Form 990 Schedule A: Protecting Public Charity Status, IRC 509 Public Support Test Calculations and Reporting

Recording of a 110-minute CPE video webinar with Q&A

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Conducted on Tuesday, August 22, 2023

Recorded event now available

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Course Materials

This course will provide nonprofit advisers with a comprehensive guide to reporting the public support tests of IRC Section 509(a) on Schedule A of Form 990 Exempt Organization Information Return.


Advisers to nonprofits must ensure charitable exempt organizations maintain their status as public charities under Internal Revenue Code rules. Charitable exempt organizations can realize greater tax benefits by qualifying as a public charity rather than meeting the more complex and burdensome regulations for private foundations. Advisers need to thoroughly understand the rules, calculations, and reporting requirements to verify public charity status.

The regulations provide several tests for maintaining public charity status. Nonprofits may be set up as a religious organization, school, or hospital, or as a supporting organization of another public charity. Alternatively, they must meet one of the public support tests by verifying that a substantial portion of the entity's total receipts come from public support. Exempt organizations must conduct this test annually, reporting the support the entity received in the current tax year and the four prior years.

Public support test calculations are reported on Schedule A of Form 990, one of the most complex schedules on the Exempt Organization Tax Return. Because an exempt organization may not know whether it qualifies as a public charity until it calculates public support at the tax year's end, advisers must keep public support calculations current to protect the client's public charity status.

Listen as our experienced panel offers a comprehensive and practical guide to mastering the public support calculation, reporting, and planning implications for exempt organizations.



  1. Introduction of public charities (specific type, publicly supported, and supporting organization) and private foundations
  2. Publicly supported organizations: two tests
    1. Which test to use?
    2. 509(a)(1) and 170(b)(1)(A)(vi)--Part II of Schedule
      1. Mechanics of numerator and denominator
      2. 10% facts and circumstances test
    3. 509(a)(2) Part III of Schedule A
      1. Mechanics of numerator and denominator
      2. Investment income limitation
    4. Unusual grants
  3. Planning to avoid (or not) private foundation status
  4. Advantages and disadvantages of private foundation status
  5. Transition to private foundation status
    1. Obtaining a waiver of private foundation excise taxes
    2. Other issues/considerations


The panel will discuss these and other important issues:

  • The "10 percent facts and circumstances test" for organizations that do not qualify for public charity status under the 1/3 support rule
  • Types of revenues and receipts that present special problems in determining the level of public support
  • Obtaining a waiver of private foundation excise taxes where the organization unexpectedly fails the public support test
  • Grants that meet the criteria for unusual grants


Ruvelson, Richard
Richard (Rich) Ruvelson, J.D.

Withum Smith+Brown

Mr. Ruvelson has more than 30 years of experience in providing tax services to non-profit clients, including labor...  |  Read More

Saidha, Shalini
Shalini Saidha, CPA

Senior Manager
Withum Smith+Brown

With over 12 years of experience, Ms. Saidha specializes in managing multiple tax compliance and consulting...  |  Read More

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