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You state that the new Form 990 requires disclosure of the compensation of employees receiving more than $100,000. When you say compensation, are you speaking only of wages or does this include benefits?

The simple answer to your question is that the organization must report the value of all compensation received from the organization on Part VII-A of the Core Form, including wages, deferred compensation and payments to retirement plans, the value of health benefits, and the value of other benefits (other than disregarded benefits such as free office coffee) as spelled out in more detail on Schedule J, plus compensation received from any related organization from which the person receives more than $10,000.

Compensation must be reported for officers (including the CEO and CFO according to the Instructions), directors and trustees without regard to amount, up to 20 “key employees” who earn more than $150,000 and have certain key responsibilities, and the five highest other employees who make more than $100,000 during the calendar ending within the tax year of the report.

For a calendar year organization, the numbers in Part VII and Schedule J will match up with the amounts expended as shown on the Statement of Functional Expenses in Part IX of the Core Form.  For a fiscal year organization, the numbers in Part VII and Schedule J must be based on the calendar year ending within the fiscal year of the filing, and will therefore not necessarily match the amounts used to compile the numbers shown on the Statement of Functional Expenses.  (See Ready Reference Page:  “New ‘Core Form’ Presents Revised  Look for Nonprofit Finances.”)

June 2, 2009