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Exempt Organizations Annual Reporting Requirements - Form 990, Part VI and Schedule L: Transactions Reported on Schedule L

When reporting independent directors in Part VI, line 2, the definition of independence includes a director who was neither involved nor had a family member who was involved in a transaction reportable on Schedule L during the year. What types of transactions are reportable on Schedule L?

These transactions include--

  • Excess benefit transactions (see Appendix G in Form 990 instructions for an explanation of excess benefit transactions)
  • Loans to or from the filing organization and current or former officers, directors, trustees, key employees and highest compensated employees
  • Grants or other assistance to an officer, director, trustee, key employee, substantial contributor or member of a selection committee
  • Business transactions between the organization and an officer, director, trustee or key employee of the organization. 

Transactions between the organization and such person’s family members or affiliated entities are also included.  Various thresholds and exceptions may determine whether a given transaction needs to be reported in this part, and filers should review Schedule L and its instructions before answering the independent Board member question in Part VI, line 1b.  Then filers can determine whether any of the organization’s governing Board members are involved in a Schedule L reportable transaction, and thus not independent for purposes of Part VI, line 1b.

Page Last Reviewed or Updated: 13-Dec-2016