Instructions for Schedule A

2025

Instructions for Schedule A

(Form 990)

Public Charity Status and Public Support

Section references are to the Internal Revenue Code

unless otherwise noted.

Future Developments

For the latest information about developments related to

Form 990 and its instructions, such as legislation enacted

after they were published, go to IRS.gov/Form990.

What’s New

Requirements for Type I and Type III supporting organizations. Final regulations (T.D. 9981) issued in

October 2023 provide guidance on certain requirements

for Type I and Type III supporting organizations. The

regulations reflect changes to the law made by the

Pension Protection Act of 2006. Schedule A and these

instructions have been updated to reflect changes made

by the final regulations.

General Instructions

Note: Terms in bold are defined in the Glossary of the

Instructions for Form 990, Return of Organization Exempt

From Income Tax.

Purpose of Schedule

Schedule A (Form 990) is used by an organization that

files Form 990, Return of Organization Exempt From

Income Tax, or Form 990-EZ, Short Form Return of

Organization Exempt From Income Tax, to provide the

required information about public charity status and

public support.

Who Must File

An organization that answered “Yes” to Form 990, Part IV,

line 1, must complete and attach Schedule A (Form 990)

to Form 990. Any section 501(c)(3) organization (or

organization treated as such) that files a Form 990-EZ

must complete and attach this schedule to Form 990-EZ.

These include:

• Organizations that are described in section 501(c)(3)

and are public charities;

• Organizations that are described in section 501(e),

501(f), 501(j), 501(k), or 501(n); and

• Nonexempt charitable trusts described in section

4947(a)(1) that aren’t treated as private foundations.

If an organization isn’t required to file Form 990 or

990-EZ but chooses to do so, it must file a complete return

and provide all of the information requested, including the

required schedules.

Jan 14, 2026

Tip: Any organization that is exempt from tax under

section 501(c)(3) but is a private foundation and not a

public charity shouldn’t file Form 990, Form 990-EZ, or

Schedule A (Form 990), but should file Form 990-PF,

Return of Private Foundation or Section 4947(a)(1) Trust

Treated as Private Foundation. See the instructions for

Part I.

Accounting Method

When completing Schedule A (Form 990), the

organization must use the same accounting method it

checked on Form 990, Part XII, line 1; or Form 990-EZ,

line G. The organization must use this accounting method

in reporting all amounts on Schedule A (Form 990),

regardless of the accounting method it used in completing

Schedule A (Form 990) for prior years, except that in Part

V, Sections D and E, distributions must be reported on the

cash receipts and disbursements method.

If the accounting method the organization used in

completing the 2024 Schedule A (Form 990) was different

from the accounting method checked on the 2025 Form

990, Part XII, line 1; or the 2025 Form 990-EZ, line G, the

organization shouldn’t report in either Part II or Part III the

amounts reported in the applicable columns of the 2024

Schedule A (Form 990). Instead, the organization should

report all amounts in Part II or Part III using the accounting

method checked on the 2025 Form 990, Part XII, line 1; or

the 2025 Form 990-EZ, line G.

Tip: If the organization changed its accounting method

from a prior year, it should provide an explanation on

Schedule O (Form 990), Supplemental Information to

Form 990 or 990-EZ.

Example 1. An organization checks “Cash” on Form

990, Part XII, line 1. It should report the amounts in Part II

or Part III using the cash method. If the organization filed a

2024 Schedule A (Form 990) using the cash method, it

should report in the 2021 through 2024 columns on the

2025 Schedule A (Form 990) the same amounts that it

reported in the 2021 through 2024 columns on the 2024

Schedule A (Form 990).

Example 2. An organization checks “Accrual” on Form

990, Part XII, line 1. The organization reports grants on

Form 990, Part VIII, line 1, in accordance with the

Financial Accounting Standards Board FASB ASC 958

(see the instructions for Form 990, Part VIII, line 1). During

the year, the organization receives a grant to be paid in

future years. The organization should report the grant’s

present value on the 2025 Schedule A (Form 990). The

organization should report accruals of present value

increments to the unpaid grant on Schedule A (Form 990)

in future years.

Instructions for Schedule A (Form 990) (2025) Catalog Number 11294Q

Department of the Treasury Internal Revenue Service www.irs.gov

Specific Instructions

Part I. Reason for Public Charity

Status

Lines 1–12 (in general)

Check only one of the boxes on lines 1 through 12 to

indicate the reason the organization is a public charity

for the tax year. The reason can be the same as stated in

the organization’s tax-exempt determination letter from the

IRS (“exemption letter”) or subsequent IRS determination

letter, or it can be different. An organization that doesn’t

check any of the boxes on lines 1 through 12 shouldn’t file

Form 990, Form 990-EZ, or Schedule A (Form 990) for the

tax year, but should file Form 990-PF instead.

If an organization believes there is more than one

reason why it is a public charity, it should check only one

box but can explain the other reasons it qualifies for public

charity status in Part VI. An organization that claims a

public charity status other than section 170(b)(1)(A)(vi)

can also demonstrate that it qualifies under section 170(b)

(1)(A)(vi) by completing Part II; it may want to do so for

purposes such as qualifying for the first Special Rule on

Schedule B (Form 990), Schedule of Contributors, by

meeting the 331/3% support test.

The IRS doesn’t update its records on an organization’s

public charity status based on a change the organization

makes on Schedule A (Form 990). Thus, an organization

that checks a public charity status different from the

reason stated in its exemption letter or subsequent

determination letter, although not required, may submit a

request to the IRS Exempt Organizations Determinations

Office for a determination letter confirming that it qualifies

for the new public charity status if the organization wants

the IRS records to reflect that new public charity status

(also referred to as “private foundation status”). See the

Instructions for Form 8940, Request for Miscellaneous

Determination. You must complete and submit Form 8940

with payment of a user fee through Pay.gov. The user fees

are listed in Rev. Proc. 2025-5, 2025-1 I.R.B. 260.

A subordinate organization of a group exemption

that is filing its own return, but hasn’t received its own tax

exemption determination letter from the IRS, should check

the public charity status box that most accurately

describes its public charity status.

An organization that doesn’t know the public charity

status stated in its exemption letter or subsequent

determination letter should call the Exempt Organizations

Customer Account Services toll free at 877-829-5500 or

write to:

Internal Revenue Service

TE/GE Customer Account Services

P.O. Box 2508

Cincinnati, OH 45201

See the following examples.

Example 1. The organization received an exemption

letter that it is a public charity under section 170(b)(1)(A)

(vi). For the tax year, it meets the requirements for public

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charity status under section 170(b)(1)(A)(vi). The

organization should check the box on line 7 and complete

Part II.

Example 2. The organization received an exemption

letter that it is a public charity under section 170(b)(1)(A)

(vi). For the tax year, it doesn’t meet the requirements for

public charity status under section 170(b)(1)(A)(vi).

Instead, it meets the requirements for public charity status

under section 509(a)(2). The organization should check

the box on line 10 and complete Part III.

Example 3. The organization received an exemption

letter that it is a public charity under section 509(a)(2). For

the tax year, it doesn’t meet the requirements for public

charity status under section 509(a)(2) or 170(b)(1)(A)(vi).

Instead, it meets the requirements for public charity status

as a supporting organization under section 509(a)(3).

The organization should:

1. Check the box for line 12 and either line 12a, 12b,

12c, or 12d;

2. Complete line 12f;

3. Complete the table on line 12g; and

4. Complete Part IV and (if applicable) Part V.

Example 4. The organization received an exemption

letter that it is a supporting organization under section

509(a)(3). Based on Rev. Proc. 2025-5, the organization

submitted a Form 8940 request to the IRS to change its

classification to public charity status under section 509(a)

(2). For the tax year, it meets the requirements of section

509(a)(2). The organization received a determination

letter that it has been reclassified as a public charity under

section 509(a)(2). The organization should check the box

on line 10 and complete Part III.

Example 5. The organization received an exemption

letter that it is a public charity under section 170(b)(1)(A)

(vi). For the tax year, it doesn’t meet the requirements for

public charity status under section 170(b)(1)(A)(vi) or

509(a)(2), or as a supporting organization under section

509(a)(3). Nor does it meet the requirements for public

charity status under any other provision of the Internal

Revenue Code. The organization is a private foundation

and shouldn’t file Form 990, Form 990-EZ, or Schedule A

(Form 990) for the tax year but should file Form 990-PF

instead.

Example 6. The organization received an exemption

letter that it is a supporting organization under section

509(a)(3). The letter doesn’t state which type of

supporting organization it is. The organization should

review the instructions for lines 12a through 12d to

determine which type best describes the organization.

The organization may wish to file Form 8940 to request a

determination of type.

Line 1. Check the box for a church, convention of

churches, or association of churches. Pub. 1828, Tax

Guide for Churches and Religious Organizations, lists

certain characteristics generally attributed to churches.

These attributes of a church have been developed by the

IRS and by court decisions. They include distinct legal

existence, recognized creed and form of worship, definite

and distinct ecclesiastical government, formal code of

Instructions for Schedule A (Form 990) 2025

doctrine and discipline, distinct religious history,

membership not associated with any other church or

denomination, organization of ordained ministers,

ordained ministers selected after completing prescribed

courses of study, literature of its own, established places

of worship, regular congregations, regular religious

services, Sunday schools for the religious instruction of

the young, and schools for the preparation of its ministers.

The IRS generally uses a combination of these

characteristics, together with other facts and

circumstances, to determine whether an organization is

considered a church for federal tax purposes.

Line 2. Check the box for a school whose primary

function is the presentation of formal instruction, which

regularly has a faculty, a curriculum, an enrolled body of

students, and a place where educational activities are

regularly conducted. A private school must have a racially

nondiscriminatory policy toward its students. For details

about these requirements, see Schedule E (Form 990),

Schools, and its related instructions.

Tip: An organization that checks the box on line 2 must

also complete Schedule E (Form 990).

Line 3. Check the box for an organization whose main

purpose is to provide hospital or medical care. A

rehabilitation institution or an outpatient clinic can qualify

as a hospital if its principal purposes or functions are the

providing of hospital or medical care, but the term doesn’t

include medical schools, medical research organizations,

convalescent homes, homes for children or the aged, or

vocational training institutions for handicapped individuals.

Check the box on line 3 also for a cooperative hospital

service organization described in section 501(e).

Tip: The definition of hospital for Schedule A (Form 990),

Part I, is different from the definition for Schedule H (Form

990). Accordingly, see Who Must File in the Instructions

for Schedule H (Form 990) about whether the organization

is also required to complete Schedule H (Form 990).

Line 4. Check the box for an organization whose principal

purpose or function is to engage in medical research,

and that is directly engaged in the continuous active

conduct of medical research in conjunction with a

hospital. The hospital must be described in section 501(c)

(3) or operated by the federal government, a state or its

political subdivision, a U.S. territory or its political

subdivision, or the District of Columbia.

If the organization primarily gives funds to other

organizations (or grants and scholarships to individuals)

for them to do the research, the organization isn’t a

medical research organization.

The organization isn’t required to be an affiliate of the

hospital, but there must be a joint effort by the

organization and the hospital to maintain continuing close

cooperation in the active conduct of medical research.

Tip: The definition of medical research for Schedule A

(Form 990), Part I, is different from the definition for

Schedule H (Form 990). Accordingly, research that is

medical research for purposes of determining whether an

organization is a medical research organization isn’t

Instructions for Schedule A (Form 990) 2025

necessarily medical research for Schedule H (Form 990)

reporting purposes.

Assets test/expenditure test. An organization qualifies

as a medical research organization if its principal purpose

is medical research, and if it devotes more than half its

assets, or spends at least 3.5% of the fair market value

of its endowment, directly in conducting medical

research. Either test can be met based on a computation

period consisting of the immediately preceding tax year or

the immediately preceding 4 tax years.

If an organization doesn’t satisfy either the assets test

or the expenditure test, it can still qualify as a medical

research organization based on the circumstances

involved.

These tests are discussed in Regulations sections

1.170A-9(d)(2)(v) and (vi). Under these tests, value the

organization’s assets as of any day in its tax year using the

same day every year, and value the endowment at fair

market value using commonly accepted valuation

methods. See Regulations section 2031.

Line 5. Check the box and complete Part II if the

organization receives and manages property for and

expends funds to benefit a college or university that is

owned or operated by one or more states or political

subdivisions. The school must be an organization

described in the instructions for line 2.

