Exempt Organizations Annual Reporting Requirements - Form 990, Schedules A and B: "Facts and Circumstances" Public Support Test


My organization is a public charity under sections 509(a)(1) and 170(b)(1)(A)(vi) of the Code, and it received 15 percent of its support from the general public. Because my organization received less than 33-1/3 percent of its support from the general public, how do I show the IRS on the Schedule A that it meets the facts and circumstances test?

If your organization receives more than 10 percent but less than 33-1/3 percent of its support from the general public or a governmental unit, it can qualify as a public charity if it can establish that, under all the facts and circumstances, it normally receives a substantial part of its support from governmental units or the general public. To establish this support, your organization should describe on Part VI of Schedule APDF the facts and circumstances which establish that the organization is in the nature of an organization that is publicly supported. Regulations section 1.170A-9(f)(3) discusses pertinent facts and circumstances.

Additional information

Schedule A instructionsPDF