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New Form 990 Revisions Effective Tax Years 2008 and Later - Impact on NCCS Data Files and Research


Impact of Form 990 Revisions and Filing Requirements on NCCS Core File Data and Research

FAQ's and User Notes

Nonprofits filing Forms 990 and 990-EZ for tax years beginning in 2008 (12-month fiscal years ending 12/2008 and later) will file the 'New' Forms 990 or 990-EZ (2008 Revision). There is a 3-year phase-in period for Form 990 filing requirements to allow organizations to adjust to the new forms, so many large organizations that normally Form 990 under the old rules may file Form 990-EZ for one or more years instead. The redesign of Form 990 and the phase-in period will have significant impacts on the structure and usage of NCCS data files. Some issues have been identified in draft versions of NCCS's Core 2008 data files: Core 2008 PC (501(c)(3) public charities) and Core 2008 CO (501(c) organizations other than 501(c)(3)). The immediate and long-term effects of these changes on NCCS data structure and usage have not been fully identified and documented. One obvious concern is the impact of changes in both form redesign and reporting phase-in requirements on time-line or trend analysis bridging Old Form 990 and New Form 990 data, so users should account for these factors and check this page for the latest information.

Form 990 Redesign:

  1. Q: What do the New Form 990 and Old Form 990 contain?
    A: The entire list of tax year 2008 Form 990, 990-EZ, schedules, and instructions are found at www.irs.gov here: TY 2008 Form 990 - Forms and Instructions (December 2008). The list of tax year 2007 forms and instructions are also found at www.irs.gov here: Forms, Instructions, and Publications for 2007
  2. Q: What are NCCS Core PC and CO data files?
    A: Detailed technical information on NCCS Core data files can be found here.
  3. Q: Do Core 2008 PC and CO files contain New 990 return data?
    A: Yes - Core 2008 PC and CO files contain circa year 2008 return data for fiscal years ending through December 31, 2008, so they are the first NCCS data files to contain New Form 990 data in addition to Old 990 data.
  4. Q: How do I identify New 990 and New 990-EZ return data in Core 2008 PC and CO files?
    A: Use the DocCd field to identify the type of return: New Form 990 records have DocCd='93' and New Form 990-EZ records have DocCd='92'. See: Using DLN and DocCd to Identify Type and Version of Form 990 Return in NCCS Core and IRS Files
  5. Q: Are there changes to Form 990-EZ in tax year 2008?
    A: Yes - While Form 990 has been extensively redesigned for 2008, the 2008 Form 990-EZ has few material changes. The dollar thresholds for Form 990-EZ filers have been raised to allow many more organizations to file Form 990-EZ. Several new lines have been added that reflect the revision of Schedule A (Form 990 or 990-EZ). Several unstructured attachments have been replaced by schedules or eliminated. Some instructions have been changed in coordination with new Form 990 instructions. (source: 2008 Instructions for Form 990-EZ)
    There are, however, significant changes in the number of 990-EZ filings and the size and composition of Form 990-EZ filers due to the phase-in of Form 990 filing requirements (see FAQ #9 below). Furthermore, many of the issues affecting New 990 data fields in Core 2008 PC and CO files identified below also affect New 990-EZ return data (see FAQ #7).
  6. Q: Is New 990 data the same as Old 990 data in Core 2008 PC and CO files?
    A: Unfortunately not. Some fields on the Old 990 were removed or redefined for the New 990, so some fields in NCCS Core 2008 PC and CO files contain blank (NULL or missing) values for New 990 records. Other fields such as PROGREV contain values from New 990 returns that are not consistent with values from Old 990 returns (fields have mixed purposes, i.e. - data for New 990 records is not defined the same as data for Old 990 records in the same field).
  7. Q: Which NCCS Core 2008 PC and CO data fields contain missing values, different values, or comparable values for New 990 data records (vs. Old 990 records)?
  8. CORE FIELDS CONTAINING NULL VALUES

    The following fields on the Old Form 990 are not available on the New Form 990 (exclude these fields from analysis if DocCd = '92' or '93' as they contain missing or invalid zero values):

