How do IRS Form 990 filings disclose fiscal sponsorships and what specific line items reveal sponsored projects?
Executive summary
Form 990s rarely name or itemize fiscally sponsored projects; the fiscal sponsor reports the money and activity on its own return, and required disclosures are indirect—appearing as revenue and expense line items, occasional narrative footnotes on Schedule O, and program descriptions that may use generic NAICS or “other revenue” labels [1] [2] [3]. Practical sleuthing requires reading the core revenue/expense sections, Schedule O narrative explanations, and any program‑service breakdowns to infer which dollars fund sponsored projects [4] [3] [5].
1. Why fiscal sponsorships are effectively invisible on the face of Form 990
The IRS does not require a fiscal sponsor to list each sponsored project as a separate filing entity, so projects that lack separate tax‑exempt status do not file their own 990s; their donations and spending are recorded on the sponsor’s return instead, which means the public rarely sees project‑level legal names or line‑by‑line project budgets on Form 990 [1] [2]. Practitioners and lawyers emphasize the practical consequence: donors’ gifts become income of the sponsor and are reported by that sponsor, not by the project [2] [5].
2. The core Form 990 sections that reveal fiscal‑sponsorship activity
Sponsored‑project money shows up where any revenue does: the form’s summary and revenue sections (total contributions and grants, program service revenue, and “other revenue”), and the statement of functional expenses where program‑related spending is aggregated [4] [6]. Analysts looking for fiscal sponsorship clues should therefore read Part I summary and the detailed revenue statement to see large contributions or unusual revenue streams that lack program‑level labels; those items are the conventional place sponsors record donations earmarked to projects [4] [3].
3. Schedule O: the narrative breadcrumbs
Schedule O (required for all Form 990 filers) is the principal place sponsors can—and sometimes do—explain relationships, unique accounting practices, and program descriptions; when organizations disclose fiscal‑sponsorship arrangements or list project names, it is usually here [4]. Because Schedule O is free‑text, disclosures are ad hoc: some sponsors offer project lists or explain fee structures, while many provide no specifics, meaning Schedule O can be decisive or silent depending on the filer [1] [3].
4. How line‑item labels and NAICS codes can help decode sponsorships
When sponsors don’t name projects, they often categorize receipts using broad buckets—“contributions and grants,” “program service revenue,” or “other revenue”—or assign a catch‑all NAICS code such as the IRS‑permitted 900099 for miscellaneous activities, which analysts have used to isolate consulting or fiscal‑sponsorship fees reported by large sponsors [3]. Reading these labels alongside the memo lines and Schedule O text can reveal patterns—consistent “consulting revenue” or recurring large grants tied to program descriptions often signal fiscal‑sponsorship flows [3].
5. What Form 990 does require that indirectly constrains fiscal sponsors
The sponsor must report receipts and expenditures, acknowledge donors when appropriate, and complete governance and compensation schedules that can illuminate whether a sponsor exercises control over funds (a legal requirement for deductible donations under IRS guidance), so governance answers and compensation disclosures can indirectly corroborate a sponsor’s fiscal‑sponsorship role even if project names are omitted [7] [4] [5]. Critics argue this is not full transparency: the current structure leaves a “Form 990 black hole” for projects that don’t file independently [1] [8].
6. Reading a 990 end‑to‑end: a practical checklist for investigators
Start with Part I and the revenue statement to spot large, unexplained receipts; cross‑check Part VIII/Statement of Revenue and Part IX or program‑service breakdowns for where funds were spent; then read Schedule O and any explanatory notes for mentions of fiscal‑sponsorship arrangements, project lists, or fee descriptions; finally, search for generic revenue labels and NAICS codes like 900099 that prior investigators have flagged as proxies for sponsorship income [4] [3] [1]. Public databases that aggregate 990s can speed this work, but they cannot replace the full return and Schedule O for context [9].
7. Limits of the record and reform debates
Available guidance and investigations show that Form 990 can be coaxed into revealing fiscal‑sponsorship activity but will often not do so without voluntary disclosure from sponsors; commentators and reform proposals have urged the IRS to require more explicit project‑level disclosure because the current rules permit large flows to be aggregated under a sponsor’s umbrella, obscuring project identities and funding amounts [8] [1]. The record documents how sponsors must report, and where the public can look, but it also makes plain that many specifics—exact project names and dollar allocations—may simply not be on the 990 unless the sponsor chooses to provide them [1] [3].