Exempt Organizations Annual Reporting Requirements - Compensation: Meaning of "Reportable Compensation" and "Other Compensation"

 

Form 990 reporting requirements refer to reportable compensation and other compensation. How does an organization know which types and amounts of compensation are included in each, and where to report these types and amounts on the form?

Reportable compensation generally means compensation reported in Box 1 or 5 (whichever amount is greater) of the employee’s Form W-2PDF, or in Box 1 of a non-employee’s Form 1099-NEC. Other compensationPDF generally means compensation that is not reportable compensation.  The instructions to Part VII explain these terms, and also provide a table listing various types of compensation and where to report them in Part VII or in Schedule J.  A specific type of other compensation that is less than $10,000 for a given person does not need to be reported in Part VII, except tax-deferred contributions by the employer to a defined contribution retirement plan, the annual increase in the actuarial value of a defined benefit plan, and the value of health benefits not includible in reportable compensation.  This $10,000 exception only applies to reporting in Part VII of Form 990; it does not apply to Schedule J.

TIP:  As stated above, the $10,000 exclusions for reporting related organization compensation (described in Reporting Compensation Paid by Related Organizations ) and certain types of other compensation (described in this Q&A) apply only to Part VII reporting, and are not available for Schedule J reporting.  Accordingly, the compensation amounts required to be reported on Schedule J may exceed the amounts required to be reported on Part VII for the same person.  Organizations are not required to use the available reporting exclusions for Part VII. Organizations that prefer to report the same total reportable compensation and other compensation amounts in both Part VII and Schedule J for a person listed in Schedule J may do so by reporting otherwise excludible amounts in Part VII.