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market value of property on the date of

organizations, and describe such

organizations, the length and nature of the

distribution. The organization must use the

distributions in detail in Part VI.

relationship between the supporting and

cash method of accounting for this

supported organization, and the purpose

Lines 8–10. Report on line 8 the amount

purpose. See Regulations section

to which the funds are put. The

of distributions reported on line 1 to

1.509(a)-4(i)(6).

attentiveness of a supported organization

supported organizations that met the

is normally influenced by the amounts

Line 1. Report amounts paid to

attentiveness and responsiveness tests

received from the supporting organization,

supported organizations to accomplish

discussed later, and provide in Part VI the

but evidence of actual attentiveness to the

their exempt purposes. Distributions

supplemental information discussed later.

operations (including investments) of the

furthering the “exempt” purposes of

A Type III non-functionally integrated

supporting organization is of almost equal

supported organizations not described in

supporting organization must distribute at

importance. Where the supporting

section 501(c)(3) refer solely to

least one-third of its distributable amount

organization supports a particular

distributions for section 501(c)(3)

each tax year to one or more supported

department or school of a university,

purposes.

organizations that are “attentive” to its

hospital, or church, the department’s or

operations and to which the supporting

Line 2. Report amounts paid to perform

school’s total support is considered

organization is “responsive” (as described

any activity that directly furthers exempt

instead of the supported organization’s

later); thus, the line 10 amount must be at

purposes of supported organizations and

total support.

least 0.333. Carryovers of excess

that would otherwise normally be engaged

Amounts received from a supporting

distributions from prior years do not count

in by the supported organizations, but only

organization that are held in a donor

toward the attentiveness requirement.

to the extent that expenses from the

advised fund of the supported

activity exceed income from the activity.

If the line 10 amount is less than

organization are disregarded in

See the Schedule A, Part IV, Section E,

one-third (that is, the amount of

determining attentiveness.

line 2 instructions on “direct furtherance”

distributions to supported organizations

See the examples in Regulations

activities.

that met both the attentiveness test and

section 1.509(a)-4(i)(5)(iii)(D).

responsiveness test is less than one-third

Line 3. Report reasonable and necessary

of the distributable amount), then the

administrative expenses paid to

Responsiveness test. A supporting

organization does not qualify as a Type III

accomplish exempt purposes of

organization is “responsive” to the needs

non-functionally integrated supporting

supported organizations. Do not include

and demands of a supported organization

organization for the tax year. See

expenses incurred in the production of

if it meets the responsiveness test set forth

Regulations sections 1.509(a)-4(i)(5)(i)

investment income.

in the instructions for Part IV, Section D,

and (iii). If the organization does not

Lines 2 and 3, with respect to the

Line 4. Report amounts paid to acquire

otherwise qualify as a public charity, then

supported organization.

exempt-use assets. Such assets must be

the organization is a private foundation

used (or held for use) to carry out the

and must file Form 990-PF for the tax

Supplemental information required.

exempt purposes of the supported

year.

In Part VI, identify each of the supported

organizations. The assets may be used or

organizations listed in Part I, Line 11g,

Attentiveness test. A supported

held by either the supporting organization

column (i), that met both of the following

organization is “attentive” to the operations

or one or more supported organizations; if

conditions for the tax year:

of a supporting organization if, during the

the latter, the supporting organization

1. the supporting organization was

tax year, at least one of the following

must make the asset available to the

responsive to the supported organization,

requirements is satisfied:

supported organization(s) free of charge

and

or for nominal rent. See Regulations

1. The supporting organization

2. the supported organization was

section 53.4942(a)-2(c)(3) for further

distributes to the supported organization

attentive to the supporting organization.

discussion of exempt-use assets.

at least 10% of the supported

With respect to each of the identified

organization’s total support in its tax year

Line 5. Report qualified amounts set

supported organizations, set forth the

ending before the beginning of the

aside for a specific project that

facts that show how both the attentiveness

supporting organization’s tax year. For

accomplishes the exempt purposes of a

test and the responsiveness test were met

example, if supporting and supported

supported organization to which the

by the supporting organization and the

organization both use a calendar year,

supporting organization is responsive. A

supported organization.

and the supported organization has total

qualified set-aside counts toward the

support of $X in a year, then the

Section E. Distribution

distribution requirement in the tax year set

supporting organization’s support in the

aside but not again when paid.

Allocations

following year must be at least 10% of $X.

Approval required. For each set-aside,

Where the supporting organization

Section E determines whether the

a supporting organization must obtain the

supports a particular department or school

distributable amount for the current tax

written approval of both the pertinent

of a university, hospital, or church, the

year (and any underdistribution for

supported organization(s) and the IRS.

department’s or school’s total support is

reasonable cause in a prior year) is

The supporting organization must apply to

considered instead.

satisfied through current-year distributions

the IRS for approval (using Form 8940)

and carryovers of prior-year excess

2. The amount of support received

before the end of its tax year in which the

distributions. Section E also determines

from the supporting organization is

amount is set aside. Explain in Part VI

carryovers of excess distributions to future

necessary to avoid the interruption of a

whether the organization has requested

years. Several lines in Section E are not

particular function or activity of the

and obtained the necessary approvals for

yet applicable during the phase-in period

supported organization.

the set-aside. See Regulations section

of the new regulations for Type III

3. The amount of support received

1.509(a)-4(i)(6)(v) for more information.

non-functionally integrated supporting

from the supporting organization is a

organizations. Those lines are grayed out.

Line 6. Report any other distributions not

sufficient part of the supported

described above that the organization

organization’s total support to ensure

In applying distributions, there are three

claims are for the use of its supported

attentiveness, based on all pertinent facts,

basic steps.

including the number of supported

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

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Instructions For Schedule A (Form 990 Or 990-Ez) - Public Charity Status And Public Support - 2014 Page 16

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