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Wednesday, March 17, 2021 Live Webcast

Governance Time! Form 990 Part VI & Schedule O Narrations (X2-15174)

4:30 PM - 5:30 PM EDT

Vendor Platform

1.0 CPE Credits in TX


Part VI of the Form 990's Core Form was added in an "attempt to influence behavior" and encourage "buy-in" from Boards and managers of exempt organizations to the end of maintaining good governance practices. This area of the form need be understood in that context, as the "better" answer to the form's inquiries requires specific details and information be entered upon Schedule O.


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


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

  • Identify the six governance inquiries made in Part VI of the Core Form with the greatest public relations impact 
  • Recognize the importance of providing the appropriate details in Schedule O mandated by the Part VI instructions 
  • Be aware of the criteria by which a voting Board member will fail to be considered "independent" for purposes of this Part's Line 1b
  • Determine whether the board of directors has been provided Form 990 via means sufficient to garner a “Yes” answer to the inquiry to Part VI’s Line 11a and identify the various aspects by which Form 990 preparation can be overseen by filer's managers and emphasized in the required Line 11b Schedule O narration
  • Identify the multiple disclosures required when a management company is employed at any time in the tax year being reported upon which occur here in Part VI rather than in Part VII 


After attending this presentation you will be able to...
  • Drill-down into the complete instructions behind the entirety of Part VI's six key inquiries (Board member independence (Line 1), TDOKEs' connections via business or family relationships (Line 2), use of management companies (Line 3), Board oversight of Form 990's preparation needs (Line 11), conflict of interest policies and management (Line 12), how compensation is set for top officers (Line 15)  
  • Discussion of the issues behind the "do you participate in a joint venture" query (Line 16) 
  • Summary of disclosure needs when filer has members/stakeholders with certain voting rights (Lines 6-7) 
  • Understand what likely comprises a "significant change" to organizational documents, and in such presence, what disclosures are required (Line 4)
  • Be aware of what constitutes a "significant diversion of assets" and ramifications that result if same need be reported (Line 5)
  • Understand this part's "Disclosure" Section and the public and/or regulatory reporting it serves
  • Explanation of what 'motivates' additional inquiries (i.e., Lines 8-10, 13-14)




Helpful to have some review of as-filed 990's Part VI and associated Schedule O disclosures




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!


$39.00 - Member

$49.00 - Nonmember

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