# Instructions for Schedule A

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## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

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
2

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.

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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 classif

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3A4e865565ba7a166a. Public record. Not legal advice.