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Form 990 Filing Tips: Schedule L (Transactions with Interested Persons)

The IRS has received a number of questions about how to report transactions with interested persons on Schedule L, Form 990, Return of Organization Exempt From Income Tax.

  1. Do all Form 990 and Form 990-EZ filers need to file Schedule L?
  2. What types of transactions are reportable on Schedule L?
  3. Should our board member’s purchase of tax-exempt bonds that we issued on the open market be reported as a loan in Schedule L, Part II?
  4. One of our governing board members is the president of a bank in which our organization has an account. We earn interest on the deposits, and there are fees we pay to the bank throughout the year. Should this transaction be reported in Part II and/or Part IV of Schedule L?
  5. Must our organization, a primary school, report in Schedule L, Part III the name of one of our officer’s family members to whom we granted a scholarship?
  6. We compensate our chief financial officer $110,000 and the CFO’s spouse (an employee) $20,000. Must we report one or both of these transactions in Schedule L, Part IV?
  7. We don’t have enough room on Schedule L to include all of the information requested, such as a description of business transactions (Part IV) or the purpose of a loan (Part II). Must we limit our response to the space provided on Schedule L? 
  8. How hard do we need to look for the information requested in Parts III and IV of Schedule L regarding assistance to interested persons and business transactions with interested persons?  What if we are unable to obtain and report all of that information?
  9. 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?