Expending funds to benefit a college or university

includes acquiring and maintaining the campus and its

buildings and equipment, granting scholarships and

student loans, and making any other payments in

connection with the normal functions of colleges and

universities.

The organization must meet the same public support

test described later for line 7. See Rev. Rul. 82-132,

1982-2 C.B. 107.

Line 6. Only a federal, state, or local government or

governmental unit that has received an exemption letter

recognizing it as exempt from tax under section 501(c)(3)

should check this box. See Rev. Rul. 60-384, 1960-2 C.B.

172.

Line 7. Check the box and complete Part II if the

organization meets one of the section 170(b)(1)(A)(vi)

public support tests. See the instructions for Part II

regarding how an organization can qualify as a publicly

supported organization under section 170(b)(1)(A)(vi).

Line 8. Check the box and complete Part II if the

organization is a community trust and meets a section

170(b)(1)(A)(vi) public support test. A community trust is a

charity that attracts large contributions for the benefit of

a particular community or area, often initially from a small

number of donors, and is generally governed by

representatives of its particular community or area. See

Regulations sections 1.170A-9(f)(10), (11), and (12).

Caution: A community trust claiming it qualifies as a

public charity should check the box on line 8 whether it is

structured as a corporation or as a trust.

Line 9. Check the box if the organization is an agricultural

research organization described in section 170(b)(1)(A)

(ix) operated in conjunction with a land-grant college or

3

university or a non-land-grant college of agriculture. Enter

the name, city, and state of the college or university. You

don’t have to complete Part II.

Line 10. Check the box and complete Part III if the

organization meets both of the section 509(a)(2) support

tests. See the instructions for Part III regarding how an

organization can qualify as a publicly supported

organization under section 509(a)(2).

Line 11. Check the box only if the organization has

received a ruling from the IRS that it is organized and

operated primarily to test for public safety.

Lines 12 and 12a–12d. If the organization is a

supporting organization, check the box for line 12 and

then check the appropriate box for line 12a, 12b, 12c, or

12d to indicate the type of supporting organization it is.

The organization must also complete lines 12e and 12f,

the table on line 12g, and Part IV. If the organization is a

Type III non-functionally integrated supporting

organization, it must also complete Part V.

For more information about supporting organizations,

see Regulations section 1.509(a)-4 and sections 509(a)

(3) and 509(f). For a brief overview of the requirements for

qualification as a supporting organization, and the

different types of supporting organizations, see Pub. 557,

Tax-Exempt Status for Your Organization, and go to

IRS.gov/Charities-Non-Profits/Section-509(a)(3)Supporting-Organizations.

Use the information later to determine the supporting

organization’s type. If the organization checks the box on

line 12e, the letter the organization received from the IRS

identifies its type. If the box checked on any of lines 12a

through 12d is different from the type stated in the letter

(for example, because the organization has made

significant changes to its structure or operations resulting

in it no longer qualifying as the type of supporting

organization indicated in its letter), provide an explanation

in Part VI. If the organization doesn’t check the box on

line 12e, it should check the box on line 12a, 12b, 12c, or

12d that best describes the type of supporting

organization it is.

Caution: All supporting organizations, regardless of type,

must be responsive to the needs or demands of one or

more supported organizations, and must constitute an

integral part of, or maintain a significant involvement in,

the operations of one or more supported organizations.

Although Type III supporting organizations have specific

“responsiveness” and “integral part” tests that must be

met, the relationship between a Type I or Type II

supporting organization and its supported organization(s)

must also include these responsiveness and integral part

characteristics. The ability of the supported

organization(s) in a Type I or Type II relationship effectively

to control the supporting organization’s board generally

ensures that these characteristics are present. If they

aren’t present, however, don’t check any box for lines 12a

through 12d. For more information, see Regulations

sections 1.509(a)-4(f)(3) and (4).

• Type I. A Type I supporting organization is

operated, supervised, or controlled by one or more

publicly supported organizations. If the organization

4

otherwise qualifies as a supporting organization and

can answer “Yes” to the following question, check the

box for Type I.

Do the supported organizations have a substantial

degree of direction over the policies, programs, and

activities of the supporting organization, typically by

ensuring that the governing body, officers, or

membership of the supported organizations may

regularly appoint or elect a majority of the supporting

organization’s directors or trustees?

• Type II. A Type II supporting organization is

supervised or controlled in connection with one or

more publicly supported organizations. If the

organization otherwise qualifies as a supporting

organization and can answer “Yes” to the following

question, check the box for Type II.

Do the same persons, such as directors, trustees,

and officers, supervise or control the supported

organization(s) and the supporting organization?

• Type III—functionally integrated. Check this box if

the organization qualifies as a Type III functionally

integrated supporting organization by meeting the

following requirements.

1. The organization meets the notification

requirement described in Part IV, Section D,

line 1.

2. The organization meets the responsiveness test

(both the relationship requirement and the

significant voice requirement) described in Part

IV, Section D, lines 2 and 3.

3. The organization meets one of the alternative

integral part tests described in Part IV, Section E.

• Type III—non-functionally integrated. Check this

box if the organization qualifies as a Type III

non-functionally integrated supporting organization by

meeting the following requirements.

1. The organization meets the notification

requirement described in Part IV, Section D, line 1.

2. The organization meets the responsiveness test

(both the relationship requirement and the

significant voice requirement) described in Part IV,

Section D, lines 2 and 3.

3. The organization meets the integral part test by

meeting either (a) the distribution and

attentiveness requirements described in Part V, or

(b) the alternative integral part test for certain

trusts in existence on November 20, 1970,

described in Part V, line 1.

Line 12e. The organization’s exemption letter or

subsequent determination letter may state the type of

supporting organization it is. If it does, check the box on

this line. If the letter doesn’t state the type, or if the letter

states Type III but doesn’t specify whether functionally

integrated or non-functionally integrated, leave this line

blank.

A grantor to a section 509(a)(3) supporting

organization, acting in good faith, can rely on this letter in

determining whether the organization is a Type I, Type II,

or Type III functionally integrated, or Type III

Instructions for Schedule A (Form 990) 2025

non-functionally integrated supporting organization until

the IRS makes a public announcement of the entity’s

change in status. See Rev. Proc. 2018-32, 2018-23 I.R.B.

739.

Line 12f. A supporting organization must be organized

and operated exclusively to support or benefit one or more

specified publicly supported organizations. Please write in

the space provided the number of supported

organizations. Include all supported organizations that the

organization was organized to support at any time during

the tax year, whether or not they actually received support

during the tax year.

Line 12g. An organization checking a box on line 12a,

12b, 12c, or 12d must complete the table on line 12g.

• Columns (i) and (ii). Enter the name and employer

identification number (EIN) for each supported

organization counted on line 12f. If the organization

had more than five supported organizations during the

tax year, enter the additional organizations on

duplicate pages of Schedule A (Form 990), Part I. Use

as many duplicate copies as needed, and number

each page.

• Column (iii). For each supported organization named

in column (i), enter the line number (from lines 1

through 10 above) that best describes the foundation

status of the supported organization.

Example 1. If the supported organization is a

hospital, then that is an organization described in

section 170(b)(1)(A)(iii), and you should enter “3” in

column (iii).

Example 2. If the supported organization is a

federal, state, or local governmental unit, or foreign

government, then that is an organization described in

section 170(b)(1)(A)(v), and you should enter “6” in

column (iii).

Example 3. If the supported organization is

exempt under section 501(c)(4), 501(c)(5), or 501(c)

(6), but can be supported by a supporting organization

(see Regulations section 1.509(a)-4(k)), enter the line

number (from lines 1 through 10 above) that would

describe the section 501(c)(4), 501(c)(5), or 501(c)(6)

organization if it were a section 501(c)(3) organization.

Identify the specific Code section (501(c)(4), 501(c)

(5), or 501(c)(6)) for each such supported organization

in Part VI.

Caution: The only correct entry in column (iii) is a line

number (from lines 1 through 10) that corresponds to

the description of the supported organization.

• Column (iv). Check “Yes” if the supported

organization named in column (i) is specifically named

as a supported organization in the organization’s

declaration of trust, articles of incorporation, or other

governing document. If the supported organization is

not named in the organizing documents, check “No”

and explain why in Part VI.

• Column (v). Enter the total amount of monetary

support paid to, or for the benefit of, the supported

organization named in column (i) during the tax year.

Such monetary support may include making payments

to or for the use of individual members of the

Instructions for Schedule A (Form 990) 2025

charitable class benefited by the supported

organization (such as scholarships), and to 501(c)(3)

public charities operated, supervised, or controlled

directly by or in connection with the supported

organization. See Regulations section 1.509(a)-4(e). If

no monetary support was provided during the tax year,

enter “0.”

• Column (vi). In this column, the organization may (but

isn’t required to) provide an estimate of the fair market

value of goods, other property, services, and use of

facilities that is provided to or for the benefit of the

supported organizations during the tax year. Describe

in Part VI any such goods, other property, services,

and use of facilities, whether or not an amount is

reported for them in column (vi).

Part II. Support Schedule for

Organizations Described in Sections

170(b)(1)(A)(iv) and 170(b)(1)(A)(vi)

Caution: If the organization checked a box in Part I, on

line 5, 7, or 8, it should complete Part II and insert the

appropriate dollar amounts. Don’t leave Part II blank or

report only zeros if the organization had any support

during the period. If the organization checks the box in

Part II, on line 13, it should stop there and not complete

the rest of Part II.

Tip: If the organization checked a box in Part I, on line 5,

7, or 8; and also checks the box in Part II, on line 18, the

organization should complete Part III to determine if it

qualifies as a publicly supported organization under

section 509(a)(2). If it does qualify, the organization should

instead check the box in Part I, on line 10.

Public support test. For an organization to qualify as a

publicly supported organization under section 170(b)(1)

(A)(vi), either:

• 331/3% or more of its total support must come from

governmental units, contributions from the general

public, and contributions or grants from other public

charities; or

• 10% or more of its total support must come from

governmental units, contributions from the general

public, and contributions or grants from other public

charities and the facts and circumstances indicate it is

a publicly supported organization.

Note: An organization won’t meet either of these public

support tests if almost all of its support comes from gross

receipts from related activities and an insignificant amount

of its support comes from governmental units and

contributions made directly or indirectly by the general

public.

Public support is measured using a 5-year computation

period that includes the current and 4 prior tax years

(including short years). If the organization’s current tax

year or any of its 4 prior tax years were short years,

explain in Part VI.

If the organization wasn’t a section 501(c)(3)

organization for the entire 5-year period in Part II, report

amounts only for the years the organization was a section

501(c)(3) organization.

5

Line 1. Don’t include any “unusual grants.” See Unusual

grants, later. Include membership fees only to the extent

to which the fees are payments to provide support for the

organization rather than to purchase admissions,

merchandise, services, or the use of facilities. To the

extent that the membership fees are payments to

purchase admissions, merchandise, services, or the use

of facilities in a related activity, report the membership

fees on line 12. To the extent that the membership fees

are payments to purchase admissions, merchandise,

services, or the use of facilities in an unrelated business

activity, report the membership fees on line 9. See

Regulations section 1.170A-9(f)(7)(iv). Include qualified

sponsorship payments under section 513(i).

Noncash contributions. Use any reasonable method

to determine the value of noncash contributions reported

on line 1.

Don’t report any donations of services (such as the

value of donated advertising space or broadcast air time)

or donations of use of materials, equipment, or facilities,

on line 1, as gifts, grants, or contributions. Donated

services and facilities from a governmental unit are only

reported on line 3.

Loss on uncollectible pledge. If an organization

records a loss on an uncollectible pledge that it reported

on a prior year’s Schedule A (Form 990), it should deduct

that loss from the contribution amount for the year in which

it originally counted that contribution as revenue. For

example, if in the prior tax year the organization reported a

pledged contribution with a then-present value of $50,000

in Part II, line 1, column (e), but learned during the current

tax year that it wouldn’t receive any of that pledged

contribution, it should deduct the $50,000 from the

amount reported in Part II, line 1, column (d), for the prior

tax year.

Support from a governmental unit. Include on line 1

support received from a governmental unit. This

includes contributions, but not gross receipts from

exercising or performing the organization’s tax-exempt

purpose or function, which should be reported on line 12.

