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Significant Change to the 2013 Federal Form 990-PF

The federal Form 990-PF is an annual information return that must be filed by the following:

  • Exempt private foundations (section 6033(a), (b), and (c)),
  • Taxable private foundations (section 6033(d)),
  • Organizations that agree to private foundation status and whose applications for exempt status are pending on the due date for filing Form 990-PF, 
  •  Organizations that made an election under section 41(e)(6),
  •  Foundations that are making a section 507 termination, and
  •  Section 4947(a)(1) nonexempt charitable trusts treated as private foundations (section 6033(d)).

The federal Form 990-PF has remained relatively unchanged for many years, unlike its counterpart the federal Form 990.  However, with the recent finalization of the 2013 Form 990-PF instructions, the IRS has implemented a significant change regarding the classification of grantee recipients. The goal is to create uniformity in reporting as well as more descriptive categories.  The instructions list specific codes, as seen at the bottom of the page.
 

Part XV, Supplementary Information, line 3 on the 2013 990-PF provides instructions that set forth codes to use for foundation status of recipients, and clarify circumstances under which grants are reported (see codes below). In addition, also Regulations section 1.509(a)-4, Notice 2006-109, and Rev. Proc. 2011-33 provide guidance on determining whether a grantee is a type I, type II, type III functionally integrated, or type III non-functionally integrated supporting organization.  As a result of this change, private foundations may need to update their grant software or their recordkeeping process, to track in more detail, the tax classification of their grantees.

 

Codes  
NC     Non-Charity (not 501(c)(3))
PF Private non-operating foundation (Section 509(a))
POF Private operating foundation (section 4942(j)(3) other than an EOF
EOF Exempt operating Foundation (section 4940(d))
PC Public charity described in section 509(a)(1) or (2)
SO-DP

Type l, type ll, or type lll functionally integrated supporting organization if  a

disqualified person of the private foundation controls the supporting

organization or a supported organization (sections 509(a)(3) and 49442(g)

(4)

SO I

Type l supporting organization (sections 509(a)(3) and 509 (a)(3)(B)(i))

other than an SO-DP

SO ll

Type ll supporting organization (sections 509(a)(3) and 509 (a)(3)(B)(ii)

other than and SO-DP

SO lll Fl

Functionally integrated type lll supporting organization (sections 509(a)(3)

509(a)(3)(B)(iii) and 4943(f) (5)(B) other than an SO-DP

SO lll NFl

Non-functionally integrated type lll supporting organization (sections 509(a)

(3), 509 (a)(3)(B)(iii) and 4943(f)(5)(b))

TPS Testing for public safety organization (Section 509(a)(4))

 

 

Timothy Schroeder is a Not-for-Profit Services Group Manager with expertise in audits of financial statements and employee benefit plans, including the preparation of Form 990.

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