Interested Person Sunshine: 990 Schedule L, Parts II-IV
Unlike Schedule L's Part I which requires "turning in the sinner," Parts II-IV promote transparency and accountability when an exempt organization has "insider transactions" regardless of whether the transaction is routine and/or reasonable! These parts imply no value judgment, but filers who miss reporting the fact of loans with, grants or assistance provided to, or business transactions with any of the parties the 990-instructions consider "Interested Persons" will be on the defensive as to what was missed, especially if the omission demonstrates management's failure to protect the organization's interests (or worse!)
This session goes past who are the so-called Interested Persons as defined by the five harmonized categories applying across all three parts to address: the additional IP categories employed in Parts II and IV; when a part's transaction is excepted; and handling what is absolutely required to be disclosed in each part.
This event may be a rebroadcast of a live event and the instructor will be available to answer your questions during the event.
The major topics that will be covered in this class include:
- Review of the "harmonized" five categories by which "Interested Person" (IP) status vests and explanation of the additional categories in play for Parts II and IV
- Tips for accessing appropriate documentation from Trustees-Directors, Officers and Key Employees as to presence of reportable events with them or with those who have IP status because of family member status or as a "35% controlled entity" of IPs
- Handling Part IV's "business transactions" reportable thresholds and working with the exceptions from "business transaction" characterization
- "Yes this means you!" -- addressing IP's privacy concerns and/or requests to omit individuals or company names when reporting business transactions on Part IV
- Reporting demands of Part II, including aspects of managing loans with IPs in favor of public relations needs raised by this part
- Reporting demands of Part III, including: drill-down into the two key exceptions to Part III's reporting of grants or assistance to an IP and address of educational institutions' exception from requirement to disclose names of scholarship or fellowship recipients and how same connects to governance reporting in Core Form 990's Part VI
After attending this presentation you will be able to...
- Recall the five categories of IPs applying uniformly across Parts II-IV of the Schedule, as well as the joint venture category that also applies to Part IV
- Retain both Part IV's business transaction dollar thresholds that apply to disclosing compensation paid to an IP whose status exists as a "family member" of a first tier IP and to all other types of business transactions
- Identify the chief exception to reporting of grants and assistance provided to interested persons in Part III
- Address how to make "best foot forward" narratives in Schedule L's blank lines (Part V), including how to override public relations concerns stemming from reporting insider transactions in Parts II-IV
Public accounting tax and audit staff, and nonprofit organization's Treasurers, CFOs and finance/compliance staff
Applicable if you are a HSCPA member in good standing.
Applicable if you are not a HSCPA member.