Comparing 2011 Form 990 to 2010

The IRS 2011 Annual Report & 2012 Work Plan reports:

FY2011 marked the end of the three-year phase-in of the redesigned Form 990. [T]his means the lead-up time is over, and the redesign has begun to pay off by providing us with more information about exempt organizations. This allows us to use data analytics and build risk models that will guide our work and greatly improve our ability to support high standards of transparency and stewardship among exempt organizations.

Consistent with this statement, Form 990 for reporting 2011 activities has few changes in its compensation reporting requirements compared to 2010. Here is a comparison of the 2010 and 2011 forms.

Defined Benefit Retirement Plan

2010 Form 2011 Form
Report increases in actuarial value Report net of increases and decreases in actuarial value

W–2 Compensation

2010 Form 2011 Form
Use box 5 (Medicare wages) unless zero, in which case use box 1 (gross wages) Use the greater of box 1 or box 5

Short Deferrals

2010 Form 2011 Form
Report as deferred compensation any amount earned in a year that is not paid by the end of the year Do not report as deferred compensation any amount paid within 2½ months after end of the year

Benefit Reporting Table

2010 Form 2011 Form
Gives instructions for reporting 70 different benefits Adds instructions for reporting gift cards (as taxable compensation) and “disregarded benefits” (e.g., working condition fringe benefits) (not reported)


Has the organization provided a copy of this Form 990 to all members of its governing body before filing the form?

2010 Form 2011 Form
Answer “yes” if the organization emailed the board a link to a password protected web site to review the form Adds:  Answer “no” if all the organization did was tell the board that the form is available upon request.