      Revenues, Expenses, and Net Income

    • DUES (Dues, New 990. See New 990-EZ below)
    • SAVINT (Interest on savings, New Form 990 only)
    • SECINC (Income from securities, New Form 990 only)
    • OTHINVST (Other investment income, New 990 and New 990-EZ)
    • OTHCHGS (Other changes in net assets, New 990. See New 990-EZ below) - OTHCHGS may be calculated as: Net assets or fund balances at end of year (FUNDBAL); LESS: Excess or (deficit) for the year (NETINC); LESS Beginning of year net assets (NETA_BOY))
    • Other Information

    • POLPURP (Political expenditures, New 990 and New 990-EZ)
    • LEGEXP (Legislative expenses: SchA,III, New 990 and New 990-EZ)
    • CONT4 (Gifts, grants, cont Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • DUES4 (Membership fees Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • GRREC4 (Gross receipts Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • INVINC4 (Gross income Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • TAXREV4 (Tax revenues Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • GVTSRV4 (Value of govt services Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • OTHINC4 (Other income Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • INCPURP4 (Total minus GrRec Tot: SchA,IV-A,E, New 990 and New 990-EZ)
    • GRROOT (Lobbying pub opinion: SchA,IV-A, New 990 and New 990-EZ)
    • INFLEXP (Lobbying legislative: SchA,IV-A, New 990 and New 990-EZ)
    • TOTLOB (Total lobbying: SchA,IV-A, New 990 and New 990-EZ)
    • LOBOTH (Other exempt purpose exp: SchA,IV-A, New 990 and New 990-EZ)
    • LOBNOTAX (Nontaxable Lobbying amt: SchA,IV-A, New 990 and New 990-EZ)
    • GRTNONTX (Grassroots nontaxable amt: SchA,IV-A, New 990 and New 990-EZ)
    • EXGRROOT (Ln 36 less ln 42: SchA,IV-A, New 990 and New 990-EZ)
    • EXLOBEXP (Ln 38 less ln 41: SchA,IV-A, New 990 and New 990-EZ)

    The following fields are found on the New Form 990, but values for these fields are not currently provided in Core 2008 PC and CO files (exclude these fields from analysis if DocCd = '92' or '93' as they contain missing or invalid zero values):

      Revenues, Expenses, and Net Income

    • SALESEXP (Sale of securities, cost basis, New Form 990 only)
    • SOLICIT (Fundraising expenses, New Form 990 only)
    • Balance Sheet

    • BOND_BOY (Tax-exempt bond liabilities - BOY, New Form 990 only)
    • MRTG_BOY (Mortgages & notes payable - BOY, New Form 990 only)
    • RETE_BOY (Retained earnings - BOY, New Form 990 only)

    The following fields are found on the New Form 990-EZ, but values for these fields are not currently provided in Core 2008 PC and CO files (exclude these fields from analysis if DocCd = '92' or '93' as they contain missing or invalid zero values):

      Revenues, Expenses, and Net Income

    • DUES (Dues, New 990-EZ) - Dues is still reported separate from Program Service Revenue in New Form 990-EZ, Part I, Line 3, but these values are not currently provided for New 990-EZ returns in Core 2008 PC and CO files.
    • OTHCHGS (Other changes in net assets, New 990-EZ) - Other changes in net assets is still reported in New Form 990-EZ, Part I, Line 20, but these values are not currently provided for New 990-EZ returns in Core 2008 PC and CO files.

    CORE FIELDS CONTAINING WRONG VALUES FOR NEW FORM 990 (excludes 990-EZ)

    New Form 990 data is incorrect on the RTF in the following fields, so values have been set to NULL:

    • SALESECN (Net gain/loss from sales of securities, New Form 990 only) - New Form 990, Part VIII, Line 7c SALESECN contains the same value as Gross Amount of Sales from Securities (SECUR) on the RTF extract. SALESECN should equal SECUR less SALESEXP, but SALESEXP contains missing/zero values New 990 returns which caused SECUR = SALESECN.

