IRS Form 990-PF – Return of Private Foundation or Section 4947(a)(1) Trust Treated as Private Foundation – Private foundations play a vital role in philanthropy, channeling resources into charitable causes while navigating strict IRS regulations. At the heart of compliance is IRS Form 990-PF, the annual return that ensures transparency and accountability. If you’re managing a private foundation or Section 4947(a)(1) nonexempt charitable trust, understanding Form 990-PF is essential for avoiding penalties and maintaining tax-exempt status.
In this guide, we’ll break down everything you need to know about Form 990-PF filing for the 2025 tax year, including who must file, due dates, key sections, and recent updates. Whether you’re a first-time filer or refining your process, this resource will help you stay compliant. For the latest official details, always refer to IRS.gov.

What Is IRS Form 990-PF?
IRS Form 990-PF, officially titled “Return of Private Foundation or Section 4947(a)(1) Nonexempt Charitable Trust Treated as a Private Foundation,” is the mandatory annual tax return for private foundations. It serves two primary purposes:
- Calculating excise taxes: Based on net investment income under Section 4940.
- Reporting activities: Including charitable distributions, assets, and compliance with minimum distribution rules to avoid penalties.
Unlike Form 990 for public charities, Form 990-PF provides detailed financial disclosures, making it a key tool for public transparency. It also substitutes for Form 1041 (U.S. Income Tax Return for Estates and Trusts) for qualifying trusts with no taxable income.
For tax year 2024 (filed in 2025), the form reflects updates like the reduced excise tax rate of 1.39% on net investment income, following the repeal of Section 4940(e).
Who Must File Form 990-PF?
Not every tax-exempt organization files Form 990-PF—it’s specifically for private foundations. Here’s who qualifies:
- Exempt private foundations under Section 501(c)(3), excluding certain private operating foundations.
- Taxable private foundations under Section 6033(d).
- Section 4947(a)(1) nonexempt charitable trusts treated as private foundations (those holding contributions for charitable purposes without timely filing Form 990 or 990-EZ).
- Organizations with pending exemption applications that agree to private foundation status.
- Foreign private foundations engaging in U.S. activities.
- Former public charities transitioning to private foundation status under Sections 507 or 509.
Exceptions: Section 4947(a)(1) trusts not treated as private foundations file Form 990 or 990-EZ instead, along with Schedule A. Disregarded entities owned by the foundation must report separately if they have unique officers.
If your foundation has $5,000 or more in assets at any point during the year, public disclosure rules apply, including making the form available for inspection.
When Is Form 990-PF Due in 2025?
The deadline for Form 990-PF is the 15th day of the 5th month after your tax year’s end. For calendar-year foundations (January 1–December 31, 2024), that’s May 15, 2025. Fiscal-year filers adjust accordingly—for example, a June 30, 2024, year-end means a November 17, 2024, due date (adjusted for weekends/holidays).
Key 2025 Filing Deadlines Table
| Tax Year End Date | Original Due Date | Extended Due Date (with Form 8868) |
|---|---|---|
| December 31, 2024 | May 15, 2025 | November 17, 2025 |
| July 31, 2025 | December 15, 2025 | June 15, 2026 |
| September 30, 2025 | February 17, 2026 | August 15, 2026 |
| November 30, 2025 | April 15, 2026 | October 15, 2026 |
Note: Holidays or weekends push deadlines to the next business day.
Extensions and Amendments
- Automatic 6-month extension: File Form 8868 by the original due date—no explanation needed. Pay any estimated taxes owed to avoid interest.
- Amended returns: Mark “Amended return” in Item G and refile the full form if correcting errors. Late filings for prior years can reinstate revoked status via streamlined procedures.
Failure to file for three consecutive years results in automatic revocation of tax-exempt status.
IRS Form 990-PF Download and Printable
Download and Print: IRS Form 990-PF
How to Complete IRS Form 990-PF: Step-by-Step Guide
Form 990-PF is divided into 16 parts, plus schedules. Use the 2024 form for tax years ending before December 31, 2025, or short periods starting after November 30, 2024. Report in U.S. dollars, round to whole numbers, and attach required schedules (e.g., Schedule B for contributions over $5,000).
Essential Sections and Line Highlights
- Heading (Items A–H): Enter EIN, contact info, accounting period, and status (e.g., initial return, termination under Section 507). Check boxes for 501(c)(3) status or foreign operations.
- Part I: Analysis of Revenue and Expenses
- Columns: (a) Per books; (b) Net investment; (c) Adjusted net income; (d) Disbursements for charitable purposes.
- Key lines: 1 (contributions—attach Schedule B if needed); 3–4 (interest/dividends); 6 (asset sales—attach details); 16a–c (professional fees); 25 (grants paid—list in Part XV); 26 (total—must meet minimum distribution).
- Part II: Balance Sheet
- Columns: Beginning/ending book value (b) and fair market value (c).
