Form 990 Attachments: "White paper attachments" and similar techniques not permitted
Some Form 990 software used to prepare paper filings transfers all narrative information that does not fit on the core form or schedules onto Schedule O. Other software permits this information to be reported, for paper filings, in separate statements or white paper attachments that are not a part of the Form 990. May either method be used when filing a paper Form 990?
Only certain documents may be attached when filing the Form 990 (see Permitted and Impermissible Attachments). However, the IRS understands that some software companies have experienced difficulties designing software for paper filings that comports with all of the new form's filing requirements regarding attachments in time for this filing season. Consequently, for the 2010-2011 tax years, the IRS will not penalize filers of Form 990 paper-filed returns for including separate statements or attachments generated by software. Please note that a reasonable cause explanation for a late-filed return must be made in a separate attachment, rather than in Schedule O, because such explanation would be publicly disclosed if included in Schedule O.