The American Institute of CPAs (AICPA) has recommended more than 30 changes to the Internal Revenue Service (IRS) for the 2018 Form 990, Return of Organization Exempt from Income Tax, and its related instructions.
In its May 7 letter, the AICPA indicated the importance and urgency of each of its recommendations. Eighteen of the 33 recommendations were ranked “high” for both importance and urgency. They include:
- Delete the terms and associated definitions from the Glossary in the Instructions to the Form 990 and in all parts of the form and related schedules that have changed under the tax law. The terms are “endowment,” “permanent (true) endowment,” “SFAS 116,” “SFAS 117,” “temporarily restricted endowment” and “FIN 48.”
- Update the Glossary to define the terms used in Accounting Standards Update (ASU) 2016-14, Presentation of Financial Statements of Not-for-Profit Entities, issued by the Financial Accounting Standards Board (FASB) as defined in the FASB Accounting Standards Codification Master Glossary.
- Update the trigger question for Schedule D to reflect the changed classification of net assets under FASB ASC 958, while still recognizing that the focus of the question is on reporting for donor restricted and board designated or quasi-endowments.
- Align the trigger questions in Form 990, Part IV and Part X so that they agree with the definition of “interested parties” in the Schedule L instructions.
- Update the net assets or fund balances portion of the balance sheet to reflect ASU 2016-14.
- Update the question and instructions related to the Office of Management and Budget/Uniform Guidance rules, and update the instructions to reflect the new single audit threshold of $750,000.
- Update the instructions for Schedule I, Part II, Line 1 so they are consistent with the instructions for the trigger question in Form 990, Part IV, Line 21.