    CORE FIELDS CONTAINING MIXED DEFINITIONS FOR NEW FORM 990 (excludes 990-EZ)

    New Form 990 data may not be comparable to Old 990 data in the following fields (values in these fields for returns prior to tax year 2008 may not be comparable to or defined the same as values for tax year 2008 and later). Definitions for these fields have not changed for New Form 990-EZ:

    • INVINC (Total investment income) - Old 990: Sum of investment revenue detail in Part I, Lines 4, 5, and 7 equals INVINC; New 990: All Investment income (including dividends, interest, and other similar amounts) is reported in total on Part VIII, Line 3 except for"Income from investment of tax- exempt bond proceeds" which is reported in Line 4. INVINC for New 990 returns includes Line 3 but not Line 4. Therefore, INVINC represents all income from investments for Old 990 returns, but excludes a portion of investment income for New 990 returns.
    • OTHINC (Other Income) - Old 990: Part I, Lines 11 equals OTHINC; New 990: New 990 filers are instructed to include Part VIII, Line 5 "Royalties" when reporting "Other Revenue" in Part I, Line 11, but OTHINC does not include values in Line 5 "Royalties". Therefore, OTHINC includes revenue from royalties for Old 990 returns, but excludes royalties for New 990 returns.
    • PROGREV (Program revenue) and DUES (Dues revenue) - Old 990: PROGREV (program revenue, Part I Line 2) and DUES (defined as the non-contributed revenue portion of dues for which members directly benefit in Part I, Line 3) are reported as separate revenue items in Part I; New 990: The non-contributed portion of dues revenue is no longer reported as a separate line item on the New 990, so DUES will contain missing or zero values for New 990 records (DUES is listed as missing in New 990 above). The New Form 990 includes dues revenue as a component of program service revenue in Part VIII, Line 2. Therefore, Old 990 [PROGREV] <> New 990 [PROGREV] and Old 990 [DUES]<> New 990 [DUES], but Old 990 [PROGREV+DUES] = New 990 [PROGREV].
    • SPEVTG, DIREXP, and FUNDINC (Special events and activities, gross income, expenses, and net) - Old 990: Special events and activities reported in Part I, Lines 9a-9c includes fundraising events and gaming activities; New 990: Fundraising events are reported in Part VIII, Lines 8a-c separately from gaming activities reported in Part VIII, Lines 9a-c. Limited review of New 990 returns for public charities indicate that SPEVTG, DIREXP, and FUNDINC contain combined amounts for fundraising events and gaming activities*. However, an initial comparison of non-zero values reveals a significant variance between tax year 2007 and 2008 in the number of values reported for SPEVTG, DIREXP, and FUNDINC:
    • Non-Zero Values as % of Total for Public Charities Filing Old 990 vs. New 990 (NCCS Core 2008 PC)

      • SPEVTG (Gross Income): Old 990 = 31%; New 990 = 23%
      • DIREXP (Direct Expenses): Old 990 = 27%; New 990 = 21%
      • FUNDINC (Net Income): Old 990 = 30%; New 990 = 23%

      Further investigation is needed, but the variance is a likely result of larger organizations filing 990-EZ in tax year 2008 due to the phase-in of 990 filing requirements. NCCS staff have not determined if possible changes in rules and instructions for reporting special events and gaming activities contribute to this variance as well.

      * SPEVTG (Gross Income from Fundraising (8a) and Gaming (9a)); LESS: DIREXP (Direct Expenses from Fundraising (8b) and Gaming (9b)); EQUALS: FUNDINC (Net Income/Loss from Fundraising (8c) and Gaming (9c))

    CORE FIELDS CONTAINING COMPARABLE VALUES

    The following fields appear to have comparable definitions and similar ratios of non-zero values to total for Old 990 return records and New 990 records. However, the relative distribution of values in New 990 returns may still differ from Old 990 returns as only the largest organizations with gross receipts >= $1 million, or total assets >= $2.5 million are required to file the New 990 for tax year 2008 (as compared to tax year 2007). The impact of phase-in requirements for filing Form 990 on the number of filings of New 990 and 990-EZ and distribution of data values is expected to continue into tax year 2011 (fiscal years ending 11/2012). Other possible sources of variance between Old 990 and New 990 values in these fields include revisions to regulations, definitions, wording, and field locations on the New 990 forms and instructions:

      Revenues, Expenses, and Net Income

    • CONT (Contributions and government grants, New 990 and New 990-EZ)
    • RENTINC (Gross rental income, New Form 990 only)
    • RENTEXP (Rental expenses, New Form 990 only)
    • NETRENT (Net rental income, New Form 990 only)
    • SECUR (Sale of securities, gross sales, New Form 990 only)
    • SALESECN (Sale of securities, net gain/loss, New Form 990 only)
    • SALEOTHG (Sale of other assets, gross sales, New 990 and New 990-EZ)
    • SALEOTHE (Sale of other assets, cost basis, New 990 and New 990-EZ)
    • SALEOTHN (Sale of other assets, net gain/loss, New 990 and New 990-EZ)
    • INVENTG (Inventory sales, gross sales, New 990 and New 990-EZ)
    • GOODS (Inventory sales, cost of goods sold, New 990 and New 990-EZ)
    • TOTREV (Total revenue, New 990 and New 990-EZ) - Old 990: TOTREV is the calculated sum of revenue detail Lines 1e-11 in Part I; New 990: A calculated sum of revenue detail is not possible for New 990 records because the available revenue fields in Core 2008 PC and CO do not account for two new revenue lines in Part VIII of New Fom 990: Line 4 - Income from investment of tax-exempt bond proceeds; and Line 5 - Royalties (see INVINC and OTHINC above). Therefore, TOTREV is calculated from current year total expenses in Part I, Line 18 (EXPS) plus current year revenue less expenses in Part I, Line 19 (NETINC).
    • GRPROF (Inventory sales, gross profit/loss, New 990 and New 990-EZ)
    • GRREC (Gross receipts, New 990 and New 990-EZ)
    • EXPS (Total expenses, New 990 and New 990-EZ)
    • COMPENS (Total compensation of officers, New Form 990 only)
    • OTHSAL (Total other salaries, New Form 990 only)
    • PAYTAX (Total payroll taxes, New Form 990 only)
    • FUNDFEES (Total prof. fundraising fees, New Form 990 only)
    • NETINC (Net income, New 990 and New 990-EZ)
    • Balance Sheet

    • ASS_BOY (Total assets - BOY, New 990 and New 990-EZ)
    • ASS_EOY (Total assets - EOY, New 990 and New 990-EZ)
    • BOND_EOY (Tax-exempt bond liabilities - EOY, New Form 990 only)
    • MRTG_EOY (Mortgages & notes payable - EOY, New Form 990 only)
    • LIAB_BOY (Total liabilities - BOY, New 990 and New 990-EZ)
    • LIAB_EOY (Total liabilities - EOY, New 990 and New 990-EZ)
    • RETEARN (Retained earnings - EOY, New Form 990 only)
    • NETA_BOY (Total net assets - BOY, New 990 and New 990-EZ)
    • FUNDBAL (Net assets, end of year, New 990 and New 990-EZ) - Old 990: FUNDBAL (net assets or fund balances at end of year) is reported in Part I, Line 21 and in Part IV, Line 73 Column A. Each location of Old 990 uses a different method to calculate end of year net assets, but the amounts in Part I and Part IV must agree;
    • New 990: FUNDBAL is reported as the difference between total assets and total liabilities. The "changes in net assets" method used in Part I of the Old 990 to calculate end of year net assets* is not found in the core section of the New Form 990 (Parts I-X), but some organizations may be required to reconcile other changes in net assets such as unrealized gains/looses from securities and prior period adjustments in Schedule D. Other changes in net assets (OTHCHGS) will contain missing or zero values for New 990 records, but it can be calculated (see OTHCHGS above).

      *(Excess or (deficit) for the year (NETINC) plus Beginning of year net assets (NETA_BOY) plus other changes in net assets (OTHCHGS) = Net assets or fund balances at end of year (FUNDBAL).)