An amount received from a governmental unit is treated as

gross receipts from exercising or performing the

organization’s tax-exempt purpose or function if the

purpose of the payment is primarily to serve the direct and

immediate needs of the payor governmental unit, and is

treated as a contribution, if the purpose is primarily to

provide a direct benefit to the public. For example, a

payment to maintain library facilities that are open to the

public should be treated as a contribution. See

Regulations section 1.170A-9(f)(8) and Rev. Rul. 81-276,

1981-2 C.B. 128. Refer to the instructions for Form 990,

Part VIII, lines 1e and 2, for more examples addressing the

distinction between government payments that are

contributions and government payments that are gross

receipts from activities related to the organization’s

tax-exempt purpose or function. Medicare and Medicaid

payments are treated as gross receipts from patients

rather than as contributions from the government payor for

purposes of the public support test. See Rev. Rul. 83-153,

1983-2 C.B. 48.

Program (PPP) to provide loans to small businesses as a

direct incentive to keep their workers on the payroll. The

loans are forgiven if all employee retention criteria are met

and the funds are used for eligible expenses. Amounts of

PPP loans that are forgiven may be reported on line 1 as

contributions from a governmental unit in the tax year

when the amounts are forgiven or at such other time as

provided in Rev. Proc. 2021-48, 2021-49 I.R.B. 835.

Unusual grants. Unusual grants are generally

substantial contributions and bequests from disinterested

persons and are:

1. Attracted because of the organization’s publicly

supported nature,

2. Unusual and unexpected because of the amount, and

3. Large enough to endanger the organization’s status

as normally meeting either the 331/3% public support

test or the 10%-facts-and-circumstances test.

For a list of other factors to be considered in

determining whether a grant is an unusual grant, see

Regulations section 1.509(a)-3(c)(4).

An unusual grant is excluded even if the organization

receives or accrues the funds over a period of years.

Don’t report gross investment income items as unusual

grants. Instead, include all investment income on line 8.

See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations

section 1.170A-9(f)(6)(ii); and Regulations sections

1.509(a)-3(c)(3) and (4) for details about unusual grants.

Include in Part VI a list showing the amount, but not the

grantor, of each unusual grant actually received each year

(if the cash accounting method is used) or accrued each

year (if the accrual accounting method is used).

Caution: Don’t include the names of the grantors

because Part VI will be made available for public

inspection.

Unusual grants recordkeeping. An organization that

received any unusual grants during the 5-year period

should also keep for its records a list showing, for each

year, the name of the contributor, the date and amount of

the grant, and a brief description of the grant. If the

organization used the cash method for the applicable

year, show only the amounts the organization actually

received during that year. If the organization used the

accrual method for the applicable year, show only the

amounts the organization accrued for that year. An

example of this list is given below.

Caution: Don’t file this list with the organization’s Form

990 or 990-EZ because it may be made available for

public inspection.

Line 1. Example—List of unusual grants

Year: 2025

Description

Name: Mr. Distinguished Donor

Undeveloped land

Date of Grant: January 15, 2025

Amount of Grant: $600,000

Tip: The Coronavirus Aid, Relief, and Economic Security

Act (CARES Act) established the Paycheck Protection

6

Instructions for Schedule A (Form 990) 2025

Conservation easements and qualified conservation

contributions. The organization must report any

qualified conservation contributions and contributions of

conservation easements consistently with how it reports

revenue from such contributions in its books, records, and

financial statements and in Form 990, Part VIII, Statement

of Revenue.

Reporting contributions not reported as revenue. If

the organization reports any contributions on line 1 of

Schedule A (Form 990), Part I, that it doesn’t report on

Form 990 as revenue in Part VIII or as assets in Part X, or

as revenue or assets on Form 990-EZ, explain in Part VI

the basis for characterizing such transfers as contributions

but not as revenue or assets. For example, if an

organization is a community foundation that receives and

holds a cash transfer for another tax-exempt organization

and reports contributions of such property on Schedule A

(Form 990), Part II, line 1, without reporting it on Form 990

as revenue in Part VIII or as assets in Part X, explain the

basis for characterizing the property as contributions but

not as revenue or assets.

Line 2. Enter tax revenue levied for the organization’s

benefit by a governmental unit and either paid to the

organization or expended on its behalf. Report this

amount whether or not the organization includes this

amount as revenue on its financial statements or

elsewhere on Form 990 or 990-EZ.

Line 3. Enter the value of services or facilities furnished

by a governmental unit to the organization without

charge. Don’t include the value of services or facilities

generally furnished to the public without charge. For

example, include the fair rental value of office space

furnished by a governmental unit to the organization

without charge but only if the governmental unit doesn’t

generally furnish similar office space to the public without

charge. Report these amounts whether or not the

organization includes these amounts as revenue on its

financial statements or elsewhere on Form 990 or 990-EZ.

Instructions for Schedule A (Form 990) 2025

Line 5. Enter in column (f) the portion of total

contributions by each individual, trust, or corporation

included on line 1 for the years reported that exceeds 2%

of the amount reported in line 11, column (f). In applying

the 2% limitation, all contributions made by a donor and by

any person or persons standing in a relationship to the

donor that is described in sections 4946(a)(1)(C) through

(a)(1)(G) and the related regulations (for example,

spouses and certain other family members, and entities

where ownership or control interests exceed a threshold

level) will be treated as made by one person. However, the

2% limitation doesn’t apply to contributions from

organizations qualifying as publicly supported

organizations under section 170(b)(1)(A)(vi),

governmental units described in section 170(b)(1)(A)(v),

and other organizations, such as the following, but only if

they also qualify as publicly supported organizations

under section 170(b)(1)(A)(vi).

• Churches described in section 170(b)(1)(A)(i).

• Educational institutions described in section 170(b)(1)

(A)(ii).

• Hospitals described in section 170(b)(1)(A)(iii).

• Organizations operated for the benefit of a college or

university owned or operated by a governmental unit

described in section 170(b)(1)(A)(iv).

• Agricultural research organizations described in

section 170(b)(1)(A)(ix).

The organization should keep for its records a list

showing the name of and amount contributed by each

donor (other than a governmental unit or publicly

supported organization) whose total gifts during the years

reported exceed 2% of the amount reported in line 11,

column (f). An example of this list is given later.

Caution: Don’t file this list with the organization’s Form

990 or 990-EZ because it may be made available for

public inspection.

7

Line 5. Example—List of donors other than governmental units and publicly supported organizations

Assumption: 2% of the amount on Schedule A (Form 990), Part II, line 11, column (f), is $12,000.

Contributors whose total gifts from 2021 through 2025 were in excess of the 2% limitation

Name

(a)

(b)

(c)

(d)

(e)

(f)

(g)

2021

2022

2023

2024

2025

Total

Excess

contributions

(column (f)

minus the 2%

limitation)

XYZ Foundation

Banana Office

Supply

$59,000

$12,000

Plum

Corporation

John Smith

Sue Adams

Raisin Trade

Association

$5,000

$5,000

$3,000

$18,000

$80,000

$68,000

$3,000

$1,000

$16,000

$4,000

$15,000

$15,000

$30,000

$18,000

$5,000

$1,000

$16,000

$4,000

$30,000

$18,000

$27,000

$15,000

$10,000

$10,000

$20,000

$7,000

$10,000

Total. Add the items in column (g). Enter the total here and on Part II, line 5, column (f) . . . . . . . . . . . . . . . . . . . . . . . . .

Line 8. Include the gross income from interest, dividends,

payments with respect to securities loans (section 512(a)

(5)), rents, royalties, and income from similar sources.

Don’t include on this line payments that result from

activities of the organization that further its exempt

purpose. Instead, report these amounts on line 12.

Line 9. Enter the organization’s net income from

conducting unrelated business activities, whether or not

the activities are regularly conducted as a trade or

business. See sections 512 and 513 and the applicable

regulations. Include membership fees to the extent they

are payments to purchase admissions, merchandise,

services, or the use of facilities in an activity that is an

unrelated business.

When calculating unrelated business taxable income

(UBTI) for this purpose, an exempt organization with more

than one unrelated trade or business may use either its

UBTI calculated under section 512(a)(6) or its UBTI

calculated in the aggregate. If a net loss results, enter “0”

on this line.

Line 10. Include all support as defined in section 509(d)

that isn’t included elsewhere in Part II. Explain in Part VI

the nature and source of each amount reported. Don’t

include gain or loss from amounts reportable on line 12 or

from the sale of capital assets.

Line 12. Enter the total amount of gross receipts the

organization received from related activities for all years

reported in Part II. The organization won’t be treated as

meeting the section 170(b)(1)(A)(vi), 331/3% public

support test or the 10%-facts-and-circumstances public

support test, if almost all of its support consists of gross

receipts from related activities and an insignificant amount

of its support comes from governmental units and public

contributions. See Regulations section 1.170A-9(f)(7)

(iii).

8

$127,000

Include on line 12 gross receipts from admissions,

sales of merchandise, performance of services, or

furnishing of facilities in any activity that isn’t an unrelated

trade or business (within the meaning of section 513). See

section 509(d)(2). Include membership fees to the extent

they are payments to purchase admissions, merchandise,

services, or the use of facilities in a related activity. For

example, include on this line gross receipts from the

following.

• A trade or business in which substantially all work is

performed by volunteers (such as book fairs and

sales of gift wrap paper). See section 513(a)(1).

• A trade or business carried on by the organization

primarily for the convenience of its members,

students, patients, officers, or employees. See

section 513(a)(2).

• A trade or business that is the selling of merchandise,

substantially all of which the organization received as

gifts or contributions. See section 513(a)(3).

• “Qualified public entertainment activities” or “qualified

convention and trade show activities” of certain

organizations. See section 513(d).

• Furnishing certain hospital services. See section

513(e).

• A trade or business consisting of conducting bingo

games, but only if the conduct of such games is lawful.

See section 513(f).

• Qualified pole rentals by a mutual or cooperative

telephone or electric company. See section 513(g).

• The distribution of certain low-cost articles incidental

to the solicitation of charitable contributions (except to

the extent such gross receipts are properly treated as

charitable contributions reportable on line 1 rather

than as proceeds of a sale or exchange), and

exchange and rental of members lists. See section

513(h).

Line 13. An organization that checks this box should stop

here and shouldn’t complete the rest of Part II. It shouldn’t

Instructions for Schedule A (Form 990) 2025

make a public support computation on line 14 or 15 or

check any of the boxes on lines 16 through 18.

Example. An organization receives an exemption letter

from the IRS that it is exempt from tax under section

501(c)(3) and qualifies as a public charity under section

170(b)(1)(A)(vi) effective on its date of incorporation.

When the organization prepares Part II for each of its first

5 tax years as a section 501(c)(3) organization, it should

check the box on line 13 and shouldn’t complete the rest

of Part II. When the organization prepares Part II for its

sixth tax year and subsequent years, it shouldn’t check the

box on line 13 and should complete the rest of Part II.

Tip: An organization in its first 5 years as a section 501(c)

(3) organization should make the public support

computations on a copy of Schedule A (Form 990) that it

keeps for itself. An organization should carefully monitor

its public support on an ongoing basis to ensure that it will

meet a public support test in the sixth year and

succeeding years.

Line 14. Round to the nearest hundredth decimal point in

reporting the percentage of public support. For example, if

the organization calculates its public support percentage

as 58.3456%, this percentage would be rounded to

58.35% when reported on line 14.

Line 15. For 2025, enter the public support percentage

from the 2024 Schedule A (Form 990), Part II, line 14.

Round to the nearest hundredth decimal point in reporting

the percentage of public support.

Line 16a. If the organization didn’t check the box on

line 13, and line 14 is 331/3% or more, check the box on

this line and don’t complete the rest of Part II. The

organization qualifies as a publicly supported organization

for 2025 and 2026.

Line 16b. If the organization didn’t check a box on line 13

or 16a, and line 15 is 331/3% or more, check the box on

this line and don’t complete the rest of Part II. The

organization qualifies as a publicly supported organization

for 2025.

Line 17a. If the organization didn’t check a box on

line 13, 16a, or 16b, and line 14 is 10% or more, and if the

organization meets the facts-and-circumstances test,

check the box on this line and don’t complete the

rest of Part II. The organization qualifies as a publicly

supported organization for 2025 and 2026.

If this box is checked, explain in Part VI how the

organization meets the facts-and-circumstances test in

Regulations section 1.170A-9(f)(3). Include the following

information.

• Explain whether the organization maintains a

continuous and bona fide program for solicitation of

funds from the general public, community,

membership group involved, governmental units, or

other public charities.

• List all other facts and circumstances, including the

sources of support, whether the organization has a

governing body that represents the broad interests

of the public, and whether the organization generally

provides facilities or services directly for the benefit of

the general public on a continuing basis.

