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Business and Policy Areas
Business and Policy Areas

NACUBO Comments on Draft Instructions for New Form 990

June 11, 2008

The redesigned Form 990 and instructions will be in effect for tax year 2008 (returns that will be filed in 2009). The final version of the new Form 990 was published late last year. This spring, the IRS released the accompanying instructions in draft form, inviting public comments. NACUBO assembled a team of business officers and campus tax directors to review, analyze, and develop recommended changes to the draft instructions. NACUBO also urged the IRS to create an advisory panel to foster an ongoing dialogue with exempt organizations about the Form 990.

The NACUBO comment letter, endorsed by 14 higher educations, offers numerous detailed recommendations for specific portions of the instructions for the Core Form 990 and several of the accompanying schedules, including:

  • Schedule D, Supplemental Financial Statements;
  • Schedule F, Statement of Activities Outside the U.S.;
  • Schedule K, Supplemental Information on Tax Exempt Bonds;
  • Schedule M, Noncash Contributions; and
  • Schedule R, Related Organizations and Unrelated Partnerships.

A significant portion of NACUBO's comments focus on the widely expanded instructions and definitions related to the reporting of compensation, which appear in the Core Form as well as Schedule J, Compensation Information.
Finalized instructions are expected to be published by IRS before the end of the year.

NACUBO Contact: Mary M. Bachinger, director, tax policy, 202.861.2581,