Insider Dealings and Sunshine: Schedule L's Parts II-IV

This session comprises one of four Form 990 Master Classes available to those wanting intermediate-to-advanced training on the 990's most difficult...

3/24/2023 1:30pm - 4:00pm  |  Online  |  CPA Crossings


CPE Categories: Taxation (2.5 CPE)

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This session comprises one of four Form 990 Master Classes available to those wanting intermediate-to-advanced training on the 990's most difficult arenas. Schedule L’s Parts II-IV require transparency of, and thus promote accountability with respect to, "insider transactions" conducted by exempt organization. Disclosure here is necessary regardless of whether the transaction or event disclosed is routine (and reasonable) or one necessary to the organization's business needs. Reporting conveys no value judgment, but omitting the fact of Parts II-IV events – loans with, grants or assistance provided to, or undertaking business transactions with – parties who are "Interested Persons" per 990 definitions is dangerous (especially if the omission signals that management may have failed to protect the organization's interests or is intentionally hiding information). This session builds upon the basics of “who” falls within Interested Person status via the five harmonized categories applying across these three parts to address: the additional IP categories employed in Parts II and IV; when a Part's transaction fits a disclosure exception; and handling what is absolutely required to be disclosed in each part, as well as the additional considerations filers face relating to public relations issues. This event may be a rebroadcast of a live event and the instructor will be available to answer your questions during the event.

Presented by Eve Rose Borenstein, LLC

Instructor: Eve R. Borenstein, J.D.

Target Audience

Public accounting tax and audit staff, nonprofit organization's Treasurers, CFOs, and other finance/compliance advisors

Course Objectives

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 the disparate Part IV business transaction dollar thresholds – both those that apply to disclosing compensation paid to an IP whose status exists as a "family member" of a first tier IP, as well as those applicable 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


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 connection to them OR by due to status as a "35% controlled entity" of one or more IPs
  • Handling Part IV's "business transactions" reportable thresholds and working with the possible exceptions from "business transaction" characterization
  • "Yes, this means IPs will be named!" – 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


Single course – EB9FD325 (Transactions with Interested Persons: Form 990 Schedule L), similar CPE training, or experience with this Schedule's instructions and their application