Instructions for Schedule A (Form 990) 2025

• If the organization is a membership organization,

explain whether the solicitation for dues-paying

members is designed to enroll a substantial number of

persons from the community, whether dues for

individual members have been fixed at rates designed

to make membership available to a broad cross

section of the interested public, and whether the

activities of the organization will likely appeal to

persons having some broad common interest or

purpose.

Line 17b. If the organization didn’t check a box on

line 13, 16a, 16b, or 17a, and line 15 is 10% or more, and

if the organization meets the facts-and-circumstances

test, check the box on this line and don’t complete

the rest of Part II. The organization qualifies as a publicly

supported organization for 2025. If this box is checked,

explain in Part VI how the organization meets the

facts-and-circumstances test in Regulations section

1.170A-9(f)(3). Include the same information identified in

the instructions for line 17a, earlier.

Line 18. If the organization didn’t check a box on line 13,

16a, 16b, 17a, or 17b, it doesn’t qualify as a publicly

supported organization under section 170(b)(1)(A)(iv) or

170(b)(1)(A)(vi) for the 2025 tax year and should check

the box on this line. If the organization doesn’t qualify as a

public charity under any of the boxes on Part I, lines 1

through 12, it is a private foundation as of the beginning of

the 2025 tax year for filing purposes and shouldn’t file

Form 990, Form 990-EZ, or Schedule A (Form 990) for the

2025 tax year. Instead, the organization should file Form

990-PF and check “Initial return of a former public charity”

on Form 990-PF at the top of page 1.

Tip: If Form 990 or 990-EZ is for the organization’s sixth

tax year as a section 501(c)(3) organization, the

organization should figure the public support percentage

on its Form 990 or 990-EZ for its first 5 tax years before it

checks the box on line 18. If its public support percentage

for its first 5 tax years is 331/3% or more, or if it meets the

10%-facts-and-circumstances test for its first 5 tax years, it

will qualify as a public charity for its sixth tax year. If the

organization qualifies under the 10% test, explain in Part

VI.

Tip: If the organization doesn’t qualify as a publicly

supported organization under section 170(b)(1)(A)(vi), it

can complete Part III to determine if it qualifies as a

publicly supported organization under section 509(a)(2).

Part III. Support Schedule for

Organizations Described in Section

509(a)(2)

Tip: If an organization checked the box in Part I, for

line 10, it should complete Part III and insert the

appropriate dollar amounts. Don’t leave Part III blank or

report only zeros if the organization had any support

during the period. If the organization checks the box in

Part III, for line 14, it should stop there and not complete

the rest of Part III.

Tip: If the organization checked the box in Part I, for

line 10, and also checks the box in Part III, for line 20, the

9

organization should complete Part II to determine if it

qualifies as a publicly supported organization under

section 170(b)(1)(A)(vi). If it does qualify, the organization

should instead check the box in Part I, for line 5, 7, or 8,

whichever applies.

Public support test. For an organization to qualify as a

publicly supported organization under section 509(a)(2):

• More than 331/3% of its support normally must come

from gifts; grants; contributions; membership fees;

and gross receipts from admissions, sales of

merchandise, performance of services, or furnishing

of facilities in an activity that isn’t an unrelated trade

or business under section 513; and

• No more than 331/3% of its support must normally

come from gross investment income and net

unrelated business income (less section 511 tax)

from businesses acquired by the organization after

June 30, 1975.

Public support is measured using a 5-year computation

period that includes the current and 4 prior tax years

(including short years). If the organization’s current tax

year or any of its 4 prior tax years were short years,

explain in Part VI.

In Part III, if the organization wasn’t a section 501(c)(3)

organization for the entire 5-year period, report amounts

only for the years the organization was a section 501(c)(3)

organization.

Line 1. Don’t include any “unusual grants.” See Unusual

grants, later. Include membership fees only to the extent

to which the fees are payments to provide support for the

organization rather than to purchase admissions,

merchandise, services, or the use of facilities. To the

extent that the membership fees are payments to

purchase admissions, merchandise, services, or the use

of facilities in a related activity, include the membership

fees on line 2. See Regulations section 1.509(a)-3(h). To

the extent that the membership fees are payments to

purchase admissions, merchandise, services, or the use

of facilities in an activity that isn’t an unrelated business

under section 513, report the membership fees on line 3.

To the extent that the membership fees are payments to

purchase admissions, merchandise, services, or the use

of facilities in an activity that is an unrelated business,

report the net amount either on line 10b or 11, as

appropriate.

Noncash contributions. Use any reasonable method

to determine the value of noncash contributions reported

on line 1.

Don’t report any donations of services (such as the

value of donated advertising space or broadcast air time)

or donations of use of materials, equipment, or facilities on

line 1 as gifts, grants, or contributions. Donated services

and facilities from a governmental unit are reported on

line 5.

Loss on uncollectible pledge. If an organization

records a loss on an uncollectible pledge that it reported

on a prior year’s Schedule A (Form 990), it should deduct

that loss from the contribution amount for the year in which

it originally counted that contribution as revenue. For

example, if in the prior tax year the organization reported a

pledged contribution with a then-present value of $50,000

10

in Part III, line 1, column (e), but learned during the current

tax year that it wouldn’t receive any of that pledged

contribution, it should deduct the $50,000 from the

amount reported in Part III, line 1, column (d), for the prior

tax year.

Support from a governmental unit. Include on line 1

support received from a governmental unit. This

includes contributions, but not gross receipts from

exercising or performing the organization’s tax-exempt

purpose or function, which should be reported on line 2.

Contributions are sometimes difficult to distinguish from

such gross receipts—the label on the agreement isn’t

controlling. An amount received from a governmental unit

is treated as gross receipts from exercising or performing

the organization’s tax-exempt purpose or function if the

purpose of the payment is primarily to serve the direct and

immediate needs of the payor governmental unit. An

amount is treated as a contribution if the purpose of the

payment is primarily to provide a direct benefit to the

public. For example, if a state government agency pays an

organization to operate an institute to train agency

employees in the principles of management and

administration, the funds received should be included on

line 2 as gross receipts. See Regulations section

1.509(a)-3(g). Refer to the instructions for Form 990, Part

VIII, lines 1e and 2, for more examples addressing the

distinction between government payments that are

contributions and government payments that are gross

receipts from activities related to the organization’s

tax-exempt purpose or function. Medicare and Medicaid

payments are treated as gross receipts from patients

rather than as contributions from the government payor for

purposes of the public support test. See Rev. Rul. 83-153,

1983-2 C.B. 48.

Tip: The CARES ACT established the PPP to provide

loans to small businesses as a direct incentive to keep

their workers on the payroll. The loans are forgiven if all

employee retention criteria are met and the funds are

used for eligible expenses. Amounts of PPP loans that are

forgiven may be reported on line 1 as contributions from a

governmental unit in the tax year when the amounts are

forgiven or at such other time as provided in Rev. Proc.

2021-48, 2021-49 I.R.B. 835.

Unusual grants. Unusual grants are generally

substantial contributions and bequests from

disinterested persons and are:

1. Attracted because of the organization’s publicly

supported nature,

2. Unusual and unexpected because of the amount, and

3. Large enough to endanger the organization’s status

as normally meeting the 331/3% public support test.

For a list of other factors to be considered in

determining whether a grant is an unusual grant, see

Regulations section 1.509(a)-3(c)(4).

An unusual grant is excluded even if the organization

receives or accrues the funds over a period of years.

Don’t report gross investment income items as unusual

grants. Instead, include all investment income on line 10a.

Instructions for Schedule A (Form 990) 2025

See Rev. Rul. 76-440, 1976-2 C.B. 58; Regulations

section 1.170A-9(f)(6)(ii); and Regulations sections

1.509(a)-3(c)(3) and (4) for details about unusual grants.

Include in Part VI a list showing the amount, but not the

grantor, of each unusual grant actually received each year

(if the cash accounting method is used) or accrued each

year (if the accrual accounting method is used).

Caution: Don’t include the names of the grantors

because Part VI will be made available for public

inspection.

Unusual grants recordkeeping. An organization that

received any unusual grants during the 5-year period

should also keep for its records a list showing, for each

year, the name of the contributor, the date and amount of

the grant, and a brief description of the grant. If the

organization used the cash method for the applicable

year, show only amounts the organization actually

received during that year. If the organization used the

accrual method for the applicable year, show only

amounts the organization accrued for that year. An

example of this list is given below.

Caution: Don’t file this list with the organization’s Form

990 or 990-EZ because it may be made available for

public inspection.

Line 1. Example—List of unusual grants

Year: 2025

Description

Name: Mr. Distinguished Donor

Undeveloped land

Date of Grant: January 15, 2025

Amount of Grant: $600,000

Conservation easements and qualified conservation

contributions. The organization must report any

qualified conservation contributions and contributions of

conservation easements consistently with how it reports

revenue from such contributions in its books, records, and

financial statements and in Form 990, Part VIII, Statement

of Revenue.

Reporting contributions not reported as revenue. If

the organization reports any contributions on

Schedule A (Form 990), Part III, line 1, that it doesn’t

report on Form 990, as revenue in Part VIII or as assets in

Part X, or as revenue or assets on Form 990-EZ, explain in

Part VI the basis for characterizing such transfers as

contributions but not as revenue or assets. For example, if

an organization is a community foundation that receives

and holds a cash transfer for another tax-exempt

organization and reports contributions of such property on

Schedule A (Form 990), Part III, line 1, without reporting it

on Form 990, as revenue in Part VIII or as assets in Part X,

explain the basis for characterizing the property as

contributions but not as revenue or assets.

Line 2. Include gross receipts from admissions,

merchandise sold, services performed, or facilities

furnished in any activity that is related to the organization’s

tax-exempt purpose (such as charitable, educational,

etc.).

To the extent that membership fees are payments to

purchase admissions, merchandise, services, or the use

Instructions for Schedule A (Form 990) 2025

of facilities in a related activity, include the membership

fees on this line 2. See Regulations section 1.509(a)-3(h).

Line 3. Include gross receipts from activities that aren’t

an unrelated trade or business under section 513, such as

the following.

• A trade or business in which substantially all work is

performed by volunteers (such as book fairs and

sales of gift wrap paper). See section 513(a)(1).

• A trade or business carried on by the organization

primarily for the convenience of its members,

students, patients, officers, or employees. See

section 513(a)(2).

• A trade or business that is the selling of merchandise,

substantially all of which the organization received as

gifts or contributions. See section 513(a)(3).

• “Qualified public entertainment activities” or “qualified

convention and trade show activities” of certain

organizations. See section 513(d).

• Furnishing certain hospital services. See section

513(e).

• A trade or business consisting of conducting bingo

games, but only if the conduct of such games is lawful.

See section 513(f).

• Qualified pole rentals by a mutual or cooperative

telephone or electric company. See section 513(g).

• The distribution of certain low-cost articles incidental

to the solicitation of charitable contributions (except to

the extent such gross receipts are properly treated as

charitable contributions reportable on line 1 rather

than as proceeds of a sale or exchange), and

exchange and rental of members lists. See section

513(h).

While the activity of soliciting and receiving qualified

sponsorship payments is also excluded from unrelated

business (see section 513(i)), the qualified sponsorship

payments themselves are treated as charitable

contributions reportable on line 1.

Line 4. Enter tax revenue levied for the organization’s

benefit by a governmental unit and either paid to the

organization or expended on its behalf. Report this

amount whether or not the organization includes this

amount as revenue on its financial statements or

elsewhere on Form 990 or 990-EZ.

Line 5. Enter the value of services or facilities furnished

by a governmental unit to the organization without charge.

Don’t include the value of services or facilities generally

furnished to the public without charge. For example,

include the fair rental value of office space furnished by a

governmental unit to the organization without charge, but

only if the governmental unit doesn’t generally furnish

similar office space to the public without charge. Report

these amounts whether or not the organization includes

these amounts as revenue on its financial statements or

elsewhere on Form 990 or 990-EZ.

Line 7a. Enter the amounts that are included on lines 1,

2, and 3 that the organization received from disqualified

persons. See the definition of disqualified person in the

Glossary of the Instructions for Form 990.

For amounts included on lines 1, 2, and 3 that were

received from a disqualified person, the organization

should keep for its records a list showing the name of, and

11

Line 7a. Example—List of amounts received from disqualified persons

Disqualified person

(a) 2021

(b) 2022

David Smith

$7,000

$6,000

Anne Parker

Total

$7,000

$6,000

(c) 2023

(d) 2024

$5,000

$7,000

$5,000

$7,000

(e) 2025

(f) Total

$2,000

$15,000

$4,000

$16,000

$6,000

$31,000

Line 7b. Example—List of amounts received from other than disqualified persons

Year 2025

(a) Name

Word Processing, Inc.

