990 Schedule R Instructions for Schedule R (Form 990)

U.S. Tax-Exempt Income Tax Return

i990sr--dft

OMB: 1545-0047

Document [pdf]
Download: pdf | pdf
Note: The draft you are looking for begins on the next page.

Caution: DRAFT—NOT FOR FILING

This is an early release draft of an IRS tax form, instructions, or publication,
which the IRS is providing for your information. Do not file draft forms. We
incorporate all significant changes to forms posted with this coversheet.
However, unexpected issues occasionally arise, or legislation is passed—in this
case, we will post a new draft of the form to alert users that changes were made
to the previously posted draft. Thus, there are never any changes to the last
posted draft of a form and the final revision of the form. Forms and instructions
are subject to OMB approval before they can be officially released, so we post
drafts of them until they are approved. Drafts of instructions and pubs usually
have some additional changes before their final release. Early release drafts are
at IRS.gov/DraftForms and remain there after the final release is posted at
IRS.gov/LatestForms. Also see IRS.gov/Forms.
Most forms and publications have a page on IRS.gov: IRS.gov/Form1040 for
Form 1040; IRS.gov/Pub501 for Pub. 501; IRS.gov/W4 for Form W-4; and
IRS.gov/ScheduleA for Schedule A (Form 1040), for example, and similarly for
other forms, pubs, and schedules for Form 1040. When typing in a link, type it
into the address bar of your browser, not a Search box on IRS.gov.
If you wish, you can submit comments to the IRS about draft or final forms,
instructions, or pubs at IRS.gov/FormsComments. Include “NTF” followed by the
form or pub number (for example, “NTF1040”, “NTFW4”, “NTF501”, etc.) in the
body of the message to route your message properly. We cannot respond to all
comments due to the high volume we receive and may not be able to consider
many suggestions until the subsequent revision of the product, but we will
review each “NTF” message. If you have comments on reducing paperwork and
respondent (filer) burden, with respect to draft or final forms, please respond to
the relevant information collection through the Federal Register process; for
more info, click here.

Instructions for Schedule R
(Form 990)
(Rev. December 2024)

Related Organizations and Unrelated Partnerships

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
Overview

Future developments

For the latest information about developments related to
Form 990 and its instructions, such as legislation enacted
after they were published, go to IRS.gov/Form990.

What’s New

Continuous-use form and instructions. Schedule R
(Form 990) and these instructions have been converted from
an annual revision to continuous use. Both the form and
these instructions will be updated only as needed.

General Instructions

Note. Terms in bold are defined in the Glossary of the
Instructions for Form 990, Return of Organization Exempt
From Income Tax.

Purpose of Schedule

Schedule R (Form 990) is used by an organization that files
Form 990 to provide information on related organizations,
on certain transactions with related organizations, and on
certain unrelated partnerships through which the organization
conducts significant activities.

Who Must File

The chart below sets forth which organizations must
complete all or a part of Schedule R and attach Schedule R
to Form 990. If an organization isn't required to file Form 990
but chooses to do so, it must file a complete return and
provide all of the information requested, including the
required schedules.

Part I of Schedule R (Form 990) requires identifying
information on any organizations that are treated for federal
tax purposes as disregarded entities of the filing
organization. Part II requires identifying information on related
tax-exempt organizations. Part III requires identifying
information on any related organizations that are treated for
federal tax purposes as partnerships. Part IV requires
identifying information on any related organizations that are
treated for federal tax purposes as C or S corporations or
trusts. Part V requires information on transactions between
the organization and related organizations (excluding
disregarded entities). Part VI requires information on an
unrelated organization treated as a partnership through
which the organization conducted more than 5% of its
activities (as described in Part VI).
Part VII of Schedule R (Form 990) may be used to provide
additional information in response to questions in
Schedule R.

Relationships

An organization, including a nonprofit organization, a stock
corporation, a partnership or limited liability company (LLC),
a trust, and a governmental unit or other government entity,
is a related organization to the filing organization if it
stands, at any time during the tax year, in one or more of the
following relationships to the filing organization.
• Parent—An organization that controls (see definitions of
control under Definition of Control) the filing
organization.
• Subsidiary—An organization controlled by the filing
organization.
• Brother/Sister—An organization controlled by the same
person or persons that control the filing organization.

Type of filer

IF you answer “Yes” to . . .

THEN you must complete . . .

All organizations

Form 990, Part IV, line 33
(regarding disregarded entities)

Schedule R, Part I.

All organizations

Form 990, Part IV, line 34
(regarding related organizations)

Schedule R, Parts II, III, IV, and V, line 1, as
applicable.

All organizations

Form 990, Part IV, line 35b
(regarding payments from or transactions with
controlled entities)

Schedule R, Part V, line 2.

Section 501(c)(3) organization

Form 990, Part IV, line 36
(regarding transfers to exempt noncharitable
related organizations)

Schedule R, Part V, line 2.

All organizations

Form 990, Part IV, line 37
(regarding conduct of activity through unrelated
partnership)

Schedule R, Part VI.

