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Form 990: Check Your State Requirements

02/16/2016

Question: On Form 990, there is a question that asks if we provide the return to the board prior to filing with the IRS.  Does this have to be the complete copy of the return or can it be the public disclosure copy with Schedule B removed?  Can we also remove the compensation information?  Some of the officers and board members don’t want others to see their compensation. Do they have to review and approve it before we can file it?

Answer: To answer the question on Part VI, line 11a: “yes”, the complete copy of the return must be provided to the entire board prior to filing.  Keep in mind, though, that the board does not necessarily have to review or formally vote on approving the 990 unless that is the organization’s normal process.  They just have to be provided a copy prior to filing.

However, state law may require the board or a subset of the board to review or approve any filing with the state.  If your organization files the Form 990 with any state, check the state requirements.

Also, it is important to have an informed and engaged board.  This is a best practice and the reason the IRS created the governance part of the Form 990. It is a little concerning that some board members want to hide information from other board members. It may be completely understandable, such as if one’s salary is paid by an unrelated organization. Nevertheless, you may want to look at your board policies, procedures, and practices and, if necessary, provide board training or consult with a not-for-profit organization management consultant to see if the governing body is operating as it should.