(b) Amount received in

2025

(c) 1% of amount on

line 13 in 2025

(d) Enter the larger of

column (c) or $5,000

(e) 2025 excess

(column (b) minus

column (d))

$25,000

$2,000

$5,000

$20,000

Enter on Schedule A (Form 990), column (e), line 7b . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

total amounts received in each year from, each

disqualified person. Enter the total of such amounts for

each year on line 7a. See an example of this list above.

Caution: Don’t file this list with the organization’s Form

990 or 990-EZ because it may be made available for

public inspection.

Line 7b. For any gross receipts included on lines 2 and 3

from related activities received from a person or from a

bureau or similar agency of a governmental unit, other

than from a disqualified person, that exceed the greater

of $5,000 or 1% of the amount on line 13 for the

applicable year, enter the excess on line 7b. The

organization should keep for its records a list showing, for

each year, the name of the person or government agency,

the amount received during the applicable year, the larger

of $5,000 or 1% of the amount on line 13 for the

applicable year, and the excess, if any. See an example of

this list above.

Caution: Don’t file this list with the organization’s Form

990 or 990-EZ because it may be made available for

public inspection.

Line 10a. Include the gross income from interest,

dividends, payments received on securities loans (section

512(a)(5)), rents, royalties, and income from similar

sources. Don’t include on this line payments that result

from activities of the organization that further its exempt

purpose. Instead, report these amounts on line 2.

Line 10b. Enter the excess of the organization’s UBTI (as

defined in section 512) from trades or businesses that it

acquired or commenced after June 30, 1975, over the

amount of tax imposed on this income under section 511.

Include membership fees to the extent they are payments

to purchase admissions, merchandise, services, or the

use of facilities in an unrelated business activity that is a

trade or business that was acquired or commenced after

June 30, 1975.

When calculating UBTI for this purpose, an exempt

organization with more than one unrelated trade or

12

$20,000

business may use either its UBTI calculated under section

512(a)(6) or its UBTI calculated in the aggregate.

Line 11. Enter the organization’s net income from

conducting unrelated business activities not included on

line 10b, whether or not the activities are regularly

conducted as a trade or business. Don’t include net

income from conducting trades or businesses acquired or

commenced by the organization prior to July 1, 1975. See

sections 512, 513, and 514, and the applicable

regulations. Include membership fees to the extent they

are payments to purchase admissions, merchandise,

services, or the use of facilities in an activity that is an

unrelated business not included on line 10b.

When calculating UBTI for this purpose, an exempt

organization with more than one unrelated trade or

business may use either its UBTI calculated under section

512(a)(6) or its UBTI calculated in the aggregate. If a net

loss results, enter “0” on this line.

Line 12. Include all support as defined in section 509(d)

that isn’t included elsewhere in Part III. Explain in Part VI

the nature and source of each amount reported. Don’t

include gain or loss from the sale of capital assets.

Line 14. An organization that checks this box should stop

here and shouldn’t complete the rest of Part III. It shouldn’t

make a public support computation on line 15 or 16 or an

investment income computation on line 17 or 18, or check

any of the boxes for line 19 or 20.

Example. An organization receives an exemption letter

from the IRS that it is exempt from tax under section

501(c)(3) and qualifies as a public charity under section

509(a)(2) effective on its date of incorporation. When the

organization prepares Part III for its first 5 tax years, it

should check the box on line 14 and shouldn’t complete

the rest of Part III. When the organization prepares Part III

for its sixth tax year and subsequent years, it shouldn’t

check the box on line 14 and should complete the rest of

Part III.

Tip: An organization in its first 5 years as a section 501(c)

(3) organization should make the public support and

investment income computations on a copy of Schedule A

Instructions for Schedule A (Form 990) 2025

(Form 990) that it keeps for itself. An organization should

carefully monitor its public support on an ongoing basis to

ensure that it will meet the public support tests in the sixth

year and succeeding years.

Line 15. Round to the nearest hundredth decimal point in

reporting the percentage of public support. For example, if

the organization calculates its public support percentage

as 58.3456%, this percentage would be rounded to

58.35% when reported on line 15.

Line 16. For 2025, enter the public support percentage

from 2024 Schedule A (Form 990), Part III, line 15. Round

to the nearest hundredth decimal point in reporting the

percentage of public support.

Line 17. Round to the nearest whole percentage.

Line 18. For 2025, enter the investment income

percentage from 2024 Schedule A (Form 990), Part III,

line 17. Round to the nearest whole percentage.

Line 19a. If the organization didn’t check the box on

line 14, line 15 is more than 331/3%, and line 17 isn’t more

than 331/3%, check the box on this line and don’t

complete the rest of this schedule. The organization

qualifies as a publicly supported organization for 2025 and

2026.

Line 19b. If the organization didn’t check the box on

line 14 or 19a, line 16 is more than 331/3%, and line 18

isn’t more than 331/3%, check the box on this line and

don’t complete the rest of this schedule. The

organization qualifies as a publicly supported organization

for 2025.

Line 20. If the organization didn’t check the box on

line 14, 19a, or 19b, it doesn’t qualify as a publicly

supported organization under section 509(a)(2) for the

2025 tax year and should check the box on this line. If the

organization doesn’t qualify as a public charity under any

of the boxes on Schedule A (Form 990), Part I, lines 1

through 12, it is a private foundation for filing purposes as

of the beginning of the tax year and shouldn’t file Form

990, Form 990-EZ, or Schedule A (Form 990) for the 2025

tax year. Instead, the organization should file Form 990-PF

and check “Initial return of a former public charity” on Form

990-PF at the top of page 1.

Tip: If Form 990 or 990-EZ is for the organization’s sixth

tax year as a section 501(c)(3) organization and it

checked the box on line 20, it should figure the public

support percentage and the investment income

percentage on its Form 990 for its first 5 tax years. If its

public support percentage for its first 5 tax years is more

than 331/3% and the investment income percentage for its

first 5 tax years isn’t more than 331/3%, it will qualify as a

public charity for its sixth tax year. If the organization

qualifies in this manner, explain in Part VI.

Tip: If the organization doesn’t qualify as a publicly

supported organization under section 509(a)(2), it can

complete Part II to determine if the organization qualifies

as a publicly supported organization under section 170(b)

(1)(A)(vi).

Instructions for Schedule A (Form 990) 2025

Part IV. Supporting Organizations

Complete the sections of Part IV that correspond below

with the type of supporting organization indicated on

line 12a, 12b, 12c, or 12d of Part I.

• Type I: Sections A and B.

• Type II: Sections A and C.

• Type III functionally integrated: Sections A, D, and E.

• Type III non-functionally integrated: Sections A and D,

and Part V.

Section A. All Supporting Organizations

Line 1. The organization’s articles of incorporation or

trust instrument must designate the publicly supported

organization(s) on whose behalf the supporting

organization is operated. The articles of a Type I or Type II

supporting organization may designate its supported

organization(s) either by class or purpose or by name. The

articles of a Type III supporting organization must

designate the supported organization(s) by name, unless

a historic and continuing relationship exists between the

organizations.

Check “Yes” only if the organization supports no

organization other than those listed by name in its

governing instrument. If the organization supports any

organization not specifically listed, check “No” and

describe in Part VI how the supported organizations are

designated. If designated by class or purpose, describe

the class or purpose. If the organization and its supported

organization(s) have a historic and continuing relationship,

explain that relationship. If support of one or more

organizations is subject to certain future contingencies,

explain those contingencies, and explain what

organizations will be supported or benefited if those

contingencies occur.

Line 2. If the organization supported any domestic or

foreign organization (other than an organization described

in section 501(c)(4), (5), or (6)) that didn’t have an IRS

determination of status under section 509(a)(1) or (2),

check “Yes” and explain in Part VI how the organization

determined that the supported organization was described

in section 509(a)(1) or (2) and why the supported

organization doesn’t have such an IRS determination (for

example, because it has applied for but not yet received

such a determination, or it isn’t required to obtain

recognition of its public charity status because it is a

church, a state university, or described in section

4948(b)).

Line 3a. A supporting organization may support an

organization described in section 501(c)(4), (5), or (6) if

the supported organization satisfies the public support

tests applicable to a section 509(a)(2) organization. See

Regulations section 1.509(a)-4(k) and the instructions for

Part III. If the organization supports a section 501(c)(4),

(5), or (6) organization, check “Yes” for line 3a.

Line 3b. If the organization confirmed that the supported

organization qualified under section 501(c)(4), (5), or (6)

and met the section 509(a)(2) public support test for its

most recent tax year, check “Yes” and describe in Part VI

how the organization made this determination. For

example, the organization may ask its section 501(c)(4),

(5), or (6) supported organization to furnish a copy of its

13

IRS determination letter and to complete annually a pro

forma Schedule A (Form 990), Part III, and keep the letter

and support calculation in the supporting organization’s

files.

If the supporting organization doesn’t annually confirm

that its supported organization satisfies the section 509(a)

(2) public support test, it must explain in Part VI how it

knows that the supported organization would’ve been

described in section 509(a)(2) if it were described in

section 501(c)(3) during the tax year.

Line 3c. Support given to a supported section 501(c)(4),

(5), or (6) organization must be used solely for charitable

purposes. If the supporting organization has put into place

measures to ensure that such support is used solely for

charitable purposes, check “Yes” and describe those

measures in Part VI. If not, check “No” and describe in

Part VI how the supporting organization ensured during

the tax year that its assets were used solely for charitable

purposes.

Line 4a. A supporting organization can’t qualify for Type

III status in the tax year if any supported organization

wasn’t organized in the United States.

Lines 4b and 4c. A supporting organization must

exercise control and discretion over funds granted to an

organization that isn’t exempt under section 501(c)(3).

See Rev. Rul. 68-489, 1968-2 C.B. 210. Also, a domestic

charity must generally exercise control and discretion over

funds granted to a foreign organization. See Rev. Rul.

63-252, 1963-2 C.B. 101; and Rev. Rul. 66-79, 1966-1

C.B. 48.

Explain in Part VI how the organization retained such

control and discretion despite being controlled or

supervised by or in connection with such foreign

supported organization(s). Also, explain what controls the

organization used to ensure that all support to the foreign

supported organization(s) was used exclusively for

charitable, educational, etc., purposes described in

section 170(c)(2)(B) if the foreign supported organization

doesn’t have an IRS determination under sections 501(c)

(3) and 509(a)(1) or (2).

Line 5. Supporting organizations may add, substitute, or

remove supported organizations only in certain limited

situations. See Regulations section 1.509(a)-4(d).

Generally, a Type I or Type II supporting organization may

add or substitute particular supported organizations within

the class or classes designated in its articles, but may not

add or substitute supported organizations outside of the

designated class(es). A Type III supporting organization,

which must specify its supported organizations by name,

may only substitute supported organizations if such

substitution is conditioned upon the occurrence of an

event that is beyond the control of the supporting

organization (such as a supported organization’s lapse

into private foundation status).

If the organization has added, substituted, or removed

any supported organization during the tax year, check

“Yes” and provide detail in Part VI, including (i) the names

and EINs of the organizations added, substituted, or

removed; (ii) the reasons for each addition, substitution, or

removal; (iii) the authority under the organization’s

organizing document for each addition, substitution, or

14

removal; and (iv) an explanation of how the action was

accomplished (such as by amendment to the organizing

document substituting a new supported organization).

Line 6. A supporting organization must engage solely in

activities that support or benefit its supported

organization(s). In addition to making grants and providing

services and facilities directly to its supported

organization(s), a supporting organization may also

generally make grants or provide services or facilities to

(1) individual members of the charitable class benefited by

its supported organization(s), or (2) other supporting

organizations that also support or benefit its supported

organization(s). See Regulations section 1.509(a)-4(e). If

the organization made any grants or provided any benefits

to any other organization or individual, check “Yes” and

provide detail in Part VI.