Nov 13, 2024

Instructions for Schedule R (Form 990) (Rev. 12-2024) Catalog Number 51519M
Department of the Treasury Internal Revenue Service www.irs.gov

• Supporting/Supported—An organization that is (or claims

•

to be) at any time during the organization's tax year (i) a
supporting organization of the filing organization within
the meaning of section 509(a)(3), if the filing organization
is a supported organization within the meaning of
section 509(f)(3); or (ii) a supported organization, if the
filing organization is a supporting organization.
Sponsoring Organization of a VEBA— An organization
that establishes or maintains a section 501(c)(9)
voluntary employees' beneficiary association (VEBA)
during the tax year. A sponsoring organization of a VEBA
also includes an employee organization, association,
committee, joint board of trustees, or other similar group
of representatives of the parties which establish or
maintain a VEBA.
Contributing Employer of a VEBA—An employer that
makes a contribution or contributions to the VEBA during
the tax year.
Although a VEBA must report sponsoring
organizations and contributing employers as related
organizations, sponsoring organizations and contributing
employers shouldn't report a VEBA as a related
organization, unless the VEBA is related to the
sponsoring organization or contributing employer in
some other capacity listed above.

veto the appointment or election of, periodically or in the
event of vacancies) a majority of the nonprofit organization's
directors or trustees, or a majority of the members who have
the power to elect a majority of the nonprofit organization's
directors or trustees. Such power can be exercised directly
by a (parent) organization through one or more of the (parent)
organization's officers, directors, trustees, or agents, acting
in their capacity as officers, directors, trustees, or agents of
the (parent) organization. Also, a (parent) organization
controls a (subsidiary) nonprofit organization if a majority of
the subsidiary's directors or trustees are trustees, directors,
officers, employees, or agents of the parent.
Control of a stock corporation. One or more persons
(whether individuals or organizations) control a stock
corporation if they own more than 50% of the stock (by voting
power or value) of the corporation.
Control of a partnership or LLC. One or more persons
control a partnership if they own more than 50% of the profits
interests or capital interests in the partnership (including an
LLC treated as a partnership or disregarded entity for
federal tax purposes, regardless of the designation under
state law of the ownership interests as stock, membership
interests, or otherwise). A person also controls a partnership
if the person is a managing partner or managing member of a
partnership or LLC which has three or fewer managing
partners or managing members (regardless of which partner
or member has the most actual control), or if the person is a
general partner in a limited partnership which has three or
fewer general partners (regardless of which partner has the
most actual control). For this purpose, a “managing partner”
is a partner designated as such under the partnership
agreement, or regularly engaged in the management of the
partnership.
Control of a trust with beneficial interests. One or
more persons control a trust if they own more than 50% of the
beneficial interests in the trust. A person’s beneficial interest
in a trust will be determined in proportion to that person’s
actuarial interest in the trust as of the end of the tax year.
In some situations, a named beneficiary may have no
determinable interest in the trust. For instance, if Trust A
allows the trustee to distribute income and principal in the
trustee’s sole discretion for 10 years to the then-living issue of
X, with the remainder (if any) to Charity B, then Charity B has
no interest in the trust that can be determined before the
10-year period is ended, and therefore doesn't control the
trust for purposes of Form 990 and Schedule R.
See Regulations sections 301.7701-2, 3, and 4 for more
information on classification of corporations, partnerships,
disregarded entities, and trusts.
Examples of control by multiple persons.

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
•

VEBA contributing employers and sponsoring organizations. If the filing organization is a section 501(c)(9) VEBA, it
must list its sponsoring organizations and contributing
employers on Schedule R (Form 990). The filing organization
must report all information on its sponsoring organizations in
Parts II through IV, as applicable. However, the filing
organization is required to list only the name of its
contributing employers in Parts II through IV, and isn't
required to report any additional information in those parts.
The filing organization must also report its related
transactions with sponsoring organizations and contributing
employers in Part V, line 1, and, if applicable, line 2.

Disregarded entity exception. Disregarded entities are
treated as related organizations for purposes of reporting on
Schedule R (Form 990), Part I, but not for purposes of
reporting transactions with related organizations in Part V, or
otherwise on Form 990. A disregarded entity of an
organization related to the filing organization is generally
treated as part of the related organization and not as a
separate entity. See Appendix F in the Instructions for Form
990.
Bank trustee exception. If the filing organization is a trust
that has a bank or financial institution trustee that is also the
trustee of another trust, the filing organization isn't required to
report the other trust as a brother/sister related organization
on the ground of common control by the bank or financial
institution trustee.

