UBIT exposure or exemption risk must be quoted exactly). Parts XI–XII reconcile audited revenue and expenses to the return (not required without an audit). Part XIII is Schedule D’s own narrative. [Final Q44, B; marked]
Schedule E: schools
- Any organization that checked Schedule A line 2 (and 990-EZ line 48). The questions of Rev. Proc. 75-50: a racially nondiscriminatory policy in the governing instrument, in every brochure and catalog, and published annually — since Rev. Proc. 2019-22 a notice on the school’s home page satisfies the publication requirement added 2026; records of racial composition of students, faculty and staff, of scholarships, and of solicitation materials; whether the school discriminates in admissions, programs, scholarships, athletics or other activities; whether it receives government financial assistance and whether any was revoked. Part II explains any “No” or “Yes” that needs it — on Schedule E, not O.
Schedule F: activities outside the United States
- Part I if aggregate revenues or expenses from foreign grantmaking, fundraising, business, investments or programs exceed $10,000 (Part IV line 14b); by region, with the number of offices, employees and agents, the type of activity and expenditures. Part II grants to foreign organizations over $5,000 each (line 15); Part III to foreign individuals over $5,000 in aggregate (line 16) — by region, without naming grantees, which the IRS does to protect them. Part IV: the foreign-form checklist — Forms 926, 3520 and 3520-A, 5471, 8621, 8865, 5713 — each “Yes” is a separate filing. Part V narrative. Investments held in foreign securities count at $100,000 of value for line 14b even with no foreign activity, which catches endowments.
- Grants abroad are not a Schedule F problem; they are an expenditure-responsibility and equivalency-determination problem for private foundations, and an anti-terrorism due-diligence problem (OFAC lists, Treasury’s voluntary guidelines) for everyone. A public charity that merely passes donor-designated money to a foreign organization has an earmarking problem (Rev. Rul. 63-252) added 2026.
Schedule G: fundraising and gaming
- Part I (Part IV line 17, professional fundraising fees over $15,000 on Part IX line 11e; 990-EZ filers skip it): fundraising methods used (mail, internet and email, phone, in person, solicitation of non-government grants, government grants, special events); whether there is a written or oral agreement with anyone for professional fundraising services (planning, management, materials, consulting or direct solicitation requiring professional judgment; not printing, mailing or banking; not the organization’s own development officer); the ten highest-paid fundraisers at $5,000 or more with gross receipts, amount paid and net to the organization; the states where the organization is registered or licensed to solicit — which the states read.
- Part II (line 18; Part VIII lines 1c + 8a over $15,000): the two largest events over $5,000 and all others combined: gross receipts, the contribution part, gross revenue, then cash prizes, noncash prizes, rent, food, entertainment and other direct expenses, to net income. Part III (line 19; line 9a over $15,000): bingo, pull tabs and instant bingo, and other gaming (raffles, casino nights, Texas Hold’em, scratch-offs, slots, video games of every kind), with the states where gaming is licensed, whether the license was revoked, whether the organization uses a gaming manager and a bank account separate from the general fund, the volunteer percentage, and the charitable distributions required by state law. A raffle is gaming; a casino night at the gala is gaming; a drawing for a door prize is gaming. Fundraising activities do not include gaming except gaming incidental to an event. [Final Q23 topic; Review image17, B]
- Colorado: a raffle or bingo needs a Secretary of State bingo-raffle license, available only to organizations in existence five years; the games manager must be registered and unpaid; proceeds go only to lawful purposes; quarterly reports. Charitable gaming income is excluded from UBTI only for bingo as defined (§513(f)) — pull tabs and raffles are not bingo, though they usually escape as not regularly carried on or as volunteer-run (UBTI exclusions). added 2026 check
Private reference, not client advice. Notes taken from a continuing-education course, Form 990: A Practical Guide (Thomson Reuters Checkpoint Learning, 12 hours, 2022 edition written on 2021 law and the 2021 forms). Figures and rules brought current to 2026 in October 2026 (P.L. 119-21, Rev. Proc. 2025-32, T.D. 9933, T.D. 9898, the 2025 form instructions). Items tagged check are to be confirmed against primary sources before they are relied on.