Lines 7 and 8. Under section 4958(c)(3), any grant, loan,

compensation, or other similar payment provided by a

supporting organization to a substantial contributor

(defined in section 4958(c)(3)(C)), to a family member

(defined in section 4958(f)(4)), and to a 35% controlled

entity of such persons, is considered a per se excess

benefit in its entirety, regardless of the fairness or

reasonableness of the payment, and is subject to tax

under section 4958(a). The same is true of any loan by a

supporting organization to a disqualified person under

section 4958 (other than loans to certain exempt

organizations). If the organization made any such

payment or loan during the tax year, check “Yes” and

report the transaction on Schedule L (Form 990),

Transactions With Interested Persons, Part I. For more

information on excess benefit transactions generally, see

the Instructions for Schedule L (Form 990).

Line 9. A supporting organization may not be controlled

by disqualified persons, as defined in section 4946.

Section 509(a)(1) or (2) organizations, and foundation

managers who are disqualified persons only as a result of

being foundation managers, aren’t treated as disqualified

persons for this purpose. Impermissible control may be

direct or indirect. If a disqualified person holds any of the

interests described on line 9b or 9c, or derives personal

benefit from any such assets, provide detail in Part VI.

Line 10. Under section 4943(f), a Type II supporting

organization that accepts a contribution from a person

who controls the governing body of a supported

organization (or from a family member of such person, or

from a 35% controlled entity of such person) is subject

to the excess business holdings tax under section 4943.

All Type III non-functionally integrated supporting

organizations are also generally subject to the tax. For

more information about excess business holdings, see the

Instructions for Form 4720, Return of Certain Excise Taxes

Under Chapters 41 and 42 of the Internal Revenue Code.

Line 11. Section 509(f)(2) prohibits Type I and Type III

supporting organizations from accepting a gift or

contribution from certain persons associated with a

supported organization of such supporting organization.

Specifically, if a Type I or Type III supporting organization

accepts a contribution after August 16, 2006, from a

person who controls the governing body of a supported

organization (or from a family member of such person, or

Instructions for Schedule A (Form 990) 2025

from a 35% controlled entity of such person), then the

supporting organization loses its status as a supporting

organization. Such supporting organization must file Form

990-PF unless it qualifies as a public charity under section

509(a)(1) or (2).

Section B. Type I Supporting Organizations

Line 1. A Type I supporting organization must be

operated, supervised, or controlled by one or more of its

supported organizations (the “controlling supported

organizations”). This means that the controlling supported

organizations must have a substantial degree of direction

over the policies, programs, and activities of the

supporting organization; and the supporting organization

in turn must be responsive to the needs or demands of the

controlling supported organizations, and must constitute

an integral part of, or maintain a significant involvement in,

the operations of the controlling supported organizations.

This relationship is most clearly established when one or

more supported organizations (through their officers,

directors, trustees, or membership) have the unconditional

power to remove and replace at least a majority of the

supporting organization’s directors or trustees at any time.

The relationship is also commonly established when one

or more supported organizations have the power to

appoint or elect at least a majority of the supporting

organization’s directors or trustees at regular intervals.

However, there may be other ways to establish this

relationship. If the organization relies on other ways to

establish the relationship, check “No” and describe in Part

VI how the necessary relationship is established.

Line 2. The supporting organization may benefit

organizations that don’t participate in the control

relationship described on line 1, but only if such activity

carries out the purposes of the controlling supported

organizations.

Section C. Type II Supporting Organizations

Line 1. A Type II supporting organization must be

supervised or controlled in connection with its supported

organization(s). This means that there must be common

supervision or control by the persons supervising or

controlling both the supporting organization and the

supported organization(s) to ensure that the supporting

organization will be responsive to the needs and

requirements of the supported organization(s). This

relationship is most clearly established when the same

persons serve as all or a majority of the directors or

trustees of all of the organizations involved. However,

there may be other ways to establish this relationship. If

the organization relies on other than overlap of at least a

majority of directors or trustees of all organizations

involved, check “No” and describe in Part VI how the

necessary relationship is established.

Section D. All Type III Supporting Organizations

Line 1. A Type III supporting organization must supply

annually a written notice, addressed to a principal officer

of each supported organization, which includes the

following.

Instructions for Schedule A (Form 990) 2025

1. A description of the type and amount of all support,

including any amounts counting toward the

distribution requirement (as described in Regulations

section 1.509(a)-4(i)(6)), the supporting organization

provided to the supported organization during the

supporting organization’s tax year preceding the tax

year in which the notice is provided, including a brief

narrative description and sufficient financial detail for

the recipient to identify the types and amounts of

support being reported.

2. A copy of the supporting organization’s most recently

filed Form 990 (the supporting organization may

redact the names and addresses of contributors).

3. A copy of the supporting organization’s updated

governing documents (including articles of

organization, bylaws, and any amendments), to the

extent not previously provided.

See Regulations section 1.509(a)-4(i)(2). The notice must

be submitted by the last day of the fifth month of the

supporting organization’s tax year being reported (May 31

for calendar-year filers). An organization that doesn’t

timely submit the required information in the required

manner doesn’t qualify as a Type III supporting

organization for the tax year in which it fails to timely

submit.

State whether during the tax year being reported the

organization provided a timely notice with the required

information in the required manner.

Lines 2 and 3. A Type III supporting organization must

be responsive to the needs or demands of each of its

supported organizations. An organization meets this

responsiveness test with regard to each supported

organization if:

1. The supported organization has an adequate

relationship with the supporting organization because:

a. The supported organization regularly appoints

or elects (whether or not during the tax year) at

least one officer, director, or trustee of the

supporting organization;

b. At least one member of the governing body of

the supported organization also serves as an

officer, director, or trustee of the supporting

organization; or

c. The officers, directors, or trustees of the

supporting organization and of the supported

organization maintain a close and continuous

working relationship; and

2. Because of this relationship, the supported

organization has a significant voice in the supporting

organization’s investment policies, timing of grants,

manner of making grants, selection of grant

recipients, and other use of income or assets (the

“significant voice” test).

In the case of a supporting organization that supported

a supported organization before November 20, 1970,

additional facts and circumstances such as a historic and

continuing relationship between the organizations may

also be taken into account in considering the

responsiveness test.

15

If the organization has an adequate relationship with at

least one supported organization only by means of a

“close and continuous working relationship” or a “historic

and continuing relationship,” then in Part V explain the

relationship and how it has been maintained. Also, all

Type III supporting organizations that claim to meet the

significant voice test must describe in Part VI the voice or

role of the supported organization(s) in directing the

supporting organization’s use of its income or assets.

Section E. Type III Functionally Integrated

Supporting Organizations

Line 1. A Type III supporting organization must constitute

an integral part of one or more of its supported

organizations by maintaining significant involvement in its

operations and providing support on which the supported

organization is dependent. To satisfy this requirement as a

Type III functionally integrated supporting organization, an

organization may (a) pass an activities test (see the

instructions for line 2, later), (b) be the parent of its

supported organizations (see the instructions for line 3,

later), or (c) support governmental supported

organizations (see Support of governmental supported

organizations, later). If the organization can’t satisfy any of

these tests, it may still qualify as a Type III non-functionally

integrated supporting organization. See Part V, later.

Support of governmental supported organizations.

A Type III supporting organization meets the integral part

test for a functionally integrated supporting organization if

it (1) only supports one or more governmental

organizations (as discussed in the instructions for

Section D under Lines 2 and 3, earlier), and (2) a

substantial part of the supporting organization’s activities

directly further the exempt purposes of at least one

governmental supported organization; and (3) if the

supporting organization supports more than one

governmental supported organization, all of the

governmental supported organizations either (1) operate

within the same city, county, or metropolitan area; or (2)

work in close coordination or collaboration together to

conduct a service, program, or activity that the supporting

organization supports.

Line 2. Activities Test. To meet the activities test of a

Type III functionally integrated supporting organization,

substantially all of the supporting organization’s activities

must (1) directly further the exempt purposes of one or

more supported organization, and (2) be activities that

such supported organization(s) would normally be

engaged in but for the supporting organization’s

involvement.

Direct furtherance. Substantially all of the supporting

organization’s activities must be “direct furtherance”

activities. Direct furtherance activities are conducted by

the supporting organization itself, rather than by a

supported organization. Holding title to exempt-use assets

and managing them are direct furtherance activities.

Fundraising, investing and managing non-exempt-use

assets, grant-making to organizations, and grant-making

to individuals (unless it meets the requirements of

Regulations section 1.509(a)-4(i)(4)(ii)(D)) aren’t direct

furtherance activities.

16

But for. In addition, the direct furtherance activities

must be activities in which, but for the supporting

organization’s involvement, the supported organization

would normally be involved.

Examples include holding and managing facilities used

by a church for its religious purposes, operating a food

pantry for a group of churches that normally would operate

food pantries themselves, and maintaining local parks for

a community foundation that would otherwise maintain

those parks. See Regulations section 1.509(a)-4(i)(4)(v)

for more detailed examples.

Line 3. Parent of Supported Organizations. To qualify

as the parent of each of its supported organizations, (1)

the supporting organization and its supported

organizations must be part of an integrated system (for

example, a hospital system); (2) the supporting

organization must direct the overall policies, programs,

and activities of the supported organizations (for example,

coordinating the activities of the supported organizations

and engaging in overall planning, policy development,

budgeting, and resource allocation); and (3) the

supporting organization’s governing body, members of the

governing body, or officers (acting in their official

capacities) must appoint or elect, directly or indirectly, a

majority of the officers, directors, or trustees of each

supported organization and have the power to remove and

replace such directors, officers, or trustees, or otherwise

have an ongoing power to appoint or elect such directors,

officers, or trustees with reasonable frequency.

Part V. Type III Non-Functionally

Integrated 509(a)(3) Supporting

Organizations

A Type III supporting organization (other than a Type III

functionally integrated supporting organization) must

generally satisfy a distribution requirement described in

Regulations section 1.509(a)-4(i)(5)(ii) along with an

attentiveness requirement described in Regulations

section 1.509(a)-4(i)(5)(iii) to meet the integral part test for

a Type III relationship. To satisfy the distribution

requirement, the organization must make a minimum

amount (distributable amount) of distributions. Carryovers

of excess distributions from certain prior years may be

used for this purpose.

Sections A through E of Part V show whether the

organization has satisfied its distribution and attentiveness

requirements for its tax year. Sections A and B determine

the organization’s adjusted net income and minimum

asset amount. These amounts are used in determining the

distributable amount in Section C. Section D determines

the organization’s distributions that count toward the

distributable amount and determines whether the

attentiveness requirement is met. Section E determines

whether the distributable amount is satisfied through

current distributions and prior-year carryovers, and

determines carryovers to future years.

A trust is excepted from the general distribution and

attentiveness requirements (and need not complete

Sections A through E) if on November 20, 1970, it met and

continues to meet the requirements set forth in

Regulations section 1.509(a)-4(i)(9). A trust that claims

Instructions for Schedule A (Form 990) 2025

this status by checking the box on line 1 at the beginning

of Part V must explain in Part VI how it meets each of the

requirements. A trust that has obtained a ruling from the

IRS on this issue must so indicate in Part VI.

Section A. Adjusted Net Income

The principles of section 4942(f) and Regulations section

53.4942(a)-2(d) apply in determining adjusted net income.

See Regulations section 1.509(a)-4(i)(5)(ii)(B).

Prior and current year columns. The organization’s

adjusted net income for the prior tax year is used in

determining the organization’s distributable amount for the

current tax year. The form also allows for reporting the

organization’s adjusted net income for the current tax year

for use in next year’s calculations; this reporting is optional

but may be helpful if the organization anticipates being

required to complete Part V next year.

Definition. Adjusted net income is gross income for the

tax year less deductions allowable to a corporation subject

to tax under section 11, with certain modifications

discussed in the line instructions later. In computing gross

income and deductions, the principles of the income tax

provisions of the Code apply (except to the extent

inconsistent with section 4942 or the underlying

regulations), but exclusions, deductions, and credits aren’t

allowed unless expressly provided for under section 4942

or the underlying regulations. See Regulations section

53.4942(a)-2(d)(1).

Line 1. Report the organization’s net short-term capital

gain, if any. Long-term capital gains and losses from the

sale or disposition of property aren’t taken into account in

determining adjusted net income (unless reportable on

line 2 as recoveries of prior-year distributions). Net

short-term capital loss can’t be carried back or forward to

other tax years. Amounts treated as long-term capital

gains include capital gain dividends from a regulated

investment company and net section 1231 gains (but net

section 1231 losses are treated as ordinary losses and

thus taken into account). If the fair market value of

property distributed for charitable purposes exceeds the

adjusted basis, the excess isn’t deemed includible in

income.

Adjusted basis. The adjusted basis for purposes of

determining gain from the sale or other disposition of

property is the greater of the following.

