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Taxes

AICPA: Clarification Is Needed for Form 990 Series

The AICPA’s comments also include a matrix for the Form 990 series which focuses on specific sections and the recommendations for those sections.

Isaac M. O'Bannon

Apr. 17, 2024

form 990

The American Institute of CPAs (AICPA) submitted a letter to the Internal Revenue Service (IRS) requesting clarification and workarounds for the 990 Series Form instructions. A broad category of exempt organizations must file returns with the IRS each year, including hospitals, private foundations, universities, churches and many others.

Exempt organizations will generally file a form that is part of the Form 990 series. Among its recommendations for Forms 990, 990-PF and 990-T, the AICPA has requested the clarification of instructions; the simplification, addition and re-wording of language; and the updating of forms and instructions.

The AICPA’s recommendations include:

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  • The IRS should provide clarification and workarounds for the 990 Series Form instructions, as well as Publication 4163, Modernized e-File (MeF) Information for Authorized IRS e-File Providers for Business Returns, to help practitioners successfully electronically file exempt organization returns.
  • In the case of a system-wide E-file outage, the IRS should alert the public via the website page “E-file for Charities and Non-Profits” or make an announcement via an alert through the IRS’ e-News for Exempt Organizations.
  • The business filing superseding return function in the MeF system should be extended to exempt organizations to allow them to file superseding returns after the original-filed return has been filed, but prior to the end of the filing period (with extensions) without amending the applicable series Form 990.

The AICPA’s comments also include a matrix for the Form 990 series which focuses on specific sections and the recommendations for those sections.

“Greater clarity in the Form 990 series, and the related instructions, will greatly benefit the exempt organizations that have to file those returns, as well as the tax professionals who assist them,” says Peter Mills, Senior Manager, AICPA Tax Policy & Advocacy. “Allowing exempt organizations to file superseding returns, instead of requiring amended returns, will greatly streamline the filing process, saving time and costs.”