February 2015
Schedule A Compliance for Supporting Organizations (SO)
In 2014, two additional parts were added to Form 990 and 990-EZ Schedule A for supporting organizations (SOs). Part IV contains two pages of questions that require an organization to demonstrate that it qualifies as one of the four types of SOs- Type I, Type II, Type III Functionally Integrated, or Type III Non-functionally Integrated.
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When the BO does not have authority to regularly elect the majority of a Type I SO’s board, the SO must specifically describe how the BO supervised the SO’s activities.
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When a Type I SO is operated for the benefit of a separate organization, the SO must describe how those operations effectively support the BO.
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If the majority of a Type II SO’s directors were not also the majority of the governing board of the BO, the SO must explain how control was vested.
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If a Type III SO’s officers or directors were not also either appointed by or are serving the governing board of the BO, the SO must indicate how the SO maintained a close working relationship with the BO.
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Type III Functionally Integrated SOs must explain 1) how its activities advance the exempt purpose(s) of the BO; 2) how the SO was responsive to the BO; 3) how the SO determined that those activities substantially included all of its activities; and 4) why the BO would have otherwise participated in those activities.