Definition of Control
Related organizations. For purposes of determining
related organizations:
Control of a nonprofit organization (or other
organization without owners or persons having
beneficial interests, whether the organization is taxable
or tax exempt). One or more persons (whether individuals
or organizations) control a nonprofit organization if they have
the power to remove and replace (or to appoint, elect, or
approve or veto the appointment or election of, if such power
includes a continuing power to appoint, elect, or approve or
2

Example 1. Organizations A and B each appoint
one-third of the board members of Organizations C and D,
and aren't otherwise related to Organizations C and D.
Although neither Organization A nor Organization B is a
parent of Organization C or Organization D, Organizations C
and D are controlled by the same persons, and therefore are
brother/sister related organizations with respect to each
other.
Example 2. There are 1,000 individuals who are
members of both Organizations E and F. The members elect
the board members of both Organizations E and F.
Organizations E and F are brother/sister related
organizations with respect to each other.

Instructions for Schedule R (Form 990) (Rev. 12-2024)

Indirect control. Control can be indirect. For example, if
the filing organization controls Entity A, which in turn controls
(under the definition of control in these instructions) Entity B,
the filing organization will be treated as controlling Entity B.
To determine indirect control through constructive ownership
of a corporation, rules under section 318 apply. Similar
principles apply for purposes of determining constructive
ownership of another entity (a partnership or trust). If an
entity (X) controls an entity treated as a partnership by being
one of three or fewer partners or members, then an
organization that controls X also controls the partnership.

attributed to T by virtue of T's 50% ownership of U's stock.
Thus, T constructively owns 20% of V through U (50% of U's
40% ownership of V), giving T a total ownership interest of
60% in V, and making T and V related organizations as
parent/subsidiary.
Example 8. F is a 501(c)(3) public charity that appoints
the governing body of G, another 501(c)(3) public charity. G
is supported by H, a Type III supporting organization within
the meaning of section 509(f)(1), but G doesn't control H. G
and H are thus related organizations because of the
supporting/supported relationship. Absent other facts, F and
H aren't related organizations.

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
Example 1. B, an exempt organization, wholly owns (by
voting power) C, a taxable corporation. C holds a 51% profits
interest in D, a partnership. Under the principles of section
318, B is deemed to own 51% of D (100% of C's 51% interest
in D). Thus, B controls both C and D, which are therefore both
related organizations with respect to B.
Example 2. X, an exempt organization, owns 80% (by
value) of Y, a taxable corporation. Y holds a 60% profits
interest as a limited partner of Z, a limited partnership. Under
the principles of section 318, X is deemed to own 48% of Z
(80% of Y's 60% interest in Z). Thus, X controls Y. X doesn't
control Z through X's ownership in Y. Y is a related
organization with respect to X, and (absent other facts) Z
isn't.

Example 3. Same facts as in Example 2, except that Y is
also one of three general partners of Z. Because Y controls Z
through means other than ownership percentage, and X
controls Y, in these circumstances, Z is a related organization
with respect to X. The other general partners of Z (if
organizations) aren't related organizations with respect to X,
absent other facts.
Example 4. Organizations A, B, C, and D are nonprofit
organizations. Organization A appoints the board of
Organization B, which appoints the board of Organization C.
A majority of the board members of Organization D are also
board members of Organization A. Under these
circumstances, Organizations B and D are directly controlled
by Organization A, and Organization C is indirectly controlled
by Organization A. Therefore, Organizations B, C, and D are
subsidiaries of Organization A; Organization C is also a
subsidiary of Organization B; and Organizations B and C
have a brother/sister relationship with Organization D.

Example 5. T, an exempt organization described in
section 501(c)(3), owns 40% of the stock of U, a taxable C
corporation. T and U each own 40% of the stock of V, another
taxable C corporation. Under these facts, T and U aren't
related organizations as parent/subsidiary because T doesn't
own more than 50% of U's stock. Under section 318(a)(2)(C),
none of U's holdings are attributed to T by virtue of T's
ownership of U stock, because T owns less than 50% of U
stock. Thus, T and V aren't related organizations as parent/
subsidiary.
Example 6. Same facts as in Example 5, except that U is
an S corporation. Under section 318(a)(5)(E), T
constructively owns 16% of V through U (40% of U's 40%
ownership of V), giving T a total ownership interest of 56% in
V, and making T and V related organizations as parent/
subsidiary.
Example 7. Same facts as in Example 5, except that T
owns 50% of U's stock. T and U aren't related organizations
as parent/subsidiary because T doesn't own more than 50%
of U's stock. Under section 318(a)(2)(C), U's holdings are
Instructions for Schedule R (Form 990) (Rev. 12-2024)

