2018 Form 990 contains notable changes; annotations attached

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May 2019


PwC is pleased to share with you our annotated version of the 2018 Form 990, including all schedules and instructions (included below). These documents include our highlights of and comments on key changes for 2018. The documents are searchable, and the electronic version includes bookmarks to assist with navigation.

The 2018 Form 990 contains several modifications resulting from the 2017 tax reform legislation. Notable changes include two new lines in Part V (lines 15 and 16) that pertain to the new excise taxes on ‘excess compensation’ and on net investment income of certain private colleges and universities. The 2018 instructions also reflect modified reporting requirements for certain Section 501(c) organizations (other than Section 501(c)(3) organizations or Section 527 political organizations), which no longer will have to report the names and addresses of donors in Schedule B.

The IRS also continues to make minor stylistic changes and corrections, updates to annual revenue procedure references, inflation-adjusted dollar amounts, and similar updates. Useful cross references are added to formal IRS guidance and information available on the IRS website.

[2018 Form 990 and schedules]

[2018 Form 990 instructions]

The takeaway

The 2018 Form 990 contains several notable changes as a consequence of the 2017 tax reform legislation and recent IRS guidance. Organizations with employees whose compensation exceeds $1 million, and private colleges and universities with investment income that exceeds the new excise tax threshold must examine these modifications. Failure to file a complete and accurate Form 990 may have adverse impacts, including penalties, loss of tax-exempt status, the imposition of other types of excise taxes, or a combination thereof. As a result, nonconforming or incomplete responses in Form 990 could result in additional IRS scrutiny.

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Rob Friz

Health Services Tax Leader, PwC US

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