      Other Information

    • INITFEES (Initiation fees, New 990 and New 990-EZ)
    • GRRECPUB (Facilities, gross receipts, New 990 and New 990-EZ)
    • GRRECMEM (Gross income from members, New Form 990 only)
    • GRRECOTH (Gross income from other sources, New Form 990 only)

Form 990 Filing Phase-In:

  1. Q: What is the phase-in schedule for filing New Form 990?
    A: Form 990 Series - Filing Phase-In:
  2. "The new Form 990 series returns are effective for 2008 tax years (returns filed beginning in 2009). To allow organizations time to adjust to the new forms, the IRS is phasing in the new returns during a three-year transition period. During the transition, an organization’s annual filing requirement depends on its financial activity." (source: www.irs.gov, January 29, 2010 - See: Filing Phase-In Chart.)

  3. Q: How will the phase-in of Form 990 filing requirements affect the number of organizations filing Form 990 and 990-EZ?
    A: The number of organizations filing Form 990 dropped from 76.4% in circa 2007 to 60.9% in circa 2008:
  4. Type of Form 990 Filed, circa 2007 (Core 2007 PC)

    Type of Return

    Count

    % of Total

    Old Form 990 (2007 rev and earlier)

    263,442

    76.4%

    Old Form 990-EZ (2007 rev and earlier)

    81,433

    23.6%

    GRAND TOTAL

    344,875

    100.0%

    Type of Form 990 Filed, circa 2008 (Core 2008 PC)

    Type of Return

    Count

    % of Total

    Old Form 990 (2007 rev and earlier)

    149,896

    align="right">42.0%

    New Form 990 (2008 rev and later)

    67,353

    align="right">18.9%

    Total Form 990

    217,249

    align="right">60.9%

    Old Form 990-EZ (2007 rev and earlier)

    42,333

    align="right">11.9%

    New Form 990-EZ (2008 rev and later)

    97,020

    align="right">27.2%

    Total Form 990-EZ

    139,353

    align="right">39.1%

    GRAND TOTAL

    356,602

    100.0%

  5. Q: Does the filing phase-in determine which fields contain data in Core 2008 PC and CO?
    A: Yes - Fewer variable fields are available for organizations filing New 990 because they contain missing or mixed values (see FAQ #7 above). Form 990-EZ contains even less detail than Form 990, so large organizations filing New 990-EZ that would normally file Form 990 under old rules will have missing values for the following fields as well:
    • Revenues, Expenses, and Net Income

    • RENTINC (Gross rental income, New Form 990 only)
    • RENTEXP (Rental expenses, New Form 990 only)
    • NETRENT (Net rental income, New Form 990 only)
    • SECUR (Sale of securities, gross sales, New Form 990 only)
    • SALESECN (Sale of securities, net gain/loss, New Form 990 only)
    • COMPENS (Total compensation of officers, New Form 990 only)
    • OTHSAL (Total other salaries, New Form 990 only)
    • PAYTAX (Total payroll taxes, New Form 990 only)
    • FUNDFEES (Total prof. fundraising fees, New Form 990 only)
    • Balance Sheet

    • BOND_EOY (Tax-exempt bond liabilities - EOY, New Form 990 only)
    • MRTG_EOY (Mortgages & notes payable - EOY, New Form 990 only)
    • RETEARN (Retained earnings - EOY, New Form 990 only)
    • Other Information

    • GRRECMEM (Gross income from members, New Form 990 only)
    • GRRECOTH (Gross income from other sources, New Form 990 only)

  6. Q: How does the filing phase-in affect the distribution of data points in Core 2008 PC and CO fields?
    A: Further investigation is needed. It is reasonable to assume that data distributions in fields that are available on New 990 and not on New 990-EZ will be affected by the fact that only the largest organizations will file New 990 in tax year 2008 (see FAQ #10 above). Distributions in variables that are commonly available on both New 990 and New 990-EZ forms may exhibit these effects as well when analysis is segmented by type of form (990 vs. 990-EZ) rather than as a whole.

Added 03/21/2010 by jdurnford, Modified 06/15/2010 by jdurnford

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