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Friday, April 28, 2023 Live Webcast

Handling Complex Related Org Issues: Schedule R's Parts II-V (X2-29462)

2:30 PM - 5:00 PM EDT

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2.5 CPE Credits in TX


This session comprises one of four Form 990 Master Classes available to those wanting intermediate-to-advanced training on the 990's most difficult arenas. Once an initial identification scan of a filer's related organizations has been undertaken, two directions of FUN result! FIRST, three key inquiries need be made of managers who are likely to be disclosed on Core Form Part VII-A: (1) amounts of compensation provided to them by such entities in the calendar year that ends within the filer's tax year; (2) whether they served in the tax year as Board members of any tax-exempt related organization; and (3) for filer’s “current” Trustees/Directors, whether any "Schedule L-type transactions" existed in the tax year with them and any related organization (or via their family members or “35% controlled entities”).


Public accounting tax and audit staff, and nonprofit organization's Treasurers, CFOs and other finance/compliance advisors


After attending this presentation you will be able to...

  • Identify baseline scans necessary to root out when one or more related organizations may be present
  • Appreciate the sensitive data-mining to be undertaken with the filer’s managers and how to address concerns (and disclosures) that result from same
  • Recognize the multiple Form 990 preparation arenas that are impacted by the presence of one or more related organizations


The major topics that will be covered in this class include:

  • Quick refresher of what conditions yield "parent,” “subsidiary" or "sibling" status in the case of a party who is a nonprofit/nonstock entity
  • Review of the definition of "control" applied to: stock corporations, entities taxed as a partnership, and trusts 
  • Deep dive into the nuances of “indirect control” under IRC section 318’s constructive ownership rules
  • Finding “sibling” organizations due to “joint control” in place under multiple parties
  • Handling bifurcated “questionnaire needs” with a filer’s Trustees/Directors and employees regarding Board service on other nonprofits versus those necessary with current and former Part VII-A managers (including High 5s) regarding compensation
  • Addressing related organization impacts on the count of independent Directors (query made on Core Form Part VI, Line 1) and with respect to potential excise tax exposure under IRC section 4960    
  • Disclosure specifics for the R's Parts II-IV, and those relating to “transactions” general address on Part V’s Line 1 and via dollar amount when Line 2’s relevant triggers apply




Single course – EB9FDN12 (Finding & Reporting Filers’ Related Organizations) or similar CPE training, or extensive experience with the relevant instructions and their application




Eve Rose Borenstein

Eve Rose Borenstein, J.D.

Eve Borenstein is a partner in Borenstein and McVeigh Law Office (BAM!) (, a Minneapolis law firm and the base from which she conducts an extensive national federal tax practice serving tax exempt organizations. In her law practice (as well as through her teaching and speaking, addressed below) Eve works to assist nonprofit organizations with exemption qualification, corporate planning and overall compliance. By early 2015, she had represented more than 1,000 exempt organizations before the IRS.

Eve provided testimony to the U.S. House of Representative’s Ways and Means Oversight Sub‐Committee in July 2012 at their 2nd Hearing on Tax‐Exempt Organizations, commenting on the reach and efficacy of the Redesigned Form 990. She volunteers extensively with multiple professional committees, including the American Bar Association’s Tax Section Committee on Exempt Organizations and the American Institute of Certified Public Accountants’ Exempt Organization Technical Resource Panel. Eve was a key participant from the private sector in the IRS’ Redesign of the Form 990, and continues to provide extensive feedback to the IRS on both that Form and the Form 1023.

A dedicated teacher and speaker on non‐profit compliance mandates, Eve’s CPE teaching is conducted through a separate consultancy, Eve Rose Borenstein, LLC ( As of 2013, she is the co‐author (with CPA Jane Searing) of the AICPA’s Form 990 Course, Form 990: A Comprehensive Approach to Complete and Accurate Preparation. She enjoys instructing nonprofits directly as well as the professionals who serve the sector and is committed to “helping the sector do it right the first time!”

Eve’s professional path to the present began with exempt organizations tax work in the Minneapolis tax offices of Ernst &Whinney in 1985. From 1989 through 2003 she had a solo practice serving nonprofits nationally; a merger in 2004 with non‐profit attorney Ellen W. McVeigh created the BAM Law firm, which exclusively provides tax and corporate counsel (including employment law) to the nonprofit sector.

Eve welcomes your inquiries: /
both e‐mails are interchangeable!


$79.00 - Member

$89.00 - Nonmember

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