Preparation, Review and Approval of IRS Forms 990 and 990-T
As a non-profit organization, Seton Hall University is required annually to file Internal Revenue Service Form 990, the “Return of Organization Exempt from Income Tax.” The principles underlying Form 990 are increased transparency and promotion of tax compliance. Accordingly, non-profit organizations are required to disclose in this form, among other things, information regarding their programs and services, finances, governance, compensation structure and whether they have in place certain policies and procedures, including policies addressing conflict of interest, whistleblowing, document retention and destruction, investment and/or joint venture, gift acceptance and executive compensation.
The University is also required to annually file the companion Internal Revenue Service Form 990-T, the “Exempt Organization Business Income Tax Return.” This return is related to the tax due on unrelated business income of the University.
The purpose of this policy is to establish a procedure by which both Forms 990 and 990-T are appropriately reviewed, approved, signed and filed by or on behalf of the Board of Regents.
This is a Board of Regents policy.
- The Associate Vice President for Finance will coordinate and supervise the preparation of the Forms 990 and 990-T.
- The completed Forms 990 and 990-T will be reviewed, approved and signed by the Vice President for Finance and Technology.
- The completed Forms 990 and 990-T will be reviewed, approved and signed by the University’s external auditors.
- Following review, approval and signature by the Vice President for Finance and Technology and the University’s external auditors, the Forms 990 and 990-T will be submitted to the Audit Committee of the Board of Regents for its review and recommendation to the Board of Regents. The Audit Committee shall contemporaneously document the meeting(s) at which the Forms 990 and 990-T are subjected to review and recommendation.
- Following review by the Audit Committee, Forms 990 and 990-T will be submitted to the entire Board of Regents for its review and approval for filing with the Internal Revenue Service. The Board of Regents shall contemporaneously document the meeting(s) at which the Forms 990 and 990-T are reviewed and approved for filing.
- Following approval by the Board of Regents, the Vice President for Finance and Technology shall ensure the filing of the Forms 990 and 990-T.
- Conscientious Employee Protection Act Policy (Whistleblower Policy)
- Records Retention and Disposition Policy
- Conflict of Interest and Commitment Policy
Approved by the Board of Regents on April 30, 2010 (BOR.Res.10.0428.01).
April 30, 2010