According to a May 29 Exempt Organization update, the IRS has provided tips on its website regarding the completion of Part VI of the new Form 990 (Governance, Management and Disclosure). The tips are in the form of answers to frequently asked questions. The document is available at http://www.irs.gov/charities/article/0,,id=208553,00.html. Among the questions to which responses are provided are the following:
(1) What happens if an organization reports that it does not have certain policies in place?
(2) If an organization adopted a policy or practice after the close of its tax year but before it filed the Form 990 for such year, may it report that it had such policy or practice in place?
(3) Why is the IRS concerned about an organization’s members and local units?
(4) Is an organization required to have its board review the 990 before filing with the IRS?
(5) How hard does the organization have to look for the information requested regarding independent directors and business and family relationships among board members, officers and key employees? and
(6) Does the IRS intend to provide model or sample policies that organizations could adopt in order to answer “yes” to the questions regarding such policies?