Group exemption. Central organizations and
subordinate organizations of a group exemption aren't
required to be listed as related organizations in Schedule R
(Form 990), Part II. All other related organizations of the
central organization or of a subordinate organization are
required to be listed in Schedule R (Form 990). The following
rules apply.
• An organization that is a central or subordinate
organization in a group exemption (whether filing an
individual return or a group return) isn't required to list
any of the subordinate organizations of the group in Part
II.
• In the case of a group return, the central organization
must attach a list of the subordinate organizations
included in the group return in response to Form 990,
page 1, item H(b). The central organization must list in
Schedule R (Form 990), Parts II through IV the related
organizations of each subordinate organization other
than (1) related organizations that are included within the
group exemption, or (2) related organizations that the
central organization knows to be included in another
group exemption. If an organization isn't listed because it
is known to be included in another group exemption, the
central organization must explain in Part VII the
relationship between its own group and members and the
related organization known to be included in another
group exemption (but you needn't include the names of
such related organizations).
• An organization that isn't included in a group exemption
isn't required to list in Part II a related organization that is
included in a group exemption. Similarly, an organization
that is included in a group exemption isn't required to list
in Part II a related organization that is included in another
group exemption. In either case, the organization must
explain in Part VII the relationship between it and the
related organization included in another group exemption
(but you needn't include the names of such related
organizations).
Even if a related organization isn't required to be listed in Part
II of Schedule R (Form 990), the organization must report its
transactions with the related organization in Part V, as
required by the Part V instructions (for example, checking
“Yes” to Part V, line 1b, if the organization made a grant to a
related organization included in a group exemption, and
reporting on Part V, line 2, the organization's receipt of
interest or annuities from a controlled entity included in a
group exemption), including listing the name of the related
organization in Part V, line 2, column (a), for transactions that
must be reported in line 2.

3

Specific Instructions
Part I. Identification of Disregarded
Entities

Enter the details of each disregarded entity on separate
lines of Part I.

501(c)(3) for a public charity, section 501(c)(6) for a
business league, or section 527 for a separate segregated
fund). For purposes of Schedule R, an organization that
claims exemption is treated as exempt. Also, for purposes of
Schedule R, treat as a section 501(c)(3) organization a
related foreign organization recognized as a charity by the
foreign country, or for which the filing organization has made
a reasonable judgment (or has an opinion of U.S. counsel)
that the foreign organization is described in section 501(c)(3).
The filing organization isn't required to make or obtain such a
determination for purposes of Schedule R. For
governmental units, instrumentalities, and foreign
governments that don't have a section 501(c) determination
letter, leave blank.

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
Column (a). Name, address, and EIN. Enter the full legal
name and mailing address of the disregarded entity. Also
enter the employer identification number (EIN) of the
disregarded entity, if it has one.

A disregarded entity generally must use the EIN of its
TIP sole member. An exception applies to employment
taxes—for wages paid to employees of a
disregarded entity, the disregarded entity must file separate
employment tax returns and use its own EIN on such returns.
See Regulations sections 301.6109-1(h) and 301.7701-2(c)
(2)(iv).
Column (b). Primary activity. Briefly describe the primary
activity of the disregarded entity.

Column (c). Legal domicile. List the U.S. state (or U.S.
territory) or foreign country in which the disregarded entity
is organized (the state or foreign country whose law governs
the disregarded entity's internal affairs).
Column (d). Total income. Enter the amount of the filing
organization's total revenue reported in Form 990, Part VIII,
line 12, column (A), attributable to the disregarded entity.

Column (e). End-of-year assets. Enter the amount of the
organization's total assets reported in Form 990, Part X,
line 16, column (B), attributable to the disregarded entity.

Column (f). Direct controlling entity. Enter the name of
the entity that directly controls the disregarded entity. For
instance, if B is a disregarded entity of the filing organization,
and if C is a disregarded entity of B, report B as the direct
controlling entity of C. If the filing organization directly
controls, enter its name.

Part II. Identification of Related
Tax-Exempt Organizations

For purposes of Schedule R (Form 990), treat governmental
units and instrumentalities and foreign governments as
tax-exempt organizations.
Enter the details of each related organization on
separate lines of Part II.
Column (a). Name, address, and EIN. Enter the related
organization's full legal name, mailing address, and EIN.
Column (b). Primary activity. Briefly describe the primary
activity of the related organization.
Column (c). Legal domicile. List the U.S. state (or U.S.
territory) or foreign country in which the related
organization is organized. For a corporation, enter the state
of incorporation (or the country of incorporation for a foreign
corporation formed outside the United States). For a trust or
other entity, enter the state whose law governs the
organization's internal affairs (or the foreign country whose
law governs for a foreign organization other than a
corporation).
Column (d). Exempt Code section. Enter the section that
describes the related organization (for example, section
4

Column (e). Public charity status. For a related section
501(c)(3) organization, report its public charity status, using
the appropriate line number (lines 1 through 12d)
corresponding to the public charity status checked on
Schedule A (Form 990), Public Charity Status and Public
Support, Part I. If the related organization is a private
foundation, use the designation “PF.” If the related
organization is a section 509(a)(3) supporting
organization, also indicate its type: I, II, III-FI, or III-O (for
Type I, Type II, Type III functionally integrated, or Type III
other, respectively).
For purposes of Schedule R, treat as a public charity a
related foreign organization that hasn't been recognized as
a section 501(c)(3) public charity by the IRS but for which the
filing organization has made a good faith determination,
based on an affidavit from the foreign organization or the
opinion of counsel, that the foreign organization is the
equivalent of a public charity. The filing organization isn't
required to make or obtain such a determination for purposes
of Schedule R; if it hasn't, leave column (e) blank.
Column (f). Direct controlling entity. Enter the name of
the entity (if any) that directly controls the related
organization; otherwise, enter “N/A.” If the filing organization
directly controls, enter its name.
Column (g). Section 512(b)(13) controlled entity. Check
“Yes” if the related organization is a controlled entity of the
filing organization under section
512(b)(13). If not, check “No.”

