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Form 990 Filing Tips: Reporting Executive Compensation (Part VII and Schedule J)

The following tips and FAQs relate to core form Part VII and Schedule J executive compensation reporting.

Which persons must be listed as officers, directors, trustees, key employees, and five highest compensated employees on the core form’s Part VII?
The organization uses a fiscal year as its tax year for completing the Form 990. May the organization report executive compensation amounts based on its fiscal year rather than the calendar year amounts reported on Form W-2 or Form 1099?
Under what circumstances must compensation paid by a related organization be reported on the Form 990?
The core form Part VII, Section A instructions say to list persons in a particular order, beginning with trustees or directors, followed by officers, then key employees, then highest compensated employees, then former such persons. Why should these persons be listed in this order?
The new reporting requirements refer to reportable compensation and other compensation. How does an organization know which types and amounts of compensation are included in each, and where to report these types and amounts on the form?
A table in the core form Part VII instructions indicates that employee deferrals to 401(k) and 403(b) plans should be reported in other reportable compensation on Schedule J column (B)(iii). Because these are deferrals of base pay for many organizations, it may cause the base pay column (B)(i) amount in Schedule J to be understated. Is it incorrect if an organization reports base pay at the full amount, including these deferrals, rather than separating the deferrals from other base pay and reporting the deferrals in Schedule J column (B)(iii) as other reportable compensation?
Are all organizations that list individuals in Form 990, Part VII also required to complete Schedule J?
Schedule J, Part I, contains questions about an organization’s executive compensation practices and policies. Are these questions to be answered for all of the persons listed in the core form Part VII, or only those persons listed in Schedule J, Part II?
How should an organization list in Part VII, Form 990, a person who is a current officer or director for part of the year and a former officer or director for the remainder of the year (as a current, former, or both)? What about persons who are key employees or highest compensated employees for only part of the year?

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Page Last Reviewed or Updated: 2013-03-07