Changes to Form 990, Schedule K Would Require 501(c)(3) Borrowers to Report to IRS Whether They Have Written Bond Compliance Procedures


Last week, the Internal Revenue Service released a revised version, still in draft form, of Schedule K to the Form 990, effective for the 2011 reporting year (which is generally filed by borrowers in 2012 or 2013). Schedule K is the form that addresses tax-exempt bond compliance for 501(c)(3) bonds. Probably the most important change is the addition of three questions that ask, in different ways, whether the 501(c)(3) borrower maintains written procedures addressing post-issuance tax-exempt bond compliance. More specifically, the questions ask whether the borrower has adopted written procedures that cover the monitoring of arbitrage compliance, the remediation of excessive private business use, and the correction of violations through the IRS’s voluntary closing agreement program (or “VCAP”).

Please see full article below for more information.

LOADING PDF: If there are any problems, click here to download the file.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

© Ropes & Gray LLP | Attorney Advertising

Written by:


Ropes & Gray LLP on:

Readers' Choice 2017
Reporters on Deadline

"My best business intelligence, in one easy email…"

Your first step to building a free, personalized, morning email brief covering pertinent authors and topics on JD Supra:

Sign up to create your digest using LinkedIn*

*By using the service, you signify your acceptance of JD Supra's Privacy Policy.

Already signed up? Log in here

*With LinkedIn, you don't need to create a separate login to manage your free JD Supra account, and we can make suggestions based on your needs and interests. We will not post anything on LinkedIn in your name. Or, sign up using your email address.