Part III. Identification of Related
Organizations Taxable as a
Partnership

In this part, identify any related organization treated as a
partnership for federal tax purposes. If the partnership is
related to the filing organization by reason of being its parent
or brother/sister and the filing organization isn't a partner or
member in the partnership, then complete only columns (a),
(b), and (c), and enter “N/A” in columns (d), (e), (f), (g), (i),
and (k).
Enter the details of each related organization on separate
lines of Part III.
Some of the information requested in this part is derived
from Schedule K-1 (Form 1065), Partner's Share of Income,
Deductions, Credits, etc., issued to the organization. If the
Schedule K-1 (Form 1065) isn't available, provide a
reasonable estimate of the required information.
Column (a). Name, address, and EIN. Enter the related
partnership's full legal name, mailing address, and EIN.
Instructions for Schedule R (Form 990) (Rev. 12-2024)

Column (b). Primary activity. Briefly describe the primary
business activity conducted, or product or service provided,
by the related partnership (for example, investment in other
entities, low-income housing, etc.).
Column (c). Legal domicile. List the U.S. state (or U.S.
territory) or foreign country in which the related partnership
is organized (the state or foreign country whose law governs
the related partnership's internal affairs).

If the organization has reason to believe that the

TIP stated amount in box 20 is incorrect, it should consult

with the partnership. The stated amount in box 20
isn't controlling with respect to the organization's unrelated
business income tax liability.

Column (j). General or managing partner. Check “Yes” if
the filing organization was at any time during its tax year a
general partner of a related limited partnership, or a
managing partner or managing member of a related general
partnership, LLC, or other entity treated as a partnership.
Otherwise, check “No.”

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
Column (d). Direct controlling entity. Enter the name of
the entity (if any) that directly controls the related partnership;
otherwise, enter “N/A.” If the filing organization directly
controls, enter its name.
Column (e). Predominant income. Classify the
predominant type of partnership income as:
• Related;
• Unrelated; or
• Excluded from tax under section 512, 513, or 514.

In other words, enter which of the three types listed above is
more prevalent than the others.
For classification purposes, use the definitions set forth in
the instructions to the Statement of Revenue in Form 990,
Part VIII, columns (B), (C), and (D).

Column (f). Share of total income. Enter the dollar amount
of the filing organization's distributive share of the related
partnership's total income, in accordance with the
organization's profits interest as specified by the partnership
or LLC agreement, for the related partnership's tax year
ending with or within the filing organization's tax year. Use the
total amount reported by the related partnership on
Schedule K-1 (Form 1065) for the partnership's tax year
ending with or within the filing organization's tax year (total of
Schedule K-1, Part III, lines 1 through 11 and 18, tax-exempt
income).

Column (g). Share of end-of-year assets. Enter the dollar
amount of the filing organization's distributive share of the
related partnership's end-of-year total assets, in accordance
with the organization's capital interest, as specified by the
partnership or LLC agreement, for the related partnership's
tax year ending with or within the filing organization's tax
year. Use Schedule K-1 (Form 1065) for the partnership's
year ending with or within the organization's tax year to
determine this amount by adding the organization's ending
capital account to the organization's share of the
partnership's liabilities at year end reported on the
Schedule K-1.
Column (h). Disproportionate allocations. Check “Yes” if
the interest of the filing organization as a partner of the
partnership (or as a member of the LLC) in any item of
income, gain, loss, deduction, or credit, or any right to
distributions was disproportionate to the filing organization's
investment in such partnership or LLC at any time during the
filing organization's tax year. Otherwise, check “No.”
Column (i). Code V—UBI amount in box 20 of Schedule K-1 (Form 1065). Enter the dollar amount, if any, listed
as the Code V amount (unrelated business taxable
income) in box 20 of Schedule K-1 (Form 1065) received
from the related partnership for the partnership's tax year
ending with or within the filing organization's tax year. If no
Code V amount is listed in box 20, enter “N/A.”

Column (k). Percentage ownership. Enter the filing
organization's percentage interest in the profits or in the
capital of the related partnership, whichever is greater.

Part IV. Identification of Related
Organizations Taxable as a
Corporation or Trust

In this part, identify any related organization treated as a C
or S corporation or trust for federal tax purposes (such as a
charitable remainder trust), other than a related organization
reported as a tax-exempt organization in Part II of Schedule R
(Form 990). If the corporation or trust is related to the filing
organization as its parent or as a brother/sister related
organization, and the filing organization doesn't have an
ownership interest in the corporation or trust, then complete
only columns (a), (b), (c), and (e), and enter “N/A” in columns
(d), (f), (g), and (h). Don't report trusts described within
section 401(a).
Some of the information requested in this part is derived
from Schedule K-1 (Form 1041), Beneficiary's Share of
Income, Deductions, Credits, etc., or Schedule K-1 (Form
1120-S), Shareholder's Share of Income, Deductions,
Credits, etc., issued to the organization. If the Schedule K-1
isn't available, provide a reasonable estimate of the required
information.