1. The fair market value of such property on August 17,

2006, plus or minus all adjustments thereafter and

before the date of disposition under sections 1011–

1023, if the property was held continuously from

August 17, 2006, to the date of disposition.

2. The adjusted basis under sections 1011–1023,

without regard to section 362(c). If assets acquired

before August 17, 2006, were subject to depreciation

or depletion, to determine the adjustments to basis

between the date of acquisition and August 17, 2006,

straight-line depreciation or cost depletion must be

taken into account. Any other adjustments that

would’ve been made during such period (such as a

change in useful life based upon additional data or a

change in facts) must also be taken into account.

Instructions for Schedule A (Form 990) 2025

The adjusted basis for purposes of determining loss is

only the amount described in item 2 above.

Line 2. Recoveries of prior-year distributions include the

following.

• Repayments received of amounts that were taken into

account as a distribution counting toward the

distribution requirement in a prior tax year.

• Proceeds from the sale or disposition of property to

the extent that acquisition of such property was taken

into account as a distribution counting toward the

distribution requirement in a prior tax year.

• An amount set aside and taken into account as a

distribution counting toward the distribution

requirement in a prior tax year to the extent it is

determined that such amount isn’t necessary for the

purposes for which it was set aside.

Line 3. Report all other gross income. Gross income

includes all amounts derived from, or in connection with,

property held by the organization (except as specified

otherwise in the instructions for line 1). Include income

from any related or unrelated trade or business. Include

income from tax-exempt bonds. Don’t include the

following.

• Gifts, grants, or contributions received.

• Long-term capital gains or losses or net short-term

capital losses.

• Income received from an estate, unless the estate is

considered terminated due to a prolonged period of

administration.

• Distributions from a trust created and funded by

another person.

• Certain amounts received by an organization in the

redemption of stock in a corporate disqualified person

in order to avoid excess business holdings, which are

treated as not essentially equivalent to a dividend

under section 302(b)(1) (and thus as amounts

received in exchange for the stock, giving rise to

long-term capital gain or loss) if the conditions of

Regulations section 53.4942(a)-2(d)(2)(iv) are met.

Line 5. The deduction for depreciation under section 167

is allowed, but only on the basis of the straight-line

method. The deduction for depletion under section 611 is

allowed, but without regard to section 613 (percentage

depletion).

Lines 6 and 7. No deduction is allowed except ordinary

and necessary expenses paid or incurred for the

production or collection of gross income, or for the

management, conservation, or maintenance of property

held for the production of income. These expenses may

include operating expenses such as compensation of

officers and employees, interest, rent, and taxes. Where

only a portion of property produces income (or is held for

the production of income) and the remainder is used for

charitable purposes, the expenses must be apportioned

between exempt and non-exempt use on a reasonable

basis.

Don’t deduct the following.

• Net losses from a related business or other charitable

activity that produces gross income (no deduction in

excess of the income from such activity).

• Charitable contributions under section 170 or 642.

17

• Net operating loss carrybacks and carryovers under

section 172.

• Dividends under section 241 and the sections

following it (the dividends-received deductions for

corporations).

• Net capital losses (short-term or long-term).

Expenses and interest relating to tax-exempt income

under section 265 are deductible.

Section B. Minimum Asset Amount

The rules for determining the supporting organization’s

minimum asset amount are set forth in Regulations

sections 1.509(a)-4(i)(5)(ii)(C) and 1.509(a)-4(i)(8), using

valuation methods described in Regulations section

53.4942(a)-2(c).

Prior and current year columns. The organization’s

minimum asset amount for the prior tax year is used in

determining the organization’s distributable amount for the

current tax year. The form also allows for reporting the

organization’s minimum asset amount for the current tax

year for use in next year’s calculations; this reporting is

optional but may be helpful if the organization anticipates

being required to complete Part V next year.

Definition. In figuring the minimum asset amount, include

only assets of the supporting organization that aren’t used

or held for use by the supporting organization (or by a

supported organization, if the supporting organization

provides the asset free of charge or at nominal rent) to

carry out the exempt purposes of the supported

organization(s). Assets held for the production of income

or for investment aren’t considered to be used directly for

charitable functions even though the income from the

assets is used for charitable functions. It is a factual

question whether an asset is held for the production of

income or for investment rather than used or held for use

directly by the supporting organization or a supported

organization for charitable purposes. For example, an

office building used to provide offices for employees

engaged in managing endowment funds for the

supporting organization or supported organization isn’t

considered an asset used for charitable purposes.

Dual-use property. When property is used for both

charitable and other purposes, the property is considered

used entirely for charitable purposes if 95% or more of its

total use is for that purpose. If less than 95% of its total

use is for charitable purposes, a reasonable allocation

must be made between charitable and noncharitable use.

Excluded property. Certain assets (in addition to

exempt-use assets) are excluded entirely from the

computation of the minimum asset amount. These include

charitable pledges and interests in an estate or trust

(created and funded by another person) prior to

distribution to the supporting organization.

Line 1a. Report on line 1a the average monthly fair

market value of securities (such as common and preferred

stock, bonds, and mutual fund shares) for which market

quotations are readily available. A supporting organization

may use any reasonable method to make this

determination if consistently used. For example, a value

for a particular month might be determined by the closing

price on the first or last trading day of the month or an

18

average of the closing prices on the first and last trading

days of the month. Market quotations are considered

readily available if a security is any of the following.

• Listed on the New York or American Stock Exchange

or any city or regional exchange in which quotations

appear on a daily basis, including foreign securities

listed on a recognized foreign national or regional

exchange.

• Regularly traded in the national or regional

over-the-counter market for which published

quotations are available.

• Locally traded, for which quotations can be readily

obtained from established brokerage firms.

If securities are held in trust for, or on behalf of, a

supporting organization by a bank or other financial

institution that values those securities periodically using a

computer pricing system, the organization may use that

system to determine the value of the securities. The

system must be acceptable to the IRS for federal estate

tax purposes.

Line 1b. Figure cash balances on a monthly basis by

averaging the amount of cash on hand on the first and last

days of each month. Include all cash balances and

amounts, even if they may be used for charitable purposes

(see the instructions for line 4, later) or set aside and

taken as a distribution (see the instructions for Section D,

line 5, later).

Line 1c. The fair market value of assets other than

securities for which market quotations are readily available

is determined annually except as described later. The

valuation may be made by supporting organization

employees or by any other person even if that person is a

disqualified person. If the IRS accepts the valuation, it is

valid only for the tax year for which it is made. A new

valuation is required for the next tax year.

Valuation date. An asset required to be valued annually

may be valued as of any day in the supporting

organization’s tax year, provided the organization values

the asset as of that date in all tax years. However, a

valuation of real estate determined on a 5-year basis by a

certified, independent appraisal (discussed later) may be

made as of any day in the first tax year of the organization

to which the valuation applies.

Proration of value of assets held for part of year or in

a short tax year. The value of an asset held less than a

full tax year is prorated by multiplying the value of the

asset by a fraction, of which the numerator is the number

of days the organization held the asset during its tax year,

and the denominator is 365 (366 if the tax year includes

February 29). If the supporting organization has a short

tax year, the value of all assets is accordingly prorated.

5-year valuation for real estate. A written, certified, and

independent appraisal of the fair market value of any real

estate, including any improvements, may be determined

on a 5-year basis by a qualified person. The qualified

person may not be a disqualified person with respect to

the supporting organization or an employee of the

supporting organization.

Commonly accepted valuation methods must be used

in making the real estate appraisal. A valuation based on

Instructions for Schedule A (Form 990) 2025

acceptable methods of valuing property for federal estate

tax purposes will be considered acceptable.

The real estate appraisal must include a closing

statement that, in the appraiser’s opinion, the appraised

assets were valued according to valuation principles

regularly employed in making appraisals of such property,

using all reasonable valuation methods. The supporting

organization must keep a copy of the independent

appraisal for its records. If a valuation is reasonable, the

organization may use it for the tax year for which the

valuation is made and for each of the 4 following tax years.

Any valuation of real estate by a certified independent

appraisal may be replaced during the 5-year period by a

subsequent 5-year certified independent appraisal or by

an annual valuation, as described earlier. The most recent

valuation should be used to figure the organization’s

minimum asset amount.

If the valuation is made according to the above rules,

the IRS will continue to accept it during the 5-year period

for which it applies even if the actual fair market value of

the real estate changes during the period.

Line 1e. If the fair market value of any securities, real

estate holdings, or other assets reported on lines 1a and

1c reflects a blockage discount, marketability discount, or

other reduction from full fair market value because of the

size of the asset holding or any other factor, enter on

line 1e the aggregate amount of the discounts claimed.

Provide an explanation in Part VI that includes the

following information for each asset or group of assets

involved.

1. A description of the asset or asset group (for example,

20,000 shares of XYZ, Inc., common stock).

2. For securities, the percentage of the total issued and

outstanding securities of the same class that is

represented by the organization’s holding.

3. The fair market value of the asset or asset group

before any claimed blockage discount or other

reduction.

4. The amount of the discount claimed.

5. An explanation of the reason for the discount.

In the case of securities, there are certain limitations on

the size of the reduction in value that can be claimed. The

organization may reduce the fair market value of securities

only to the extent that it can establish that the securities

could only be liquidated in a reasonable period of time at a

price less than the fair market value because:

• The securities are such a large block that liquidation

would depress the market,

• The securities are in a closely held corporation, or

• The sale would result in a forced or distress sale.

Any reduction in value of securities may not exceed 10%

of the fair market value (determined without regard to any

reduction in value).

Line 2. Enter the total acquisition indebtedness that

applies to assets included on line 1 (prorated in the case

of assets held for a portion of the year or in a short tax

year). For details on acquisition indebtedness, see section

514(c)(1).

Instructions for Schedule A (Form 990) 2025

Line 4. Supporting organizations may exclude from the

minimum asset amount the reasonable cash balances

necessary to cover current administrative expenses and

other normal and current disbursements directly

connected with the charitable, educational, or other

similar activities. The amount of cash that may be

excluded is generally 1.5% of the fair market value of all

assets (minus any acquisition indebtedness). However, if

under the facts and circumstances an amount larger than

the deemed amount is necessary to pay expenses and

disbursements, then the organization may enter the larger

amount instead (prorated in the case of a short tax year).

If the organization uses a larger amount, explain why in

Part VI.

Line 7. Enter the amount of recoveries (if any) reportable

on Section A, line 2.

Section C. Distributable Amount

The organization’s distributable amount for the current tax

year is ordinarily the greater of:

1. 85% of its adjusted net income for the prior tax year,

or

2. Its minimum asset amount for the prior tax year.

See Regulations section 1.509(a)-4(i)(5)(ii)(B).

First tax year. The distributable amount for the first tax

year that an organization is treated as a non-functionally

integrated Type supporting organization is zero rather than

the amount as ordinarily determined. Such an

organization should check the box on line 7. For purposes

of determining whether the organization has an excess of

distributions in its tax year that can be carried over to

future years, the distributable amount as ordinarily

determined applies to every non-functionally integrated

Type III supporting organization (including an organization

that checked the box on line 7 for the current year). The

distributable amount as ordinarily determined is reported

in Sections C and E.

Emergency temporary reduction. In cases of disaster

or emergency, the IRS may provide for a temporary

reduction in the distributable amount by publication in the

Internal Revenue Bulletin. In these cases, the reduced

amount should be reported on line 6 and the reduction

noted in Part VI.

Section D. Distributions

Section D sets forth the supporting organization’s

distributions that count toward its distribution requirement,

and determines whether the attentiveness requirement is

met. The amount of a distribution made to a supported

organization is the amount of cash or fair market value of

property on the date of distribution. The organization must

use the cash method of accounting for this purpose. See

Regulations section 1.509(a)-4(i)(6).

Line 1. Report amounts paid to supported organizations

to accomplish their exempt purposes. Distributions

furthering the “exempt” purposes of supported

organizations not described in section 501(c)(3) refer

solely to distributions for section 501(c)(3) purposes.

19

Line 2. Report amounts paid to perform any activity that

directly furthers exempt purposes of supported

organizations and that would otherwise normally be

engaged in by the supported organizations, but only to the

extent that expenses from the activity exceed income from

the activity. See Part IV, Section E, line 2, instructions,

earlier, on “direct furtherance” activities.

