Instructions For Schedule A (Form 990 Or 990-Ez)

Part VI-B—Lobbying

Line 51. Reporting of certain

transfers and transactions. Except

Part VII—Information

Activity by Nonelecting

as provided below, report on line 51

Regarding Transfers To

any transfer to or transaction with a

Public Charities

noncharitable exempt organization

and Transactions and

The Part VI-A instructions defining

even if the transfer or transaction

direct and grassroots lobbying activities

Relationships With

constitutes the only connection with the

noncharitable exempt organization.

by organizations that made the section

Noncharitable Exempt

501(h) election do not apply to

Related organizations. If the

nonelecting organizations that complete

Organizations

noncharitable exempt organization is

Part VI-B.

related to or affiliated with the reporting

Part VII is used to report direct and

organization, report all direct and

indirect transfers to (line 51a), direct

indirect transfers and transactions

Part VI-B provides a reporting format

and indirect transactions with (line 51b),

except for contributions and grants

for any organization that engaged in

and relationships with (line 52) any

received by the reporting organization.

lobbying activities in its 2001 tax year

other noncharitable exempt

Unrelated organizations. All

but did not make a section 501(h)

organization (section 6033(b)(9)).

transfers from the reporting

lobbying expenditure election for that

A “noncharitable exempt

organization to an unrelated

year by filing Form 5768.

organization” is an organization exempt

noncharitable exempt organization

under section 501(c) (that is not exempt

must be reported on line 51a. All

A nonelecting public charity will

under section 501(c)(3)), or a political

transactions between the reporting

generally be regarded as lobbying if the

organization described in section 527.

organization and an unrelated

organization either: (1) contacts, or

noncharitable exempt organization

For purposes of these instructions,

urges the public to contact, members of

must be shown on line 51b unless they

the section 501(c)(3) organization

a legislative body for the purpose of

meet the exception in the specific

completing this Schedule A (Form 990

proposing, supporting, or opposing

instructions for that line.

or 990-EZ) is referred to as the

legislation or the government’s budget

Line 51a. Transfers. Answer “Yes” to

“reporting organization.”

process; or (2) advocates the adoption

lines 51a(i) and 51a(ii) if the reporting

A noncharitable exempt organization

or rejection of legislation.

organization made any direct or indirect

is related to or affiliated with the

transfers of any value to a

reporting organization if:

Nonelecting organizations must

noncharitable exempt organization.

1. The two organizations share

complete Part VI-B to show lobbying

A “transfer” is any transaction or

some element of common control or

expenditures paid or incurred.

arrangement whereby one organization

2. A historic and continuing

transfers something of value (cash,

relationship exists between the two

Note: In item g, “direct contact” means

other assets, services, use of property,

organizations.

a personal telephone call or visit with

etc.) to another organization without

A noncharitable exempt

receiving something of more than

legislators, their staffs, or government

organization is unrelated to the

nominal value in return. Contributions,

officials.

reporting organization if:

gifts, and grants are examples of

These nonelecting organizations

transfers.

1. The two organizations share no

must also attach a statement giving a

element of common control and

If the only transfers between the two

detailed description of their lobbying

2. A historic and continuing

organizations were contributions and

activities. The detailed description of

relationship does not exist between the

grants made by the noncharitable

lobbying activities should include all

two organizations.

exempt organization to the reporting

lobbying activities, whether expenses

organization, answer “No.”

An “element of common control” is

are incurred or not (e.g., even lobbying

Line 51b. Other transactions. Answer

present when one or more of the

activities carried out by unreimbursed

“Yes” for any transaction described in

officers, directors, or trustees of one

volunteers).

lines 51b(i) through (vi), regardless of

organization are elected or appointed

its amount, if it is with a related or

by the officers, directors, trustees, or

For example, the activities should be

affiliated organization.

members of the other. An element of

included in the attached statement if an

common control is also present when

Unrelated organizations. Answer

organization (either through its

more than 25% of the officers,

“Yes” for any transaction between the

employees or volunteers) attempts to

directors, or trustees of one

reporting organization and an unrelated

influence legislation in any of the

organization serve as officers, directors,

noncharitable exempt organization,

following ways:

or trustees of the other organization.

regardless of its amount, if the reporting

organization received less than

A “historic and continuing

•

Sending letters or publications to

adequate consideration. There is

relationship” exists when two

government officials or legislators.

adequate consideration where the fair

organizations participate in a joint effort

•

market value of the goods, other

Meeting with or calling government

to work in concert toward the

assets, or services furnished by the

officials or legislators.

attainment of one or more common

reporting organization is not more than

•

purposes on a continuous or recurring

Sending or distributing letters or

the fair market value of the goods,

basis rather than on the basis of one or

publications (including newsletters,

other assets or services received from

several isolated transactions or

brochures, etc.) to members or to the

the unrelated noncharitable exempt

activities. Such a relationship also

general public.

organization. The “exception” described

exists when two organizations share

•

below does not apply to transactions for

Using direct mail, placing

facilities, equipment, or paid personnel

less than adequate consideration.

advertisements, issuing press releases,

during the year, regardless of the

holding news conferences; or holding

length of time the arrangement is in

Answer “Yes” for any transaction,

rallies or demonstrations.

effect.

including transfers for adequate

-12-

Instructions for Schedule A (Form 990 or 990-EZ)

Instructions For Schedule A (Form 990 Or 990-Ez) - 2001 Page 12

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