Enter the details of each related organization on separate
lines of Part IV.
Column (a). Name, address, and EIN. Enter the related
organization's full legal name, mailing address, and EIN.
Column (b). Primary activity. Briefly describe the primary
business activity conducted, or product or service provided,
by the related organization (for example, holding company,
management company).
Column (c). Legal domicile. List the U.S. state (or U.S.
territory) or foreign country in which the related
organization is organized. For a corporation, enter the state
of incorporation (or the country of incorporation for a foreign
corporation formed outside the United States). For a trust or
other entity, enter the state whose law governs the
organization's internal affairs (or the foreign country whose
law governs for a foreign organization other than a
corporation).
Column (d). Direct controlling entity. Enter the name of
the entity (if any) that directly controls the related
organization; otherwise, enter “N/A.” If the filing organization
directly controls, enter its name.
Column (e). Type of entity. Use one of the following codes
to indicate the tax classification of the related organization: C
(corporation or association taxable under subchapter C), S

Instructions for Schedule R (Form 990) (Rev. 12-2024)

5

(corporation or association taxable under subchapter S), or T
(trust, including a split-interest trust).
Column (f). Share of total income. For a related
organization that is a C corporation, enter the dollar amount
of the organization's share of the C corporation's total
income. To calculate this share, multiply the total income of
the C corporation (as reported on its Form 1120, U.S.
Corporation Income Tax Return) by the following fraction: the
value of the filing organization's shares of all classes of stock
in the C corporation, divided by the value of all outstanding
shares of all classes of stock in the C corporation. The total
income is for the related organization's tax year ending with
or within the filing organization's tax year.
For a related organization that is an S corporation, enter
the filing organization's allocable share of the S corporation's
total income. Use the amount on Schedule K-1 (Form
1120-S) for the S corporation's tax year ending with or within
the filing organization's tax year (Part III, lines 1 through 10, of
Schedule K-1 (Form 1120-S)).
For a related organization that is a trust, enter the total
income and gains reported on Part III, lines 1 through 8, of
Schedule K-1 (Form 1041) issued to the filing organization for
the trust's tax year ending with or within the filing
organization's tax year.

charitable lead trusts, it should enter “Charitable remainder
trusts (2)” on one line of column (a) and “Charitable lead
trusts (3)” on another line in column (a). The organization
may leave columns (e), (f), (g), and (h) blank for these lines.
Use Part VII if the organization needs space to provide
additional information for columns (b), (c), (d), or (i).

Part V. Transactions With Related
Organizations

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
A section 501(c)(3) organization that is an S

TIP corporation shareholder must treat all allocations of

income from the S corporation as unrelated
business income, including gain on the disposition of stock.

Column (g). Share of end-of-year assets. Enter the dollar
amount of the filing organization's allocable share of the
related organization's total assets as of the end of the
related organization's tax year ending with or within the filing
organization's tax year. For related C and S corporations, this
amount is determined by multiplying the corporation's
end-of-year total assets by the fraction described in column
(f). For related trusts, this amount corresponds to the filing
organization's percentage ownership in the trust.
Column (h). Percentage ownership. For a related
organization taxable as a corporation, enter the filing
organization's percentage of stock ownership in the
corporation (total combined voting power or total value of all
outstanding shares, whichever is greater). For a related S
corporation, use the percentage reported on Schedule K-1
(Form 1120-S) for the year ending with or within the filing
organization's tax year. For a related organization taxable as
a trust, enter the filing organization's percentage of beneficial
interest. In each case, enter the percentage interest as of the
end of the related organization's tax year ending with or
within the filing organization's tax year.
Column (i). Section 512(b)(13) controlled entity. Check
“Yes” if the related organization is a controlled entity of
the filing organization under section
512(b)(13). If not, check “No.”

Split-interest trusts. If the related organization is a
split-interest trust described in section 4947(a)(2), the
organization may enter in column (a) the term “Charitable
remainder trust,” “Charitable lead trust,” or “Pooled income
fund,” as appropriate, instead of the trust's name, EIN, or
address. If the organization was related to more than one of a
certain type of related split-interest trust during the tax year, it
should enter the number of that type of trust in parentheses
after the name. For instance, if the organization had two
related charitable remainder trusts and three related
6

Line 1. Check “Yes” in the appropriate boxes of line 1 if the
filing organization engaged in any of the transactions listed in
Part V with any related organizations (other than
disregarded entities listed in Part I). A single transaction may
be described by and reported in more than one line. A
“transfer,” for purposes of Part V, lines 1r and 1s, includes any
conveyance of funds or property not described in lines 1a
through 1q, whether or not for consideration, such as a
merger with a related organization.