Line 3. Report reasonable and necessary administrative

expenses paid to accomplish exempt purposes of

supported organizations. Don’t include expenses incurred

in the production of investment income or expenses

incurred in the conduct of fundraising activities (except

certain expenses described in Regulations section

1.509(a)-4(i)(6)(iii)(B) incurred to solicit contributions

received directly by a supported organization).

Line 4. Report amounts paid to acquire exempt-use

assets. Such assets must be used (or held for use) to

carry out the exempt purposes of the supported

organizations. The assets may be used or held by either

the supporting organization or one or more supported

organizations; if the latter, the supporting organization

must make the asset available to the supported

organization(s) free of charge or for nominal rent. See

Regulations section 53.4942(a)-2(c)(3) for further

discussion of exempt-use assets.

Line 5. Report qualified amounts set aside for a specific

project that accomplishes the exempt purposes of a

supported organization. A qualified set-aside counts

toward the distribution requirement in the tax year set

aside but not again when paid.

Approval required. For each set-aside, a supporting

organization must obtain the written approval of both the

pertinent supported organization(s) and the IRS. The

supporting organization must apply to the IRS for approval

(using Form 8940) before the end of its tax year in which

the amount is set aside. Explain in Part VI whether the

organization has requested and obtained the necessary

approvals for the set-aside. See Regulations section

1.509(a)-4(i)(6)(v) for more information.

Lines 7–9. Report on line 7 the amount of distributions

reported on line 1 to supported organizations that met the

attentiveness and responsiveness tests, discussed later,

and provide in Part VI the supplemental information,

discussed later.

A Type III non-functionally integrated supporting

organization must distribute at least one-third of its

distributable amount each tax year to one or more

supported organizations that are “attentive” to its

operations; thus, the line 9 amount must be at least 0.333.

Carryovers of excess distributions from prior years don’t

count toward the attentiveness requirement.

If the line 9 amount is less than one-third (that is, the

amount of distributions to supported organizations that

met both the attentiveness test and the responsiveness

test is less than one-third of the distributable amount),

then the organization doesn’t qualify as a Type III

non-functionally integrated supporting organization for the

tax year. See Regulations sections 1.509(a)-4(i)(5)(i) and

(iii). If the organization doesn’t otherwise qualify as a

20

public charity, then the organization is a private foundation

and must file Form 990-PF for the tax year.

Attentiveness test. A supported organization is

“attentive” to the operations of a supporting organization if,

during the tax year, at least one of the following

requirements is satisfied.

1. The supporting organization distributes to the

supported organization at least 10% of the supported

organization’s total support in its tax year ending

before the beginning of the supporting organization’s

tax year. For example, if the supporting organization

and the supported organization both use a calendar

year, and the supported organization has total support

of $X in a year, then the supporting organization’s

support in the following year must be at least 10% of

$X. Where the supporting organization supports a

particular department or school of a university,

hospital, or church, the department’s or school’s total

support is considered instead.

2. The amount of support received from the supporting

organization is necessary to avoid the interruption of a

particular function or activity of the supported

organization.

3. The amount of support received from the supporting

organization is a sufficient part of the supported

organization’s total support to ensure attentiveness,

based on all pertinent facts, including the number of

supported organizations, the length and nature of the

relationship between the supporting organization and

supported organization, and the purpose to which the

funds are put. The attentiveness of a supported

organization is normally influenced by the amounts

received from the supporting organization, but

evidence of actual attentiveness to the operations

(including investments) of the supporting organization

is of almost equal importance. Where the supporting

organization supports a particular department or

school of a university, hospital, or church, the

department’s or school’s total support is considered

instead of the supported organization’s total support.

Amounts received from a supporting organization that

are held in a donor-advised fund of the supported

organization are disregarded in determining attentiveness.

See the examples in Regulations section 1.509(a)-4(i)

(5)(iii)(D).

Responsiveness test. A supporting organization is

“responsive” to the needs or demands of each of its

supported organizations if it meets the responsiveness

test set forth in the instructions for Part IV, Section D,

under Lines 2 and 3, earlier, with respect to the supported

organization.

Supplemental information required. In Part VI,

identify each of the supported organizations listed in Part

I, line 12g, column (i), that met both of the following

conditions, for the tax year.

1. The supporting organization was responsive to the

supported organization.

2. The supported organization was attentive to the

supporting organization. With respect to each of the

identified supported organizations, set forth the facts

Instructions for Schedule A (Form 990) 2025

that show how both the attentiveness test and the

responsiveness test were met by the supporting

organization and the supported organization.

Section E. Distribution Allocations

Section E determines whether the distributable amount for

the current tax year (and any underdistribution for

reasonable cause in a prior year) is satisfied through

current-year distributions and carryovers of prior-year

excess distributions. Section E also determines carryovers

of excess distributions to future years. Several lines in

Section E aren’t yet applicable during the phase-in period

of the new regulations for Type III non-functionally

integrated supporting organizations. Those lines are

grayed out.

In applying distributions, there are three basic steps.

1. First, apply distributions to eliminate any

underdistribution for reasonable cause in a prior tax

year.

2. Second, apply distributions to satisfy the distributable

amount for the current year.

3. Third, carry over to future years any remaining excess

distributions.

Apply the oldest distributions first. Carryovers of

excess distributions from prior years are always applied in

full before current-year distributions (unlike the rules for

qualifying distributions by private foundations), and older

carryovers are applied before newer carryovers. Excess

distributions of a given year can’t be carried over for more

than 5 years.

Example 1. X is a Type III non-functionally integrated

supporting organization that for its tax year including

December 28, 2022, and through its following 2023 tax

year meets the requirements of Regulations section

1.509(a)-4(i)(3)(iii) as in effect prior to December 28,

2022. Under transition rules, X is deemed to meet its

distribution requirement for 2023, but its distributable

amount is calculated in the ordinary manner to determine

its excess distributions. For 2023, X had a distributable

amount, as ordinarily determined, of $80,000 and

distributions of $100,000. Accordingly, X had excess

distributions of $20,000. For 2024, X had a distributable

amount of $95,000 and distributions of $85,000. X first

applied its 2023 excess distributions carryover of $20,000

to the 2024 distributable amount of $95,000. Then, X

applied $75,000 of its 2024 distributions of $85,000 to the

remaining 2024 distributable amount. Accordingly, X has

excess distributions of $10,000 from 2024 (2024

distributions of $85,000 minus $75,000 applied to the

2024 distributable amount), which it may carry over to

2025. For 2025, X has a distributable amount of $100,000

and distributions of $150,000. X applies the $10,000

excess distribution carryover from 2024 to the 2025

distributable amount. Then, X applies $90,000 of its 2025

distributions to the remaining 2025 distributable amount.

Section E will show $0 carryovers for 2023 and 2024

(because the excess carryovers for each of those years

were previously applied). In addition, Section E will show

excess distributions of $60,000 in 2025 (2025 distributions

of $150,000 minus $90,000 applied to the 2025

Instructions for Schedule A (Form 990) 2025

distributable amount), which it may carry over in the next 5

tax years until applied.

Example 2. Y is a Type III supporting organization that

for its tax year including December 28, 2022, meets the

requirements of Regulations section 1.509(a)-4(i)(3)(iii) as

in effect prior to such date, but doesn’t meet such

requirements in its following 2023 tax year (because of

underdistributions for which the prior regulation didn’t

expressly provide a reasonable cause exception).

Therefore, Y didn’t benefit from the transition rule for its

2023 tax year. Y’s distributable amount was $120,000 for

2023. Y made distributions of that amount and had no

excess distributions to carry over to 2024. Y calculated

that its distributable amount was $150,000 for 2024 and

made distributions of exactly that amount in 2024. Early in

its 2025 tax year, Y discovers that its distributable amount

for 2024 was actually $200,000. Within 180 days, Y makes

a $110,000 distribution ($50,000 to cover the

underdistribution for 2024 and $60,000 as part of its 2025

distributions). Later in the 2025 tax year, Y makes

additional distributions totaling $200,000. Y’s distributable

amount in the 2025 tax year is $190,000. On its 2025

Form 990, Y claims reasonable cause for the 2024

underdistribution due to a clerical error. Under these

circumstances, Y first applies $50,000 of its 2025

distributions of $310,000 to the 2024 underdistribution of

$50,000 ($200,000 minus $150,000), then applies

$190,000 of its remaining 2025 distributions of $260,000

($310,000 minus $50,000) to satisfy its 2025 distributable

amount. Y’s remaining $70,000 of distributions in 2025

($310,000, minus $50,000 allocated to 2024, and minus

$190,000 allocable to 2025) are excess distributions that

may be carried over to future years.

Line 1. Report the distributable amount for 2025 from

Section C, line 6.

Line 2. An organization that is treated as a Type III

non-functionally integrated supporting organization for the

first time in its 2024 tax year will have a distributable

amount of zero during the 2024 tax year.

If the organization had any underdistributions for a prior

tax year (2023 or 2024), then it didn’t qualify as a Type III

non-functionally integrated supporting organization in that

tax year and subsequent years (and would be classified

as a private foundation unless it met the requirements of

another public charity status) unless it met the

requirements of the reasonable cause exception or the

judicial proceeding exception discussed in the instructions

for lines 5 and 6, later. If the organization met either of

these exceptions, explain in detail in Part VI how the

organization met the requirements for the exception.

Line 3. On lines 3d and 3e, enter the amounts reported

on lines 8d and 8e, respectively, from the organization’s

return for the 2024 tax year. The sum of the amounts on

lines 3d and 3e is also reported on line 3f. The amount

reported on line 3f is then applied in the following priority.

1. First to any prior-year underdistributions on line 3g.

2. Second (if any remaining amount) to the current-year

distributable amount on line 3h.

3. Third (if any remaining amount) on line 3j for carryover

to future years.

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Excess distributions can’t be carried over for more than 5

tax years immediately following the tax year in which the

excess amount is created, and thus are forfeited if not

used in the fifth year of carryover. Such amounts are set

forth on line 3i (not applicable to the 2025 tax return).

Line 4. Apply the current-year distributions (from

Section D, line 7) in the same order of priority as

described in the instructions for line 3 to any prior-year

underdistributions (line 4a) and current-year distributable

amount (line 4b) remaining after applying carryovers on

line 3. Any remaining distributions are reported on line 4c

for carryover to future years.

Lines 5 and 6. If the current-year distributable amount is

greater than the sum of the excess distributions carryover

from the prior year plus the current-year distributions, then

the organization doesn’t meet the distribution requirement

and can’t qualify as a Type III non-functionally integrated

supporting organization for the tax year, unless an

exception applies. If the organization doesn’t qualify as a

supporting organization or otherwise as a public charity for

the tax year, then it is a private foundation and must file

Form 990-PF for the tax year and subsequent years until

private foundation status is terminated under section 507.

If either the reasonable cause or judicial proceeding

exception applies, then explain in detail in Part VI how the

organization met the requirements for the exception.

Reasonable cause exception. An organization that

fails to distribute its distributable amount won’t be

classified as a private foundation for the year of the failure

if the organization establishes to the satisfaction of the IRS

that:

1. The failure was due to unforeseen events or

circumstances beyond its control, a clerical error, or

an incorrect valuation of assets;

2. The failure was due to reasonable cause and not to

willful neglect; and

22

3. The distribution requirement is met within 180 days

after the organization is first able to distribute its

distributable amount notwithstanding the unforeseen

events or circumstances, or within 180 days after the

clerical error or incorrect valuation was or should have

been discovered.

Amounts paid to meet a distribution requirement of a prior

tax year can’t also be counted toward the distribution

requirement for the tax year in which paid.

Judicial proceeding exception. An organization is

excused from meeting the distribution requirements to the

extent of a conflicting mandatory provision in its governing

instrument, if a judicial proceeding is pending to reform a

governing instrument that prohibits compliance, under the

circumstances set forth in Regulations section

1.509(a)-4(i)(11)(ii)(E).

Lines 7 and 8. Enter on line 7 the prior-year carryover

and the current-year distributions to the extent not applied

to prior-year underdistributions and the current-year

distributable amount (and not already carried over for 5

tax years). The organization may carry over these

amounts to future years. Prior-year carryovers are applied

before current-year distributions.

Part VI. Supplemental Information

Use Part VI to provide narrative information required by

these instructions or to supplement responses to

questions on Schedule A (Form 990). Identify the specific

part and line number that the response supports, in the

order in which they appear on Schedule A (Form 990).

Part VI can be duplicated if more space is needed.

Caution: Don’t include in Part VI the names of any

donors, grantors, or contributors because Part VI will be

made available for public inspection.

Instructions for Schedule A (Form 990) 2025