The organization uses a fiscal year as its tax year for completing Form 990. May the organization report executive compensation amounts based on its fiscal year rather than the calendar year amounts reported on Form W-2 or Form 1099?
No. A fiscal year filing organization must report amounts in Form 990, Part VII, and any amounts reported in Schedule J, based on the calendar year ending with or within the organization's fiscal year. This is the same requirement for organizations filing a Form 990 on a calendar year basis.
TIP: Although the organization must use the calendar year to report in Part VII executive compensation and amounts paid to independent contractors, an organization filing Form 990 for a fiscal year must use its fiscal year to report compensation expense amounts in its Statement of Expenses (Part IX of the core form).