Line 2. The filing organization must report on this line any of
the following transactions that it engaged in with a controlled
entity of the filing organization, as defined in section
512(b)(13), during the tax year.
• All transactions described in line 1a, which includes all
receipts or accruals of interest, annuities, royalties, or
rent from a controlled entity under section 512(b)(13),
regardless of amount.
• Any other type of transaction, described in lines 1b
through 1s, with controlled entities, if the amounts
involved during the tax year between the filing
organization and a particular controlled entity exceed
$50,000 for that type of transaction.
Section 501(c)(3) organizations must also report on
line 2 transactions described in Part V, lines 1b through
1s, that they engaged in with related tax-exempt
organizations not described in section 501(c)(3)
(including section 527 political organizations), if the
amounts involved during the tax year between the filing
organization and a particular related tax-exempt
organization exceed $50,000.

Enter the details of each related organization and each
transaction type on a separate line of the table. Transactions
of a specified type, described in lines 1b through 1s, with a
particular organization don't need to be reported if the total
amount of transactions of such type during the tax year didn't
exceed $50,000.
Column (a). Name of related organization. Enter the full
legal name of the related organization.
Column (b). Transaction type (a–s). Enter the transaction
type (lines 1a through 1s). Aggregate all transactions of the
same type with the same related organization.
Column (c). Amount involved. The amount involved in a
transaction is the fair market value of the services, cash,
and other assets provided by the filing organization during its
tax year, or the fair market value received by the filing
organization, whichever is higher, regardless of whether the
transaction was entered into by the parties in a prior year.
Any reasonable method for determining such amount is
acceptable.
Column (d). Method of determining amount involved.
Describe the method used to determine the value of the
services, cash, and other assets reported in column (c).

Instructions for Schedule R (Form 990) (Rev. 12-2024)

Split-interest trusts. If the organization engaged in a type
of transaction reportable in Part V, line 2, with one or more
split-interest trusts described in section 4947(a)(2), the
organization may enter in column (a) the term “Charitable
remainder trust,” “Charitable lead trust,” or “Pooled income
fund,” as appropriate, instead of the trust's name. For
instance, if the organization carried a $100,000 liability for a
loan it received from a related charitable lead trust, it should
enter “Charitable lead trust” in column (a), transaction type
“e” in column (b), and “$100,000” in column (c). Multiple
transactions of the same type with the same type of
split-interest trust may be aggregated on the same line, with
the number of each type of trust listed in parentheses. For
instance, if the organization received $60,000 from one
related charitable remainder trust as payment for investment
services and $70,000 from another related charitable
remainder trust as payment for investment services during
the tax year, it may enter “Charitable remainder trusts (2)” in
column (a), transaction type “l” in column (b), and “$130,000”
in column (c).

thus must identify Y in Schedule R (Form 990), Part VI, and
provide the required information. If, instead, X's total revenue
for its tax year was $1,300,000, then total revenue would be
considered rather than total assets; X's activities conducted
through Y, as measured by X’s total revenue
($60,000/$1,300,000), wouldn't be greater than 5% of X's
total activities, and therefore X wouldn't be required to identify
Y in Schedule R (Form 990), Part VI.

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
Part VI. Unrelated Organizations
Taxable as a Partnership

In this part, provide information on any unrelated
organization (an organization that isn't a related
organization with respect to the filing organization) that meets
all of the following conditions.
1. The unrelated organization is treated as a partnership for
federal tax purposes (S corporations are excluded).
2. The filing organization was a partner or member of the
unrelated partnership at any time during the filing
organization's tax year.

3. The filing organization conducted more than 5% of its
activities, based on the greater of its total assets at the
end of its tax year or its total revenue for its tax year,
through the unrelated partnership.
In determining the percentage of the filing organization's
activities as measured by its total assets, use the amount
reported on Form 990, Part X, line 16, column (B), as the
denominator, and the filing organization's ending capital
account balance for the partnership tax year ending with or
within the filing organization's tax year as the numerator (the
amount reported on Schedule K-1 (Form 1065) can be used).
In determining the percentage of the filing organization's
activities as measured by its total revenue, use the amount
reported on Form 990, Part VIII, line 12, as the denominator,
and the filing organization's distributive share of the
partnership's gross revenue for the partnership tax year
ending with or within the filing organization's tax year as the
numerator.
Example. X, a section 501(c)(3) organization, is a partner
of Y, an unrelated partnership, which conducts an activity that
constitutes an unrelated trade or business with respect to
X. X's distributive share of Y's total income is $60,000 for Y's
tax year ending with or within X's tax year. X has an ending
capital account balance in Y of $120,000 as reported on
Schedule K-1 (Form 1065). X's total revenue and total assets
for its tax year are $1,000,000 and $1,200,000, respectively.
Because X's total assets exceed X's total revenue for its tax
year, X must consider total assets in determining whether X
conducted more than 5% of its activities through Y for X's tax
year. X conducted 10% of its activities through Y, as
measured by X's total assets ($120,000/$1,200,000), and
Instructions for Schedule R (Form 990) (Rev. 12-2024)

Disregard the unrelated partnerships that meet both of the
following conditions.