- Key lines: 1–16 (assets like cash, investments); 17–23 (liabilities); 30 (net assets—updated for FASB donor restrictions).
- Part III: Net Increase or Decrease in Net Assets
- Reconciles Part I totals to balance sheet changes.
- Part IV: Capital Gains and Losses
- Details sales for lines 6–8 in Part I.
- Part V: Excise Tax Based on Investment Income
- Line 5: 1.39% of net investment income (Line 27, column (b) minus deductions).
- Exempt operating foundations: Check box if qualified under Section 4940(d)(2).
- Parts VI-A/B: Statements Regarding Activities
- Self-dealing (Line 1), excess holdings (Line 3), taxable expenditures (Line 5). Answer “Yes/No” and file Form 4720 if violations occur.
- Part VII-A: Officers and Directors
- List compensation, hours devoted. Include 5% contributors over $5,000.
- Part VIII: Charitable Activities and Program-Related Investments
- VIII-A: Direct activities (e.g., grants, programs).
- VIII-B: Investments advancing exempt purposes.
- Part IX: Minimum Investment Return
- 5% of noncharitable assets (Line 6)—basis for distributable amount.
- Part X: Qualifying Distributions (Recent Change)
- Calculates amount to distribute by year-end to avoid 30% tax.
- 2024 Update: Revised for clarity on recoveries and accumulations; applies to 2025 filings.
- Part XI: Distributable Amount
- Adjusted minimum return minus prior undistributed amounts.
- Part XII: Undistributed Income
- Tracks carryovers; excess from 2020 must be applied by end of 2025.
- Parts XIII–XVI: Supplementary Info
- XIII: Operating foundation tests.
- XIV: Grants over $5,000 (recipient details).
- XV: Income-producing activities.
- XVI: Transfers to other exempt organizations.
Pro Tip: Follow the sequencing chart in the instructions—start with Part IV, then I/II. Use cash method for column (d); accrual for others if consistent.
E-Filing Requirements for Form 990-PF
Electronic filing is mandatory for tax years beginning on or after July 1, 2019, under the Taxpayer First Act—especially for foundations with assets ≥$10 million (or ≥250 returns). Use IRS-approved software like Tax990 or e-file providers. Paper filing is rare and requires approval.
Benefits include faster processing (6–8 weeks vs. 8–12 for paper) and Electronic Funds Withdrawal for payments. For foreign bank accounts (Part VII-B, Line 16), file FinCEN Form 114 separately.
Recent Changes to Form 990-PF for 2025 Filings
While the core structure remains stable, key updates from 2024 carry over:
- Excise Tax Reduction: Locked at 1.39% on net investment income; no more qualifying for 1% rate.
- Part X Revisions: Enhanced guidance on distributable amounts, including better handling of recoveries and set-asides (effective August 2024).
- Net Assets Reporting: Aligns with FASB ASC 958—report “without donor restrictions” and “with donor restrictions.”
- Payment Options: New business payment methods announced March 2025.
- Carryover Deadline: Excess distributions from 2020 must be fully applied by December 31, 2025, or face 30% tax.
No major overhauls for tax year 2025, but check IRS.gov/Form990PF for legislation post-publication.
Penalties for Late or Incomplete Form 990-PF Filing
Non-compliance is costly:
- Failure to file timely: $20/day (up to lesser of $10,000 or 5% of assets). Minimum $400 for small foundations.
- Undistributed income tax: 30% on amounts not qualifyingly distributed by year-end.
- Revocation: Automatic after three years of non-filing—reinstate via Form 1023 or streamlined late filing.
- Other taxes: Self-dealing (initial 10%, additional 200%); excess holdings (initial 10%); taxable expenditures (20%).
State penalties may apply; furnish copies to Attorneys General in required states (e.g., CA, NY, TX).
Best Practices for Form 990-PF Compliance in 2025
- Gather records early: Financial statements, grant details, investment reports.
- Use software: Tools like TaxZerone or TurboTax streamline e-filing.
- Public disclosure: Post on GuideStar or your website; respond to inspection requests within 30 days.
- Seek help: Consult a CPA or attorney for complex items like set-asides (require IRS approval via Form 8940).
- Track distributions: Aim for 5% minimum return; excess carries over but expires after five years.
By prioritizing accuracy, your foundation can focus on impact rather than audits.
Conclusion: Stay Compliant with Form 990-PF in 2025
Filing IRS Form 990-PF is more than a requirement—it’s a commitment to transparency that builds donor trust and sustains your mission. With deadlines approaching on May 15, 2025, for most filers, start preparing now to leverage extensions if needed.
For the full form and instructions, download from IRS.gov. Questions? Contact the IRS Exempt Organizations hotline at 877-829-5500. Proper filing ensures your private foundation thrives—philanthropy without the pitfalls.
Last updated: December 2025. Always verify with official IRS sources for personalized advice.








