Executive Compensation Initiative--Errors on and Omissions from Annual Returns by Exempt Organizations
This initiative was completed prior to 2008 Form 990 changes. See Redesign of the 2008 Form 990 and Corresponding Instructions for major changes on Form 990
The Executive Compensation Compliance Initiative involved examinations and compliance checks of approximately 2,000 organizations. The project identified the following reporting errors and/or omissions in the Forms 990 (Return of Organization Exempt From Income Tax) and Forms 990-PF (Return of Private Foundation) reviewed for Tax Years 2002 and 2003..
- Failure to file Part V, which details compensation paid to officers, directors, trustees, and key employees, when filing Form 990.
- Incorrect reporting on lines 50 and 51, Part IV (Balance Sheet). Loans to current and former officers, directors, and key employees should be reported on Line 50, but those to non-key employees should be reported on Line 51. Organizations involved in the project were found to have combined amounts from non-key employees along with those relating to officers, directors, trustees, and key employees on one line.
- Missing required schedules supporting Part IV, Line 51a. Returns reporting loans receivable did not include the required schedule detailing borrowers' identities and loan terms.
- Errors and omissions involving Line 89b, Part VI. Line 89b asks whether the filing organization engaged in, or became aware that it had engaged in, an excess benefit transaction. The IRS questioned organizations that left line 89b blank or answered yes.
- Errors or omissions involving Schedule A, Part III (Statements About Activities). Yes responses require an attached supporting schedule. The IRS questioned organizations that answered yes or left questions blank.
- Errors or omissions in reporting officer compensation on Line 13, Part I, Form 990-PF. Yes responses require an attached supporting schedule. The IRS questioned organizations that did not report any compensation or check a box indicating that officers were not compensated.