1. 95% or more of the filing organization's total revenue
from the partnership for the partnership's tax year ending
with or within the organization's tax year is described in
sections 512(b)(1)–(3) and (5), such as interest,
dividends, royalties, rents, and capital gains (including
unrelated debt-financed income).
2. The primary purpose of the filing organization's
investment in the partnership is the production of income
or appreciation of property and not the conduct of a
section 501(c)(3) charitable activity such as
program-related investing.

Enter the details of each organization on separate lines of
Part VI.

Some of the information requested in this part is derived
from Schedule K-1 (Form 1065) issued to the organization. If
the Schedule K-1 isn't available, provide a reasonable
estimate of the required information.

Column (a). Name, address, and EIN. Enter the unrelated
partnership's full legal name, mailing address, and EIN.
Column (b). Primary activity. Briefly describe the primary
business activity conducted, or product or service provided,
by the unrelated partnership.
Column (c). Legal domicile. List the U.S. state (or U.S.
territory) or foreign country in which the unrelated
partnership is organized (the state or foreign country whose
law governs the unrelated partnership's internal affairs).
Column (d). Predominant income. Classify the
predominant type of income as:
• Related;
• Unrelated; or
• Excluded from tax under section 512, 513, or 514.
In other words, enter one of the three types of income
listed above that is more prevalent than the others. For
classification purposes, use the definitions set forth in the
instructions to the Statement of Revenue in Form 990, Part
VIII, columns (B), (C), and (D).

Column (e). Section 501(c)(3) partners. Check “Yes” if all
the partners of the unrelated partnership (or members of the
LLC) are section 501(c)(3) organizations or governmental
units (or wholly owned subsidiaries of either). Otherwise,
check “No.”
Column (f). Share of total income. Enter the dollar amount
of the filing organization's distributive share of the related
partnership's total income, in accordance with the
organization's profits interest as specified by the partnership
or LLC agreement, for the related partnership's tax year
ending with or within the filing organization's tax year. Use the
total amount reported by the related partnership on
Schedule K-1 (Form 1065) for the partnership's tax year
ending with or within the filing organization's tax year (total of
7

Schedule K-1, Part III, lines 1 through 11 and line 18,
tax-exempt income).
Column (g). Share of end-of-year assets. Enter the dollar
amount of the filing organization's distributive share of the
unrelated partnership's total assets, in accordance with the
filing organization's capital interest as specified by the
partnership or LLC agreement, as of the end of the unrelated
partnership's tax year ending with or within the filing
organization's tax year. Use the ending capital account
reported on Schedule K-1 (Form 1065) for the year ending
with or within the filing organization's tax year.

If the organization has reason to believe that the

TIP stated amount in box 20 is incorrect, it should consult

with the partnership. The stated amount in box 20
isn't controlling with respect to the organization's unrelated
business income tax liability.

Column (j). General or managing partner. Check “Yes” if
the filing organization was at any time during its tax year a
general partner of an unrelated limited partnership, or a
managing partner or managing member of an unrelated
general partnership, LLC, or other entity treated as a
partnership. Otherwise, check “No.”

TREASURY/IRS
AND OMB USE
ONLY DRAFT
November 13, 2024
Column (h). Disproportionate allocations. Check “Yes” if
the interest of the filing organization as a partner of the
partnership (or as a member of the LLC) in any item of
income, gain, loss, deduction, or credit, or any right to
distributions was disproportionate to the organization's
investment in such partnership or LLC at any time during the
filing organization's tax year. Otherwise, check “No.”
Column (i). Code V—UBI amount in box 20 of Schedule K-1 (Form 1065). Enter the dollar amount, if any, listed
as the Code V amount (unrelated business taxable
income) in box 20 of Schedule K-1 (Form 1065) received
from the unrelated partnership for the partnership's tax year
ending with or within the filing organization's tax year. If no
Code V amount is listed in box 20, enter “N/A.”

8

Column (k). Percentage ownership. Enter the filing
organization's percentage interest in the profits or in the
capital of the related partnership, whichever is greater.

Part VII. Supplemental Information

Use Part VII if the organization needs space to provide
additional information in response to questions in Schedule R
(Form 990). In Part VII, identify the specific part and line
number that each response supports in the order in which
those parts and lines appear on Schedule R (Form 990).

Instructions for Schedule R (Form 990) (Rev. 12-2024)


File Typeapplication/pdf
File TitleInstructions for Schedule R (Form 990) (Rev. December 2024)
SubjectInstructions for Schedule R (Form 990), Related Organizations and Unrelated Partnerships
AuthorW:CAR:MP:FP
File Modified2024-11-13
File Created2024-11-13

© 2025 OMB.report | Privacy Policy