In view of the new 2011 Form 990, Appendix F instruction requiring information from joint ventures and other partnerships to be reported using Form 1065, Schedule K-1 data, may an organization continue to report its interests in joint ventures and partnerships using its books and records, even if those books and records do not reflect Schedule K-1 information?
Yes. The 2011 Form 990, Appendix F Instruction on Form 1065, Schedule K-1 reporting (and equivalent instructions in Parts VIII and X) are optional for Tax Year 2011 pursuant to Announcement 2012-19 . The parallel Form 990-EZ instructions for reporting the organization's share of any assets of joint ventures and partnerships on line 24 using Schedule K-1 information is also optional for Tax Year 2011. In reporting on Form 990 or Form 990-EZ its proportionate interests in the revenue, expenses and assets of joint ventures and other partnerships in which it has an ownership interest, an organization generally may report based on its books and records (but see Schedule H and Schedule R instructions for reporting certain partnership information in those schedules based on Schedule K-1).
Note: The 2010 Form 990 instructions state, in Appendix F, that the filing organization should report its proportionate interests in a joint venture’s or other partnership’s revenue, expenses, and assets in accordance with the organization’s books and records. The 2011 Form 990 Instructions state, in Appendix F, that the filing organization should report such interests using information from the Form 1065, Schedule K-1 provided by the joint venture/partnership.
For tax years subsequent to 2011, the Form 990 Instructions state the filing organization should report in accordance with the organization's books and records.