IRS Form 990-PF – IRS Forms, Instructions, Pubs 2026 – In the world of nonprofit tax compliance, IRS Form 990-PF stands out as a critical document for private foundations and certain trusts. This comprehensive return not only reports financial activities but also ensures adherence to federal tax laws on investments, distributions, and charitable operations. Whether you’re managing a family foundation, a corporate giving entity, or a Section 4947(a)(1) trust treated as a private foundation, understanding Form 990-PF is essential to avoid penalties and maintain tax-exempt status. In this guide, we’ll break down everything you need to know about filing IRS Form 990-PF, including who must file, key sections, excise taxes, tips for accuracy, and updates relevant to 2026.
What is IRS Form 990-PF?
IRS Form 990-PF, officially titled “Return of Private Foundation or Section 4947(a)(1) Trust Treated as Private Foundation,” is an annual tax return used by private foundations to report their income, expenses, assets, and charitable activities. Unlike public charities that file variations of Form 990, private foundations use this form to calculate and pay excise taxes on net investment income under Section 4940. It also serves as a transparency tool, as these returns are publicly available, allowing donors, regulators, and the public to review a foundation’s operations.
The form helps the IRS monitor compliance with rules designed to prevent self-dealing, ensure minimum charitable distributions, and avoid excess business holdings. For Section 4947(a)(1) nonexempt charitable trusts, it may substitute for Form 1041 if there’s no taxable income. Private foundations must file regardless of their size or revenue, making it a universal requirement in this sector.
Who Must File Form 990-PF?
Not every nonprofit files Form 990-PF—it’s specifically for:
- Exempt Private Foundations: Organizations under Section 501(c)(3) that are classified as private foundations (e.g., those funded by a single family, corporation, or small group of donors).
- Taxable Private Foundations: Foundations that don’t qualify for exemption but operate similarly.
- Section 4947(a)(1) Trusts: Nonexempt charitable trusts treated as private foundations, where unexpired interests are devoted to charitable purposes.
- Foreign Foundations: Exempt foreign private foundations with U.S.-sourced income, though they may skip certain parts.
- Organizations in Transition: Entities terminating private foundation status under Section 507(b)(1)(B) or with pending exemption applications.
If your organization has assets under $5,000, you may simplify some sections, but filing is still required. Public charities, donor-advised funds (unless treated as private), and most other 501(c) organizations use Form 990 or 990-EZ instead.
To confirm your status, check your IRS determination letter or consult a tax professional. Misclassification can lead to penalties, so accuracy is key.
When and How to File Form 990-PF?
Filing Deadlines
Form 990-PF is due by the 15th day of the 5th month after your accounting period ends. For calendar-year filers (January 1–December 31), this means May 15, 2026, for the 2025 tax year. Fiscal-year filers adjust accordingly—for example, a June 30 year-end requires filing by November 15.
Extensions are available via Form 8868, granting an automatic 6-month extension. However, estimated taxes on investment income (if $500 or more) must be paid quarterly using Form 990-W.
How to File?
- Electronic Filing: Mandatory for tax year 2025 and later. Use IRS-approved software or an authorized e-file provider.
- Paper Filing: Only for prior years or specific exceptions.
- Payments: Use EFTPS for deposits; electronic payments are encouraged to reduce fraud risks.
- Where to File: Electronically via the IRS Modernized e-File (MeF) system.
Include all required attachments, such as Schedule B for contributions over $5,000, Form 4720 for excise taxes, or appraisals for asset valuations. State requirements vary—many states require a copy of Form 990-PF.
Penalties for late filing start at $25–$130 per day, up to $13,000, plus interest on unpaid taxes.
Key Parts of Form 990-PF: A Breakdown
Form 990-PF spans multiple parts, requiring detailed financial and operational data. Here’s an overview of the main sections:
| Part | Description | Key Information Required |
|---|---|---|
| Heading | Basic info | Name, EIN, address, type of organization, fair market value of assets, checkboxes for terminations or foreign status. |
| Part I: Analysis of Revenue and Expenses | Financial summary | Revenue (contributions, interest, dividends, capital gains); expenses (compensation, grants, administrative); columns for books, net investment income, adjusted net income, and charitable disbursements. |
| Part II: Balance Sheets | Assets and liabilities | Cash, investments, receivables, land/equipment; book and fair market values at year-start and end. |
| Part III: Analysis of Changes in Net Assets | Net asset tracking | Beginning balance, excess revenue, adjustments, ending balance. |
| Part IV: Capital Gains and Losses | Investment sales | Property details, basis, gains/losses for tax calculation. |
| Part V: Excise Tax Based on Investment Income | Tax computation | 1.39% on net investment income (domestic); 4% on gross for foreign; credits and payments. |
| Part VI-A/B: Statements Regarding Activities | Compliance questions | Political activities, unrelated business income, self-dealing, excess holdings. |
| Part VII: Officers and Compensation | Personnel details | Officers, highest-paid employees/contractors over $50,000. |
| Part VIII-A/B: Charitable Activities and Investments | Program summaries | Direct activities, program-related investments. |
| Part IX: Minimum Investment Return | Distribution requirement | 5% of non-charitable assets’ fair market value. |
| Part X: Distributable Amount | Amount to distribute | Adjusted for taxes and recoveries; must be distributed by next year-end to avoid 30% tax. |
| Part XI: Qualifying Distributions | Charitable spending | Grants, set-asides, program expenses. |
| Part XII: Undistributed Income | Carryover tracking | Prior undistributed amounts, excess distributions (5-year limit). |
| Part XIII: Private Operating Foundations | Operating status | Tests for income, assets, or support (e.g., 85% spent on exempt activities). |
| Part XIV: Supplementary Information | Grants and managers | Grant programs, recipients, purposes (for assets ≥$5,000). |
| Part XV-A/B: Income-Producing Activities | Revenue breakdown | Business codes, exclusions, exempt purpose links. |
| Part XVI: Transfers to Noncharitable Orgs | Transactions | Details on relationships, loans, services with non-501(c)(3) entities. |
Follow the sequencing chart in instructions: Start with Part IV, then I/II, etc. Round to whole dollars and use “N/A” or zeros where applicable.
Excise Taxes and Compliance for Private Foundations
Private foundations face unique excise taxes to encourage charitable giving and prevent abuse:
- Section 4940: 1.39% on net investment income; exempt operating foundations may qualify for reduction.
- Section 4941: 10–200% on self-dealing with disqualified persons.
- Section 4942: 30% on undistributed income if minimum distributions aren’t met.
- Section 4943: 10% on excess business holdings (>20% in a business).
- Section 4944: 10–25% on jeopardizing investments.
- Section 4945: 20–50% on taxable expenditures (e.g., non-charitable grants, political activities).
- Section 4948: 4% on U.S. gross investment income for foreign foundations.
Report these on Form 4720. Maintain records for appraisals, grant substantiations, and allocations between investment and charitable expenses. Public inspection is required—make returns available on your website or upon request, with penalties up to $10,000 for non-compliance.
Common Mistakes and Tips for Filing Form 990-PF
Avoid these pitfalls:
- Incomplete entries: Always fill in zeros or “N/A.”
- Misallocation of expenses: Use reasonable methods to split between investments and charitable purposes.
- Valuation errors: Assets need annual fair market values; real estate requires 5-year appraisals.
- Missing attachments: Forget Schedule B or Form 4720, and your return is invalid.
- Late payments: Pay estimated taxes if net investment income ≥$500.
Tips:
- Use the cash method for disbursements.
- Allocate indirect expenses by salary or space usage.
- Review for ASC 958 compliance if following FASB standards.
- Amend via a full corrected return within 3 years for refunds.
- Work with a CPA specializing in nonprofits for complex filings.
Recent Updates for IRS Form 990-PF in 2026
As of February 2026, key developments include:
- Emphasis on electronic payments to reduce fraud and delays.
- No major structural changes to Form 990-PF, but check IRS.gov for post-publication legislation.
- Group exemption updates (Rev. Proc. 2026-8) affect affiliated organizations, requiring compliance by January 2027, though not directly impacting standalone private foundations.
- Burden estimates: Average 53 hours and $4,500 per return.
Stay updated via IRS.gov/Form990PF for any tax rate adjustments or new guidance.
FAQs About IRS Form 990-PF
1. What if my foundation has no activity?
You still must file, entering zeros where applicable.
2. Can I file Form 990-PF instead of Form 1041 for a trust?
Yes, for Section 4947(a)(1) trusts with no taxable income.
3. How do I value assets for Part IX?
Use average monthly fair market values; appraisals for real estate.
4. What are qualifying distributions?
Grants, program expenses, set-asides (with IRS approval), and asset acquisitions for charitable use.
5. Is Form 990-PF public?
Yes, available on IRS TEOS or upon request.
Conclusion
Filing IRS Form 990-PF is more than a compliance task—it’s an opportunity to demonstrate your foundation’s commitment to transparency and charitable impact. By understanding the requirements, leveraging trusted sources like the IRS website, and avoiding common errors, you can streamline the process and focus on your mission. For personalized advice, consult a tax expert. Download the latest form and instructions from IRS.gov. Stay compliant in 2026 and beyond!