Form 990 for 501(c)(4), 501(c)(6) and 501(c)(7) organizations

Most writing about the Form 990 assumes a 501(c)(3) charity. But homeowners' and civic associations, advocacy groups, chambers of commerce, professional societies, country clubs, hobby clubs and veterans' posts file the same family of returns. The core of the form is the same. What changes is a handful of schedules and questions that reflect how these organizations raise money and what they are allowed to do with it.

The basics are the same

Which return you file still depends on gross receipts and assets: the 990-N if gross receipts are normally $50,000 or less, the 990-EZ if gross receipts are under $200,000 and assets under $500,000, and the full Form 990 otherwise. The due date is the 15th day of the 5th month after year end, the late-filing penalties are the same, and three missed years still mean automatic revocation.

What doesn't apply: Schedule A (public charity status) is for 501(c)(3)s only, and so is Part II of Schedule C, which covers lobbying limits for charities.

Lobbying, politics and Schedule C

Political activity (Part I-C)

Any 501(c) organization that answers "Yes" to political campaign activity completes Schedule C, Part I-A, and organizations other than 501(c)(3)s also complete Part I-C. That part reports money spent on section 527 exempt function activities (influencing the selection or election of candidates) and amounts transferred to political organizations, including a separate segregated fund or PAC. The total is also carried to Form 1120-POL. Under section 527(f), a 501(c) organization that spends money on these activities is taxed on the lesser of its net investment income or the amount it spent.

The section 6033(e) dues notice and proxy tax (Part III)

Members can't deduct as a business expense the part of their dues that pays for lobbying and political activity. So section 6033(e) requires 501(c)(4), 501(c)(5) and 501(c)(6) organizations that receive dues to do one of two things:

1. Send dues notices at the time of assessment or payment that reasonably estimate the share of dues allocable to nondeductible lobbying and political expenditures, or
2. Pay a proxy tax instead, at 21% of the nondeductible amount not covered by notices. The proxy tax is reported on Form 990-T, with no deductions allowed.

If actual lobbying and political spending turns out higher than the estimate in the notices, the organization owes proxy tax on the excess, unless the IRS allows it to carry the difference into next year's estimate.

Who is exempt from these rules. Schedule C, Part III-A lists the exceptions. The most common are:

• In-house lobbying of $2,000 or less for the year (excluding overhead), with no political or foreign lobbying spending and no other lobbying
• Organizations that receive more than 90% of their dues from other tax-exempt organizations (other than 501(c)(4), (5) and (6)s), state or local governments, or similar entities
• 501(c)(4) and (5) organizations receiving more than 90% of their dues from persons, families or entities who each paid annual dues of $143 or less in 2025 or $147 or less in 2026 (inflation-adjusted each year)
• Organizations that keep records showing 90% or more of members can't deduct their dues anyway
• Organizations that aren't membership organizations

A trade association whose members are businesses that deduct their dues rarely fits these exceptions, so a 501(c)(6) that lobbies usually has to choose each year between dues notices and the proxy tax.

501(c)(4) social welfare organizations

Form 8976 notice

Every new 501(c)(4) must notify the IRS of its intent to operate as a social welfare organization within 60 days of formation, on Form 8976, submitted only online through Pay.gov with a $50 fee. This applies whether or not the organization also asks for recognition on Form 1024-A, which is optional for 501(c)(4)s. Filing Form 8976 is not a determination of exempt status, and it doesn't replace the annual return. If the notice is late, the IRS assesses a penalty of $20 per day, up to $5,000.

Insider transactions and compensation

Like 501(c)(3)s, 501(c)(4)s are subject to the excess benefit transaction rules, so the compensation questions on Schedule J, Part I, lines 5 through 9 apply to them. See our compensation reporting guide.

Nondeductibility disclosure

Gifts to a 501(c)(4) or 501(c)(6) generally aren't deductible as charitable contributions. An organization with gross receipts normally over $100,000 must state clearly in its fundraising solicitations, including dues solicitations, that contributions aren't deductible as charitable contributions. Form 990, Part V, line 6 asks about it. The penalty for failing to disclose is $1,000 per day, up to $10,000 a year, unless the failure was due to reasonable cause.

501(c)(6) business leagues and trade associations

Beyond dues notices, the issues that most often affect a trade association's return are unrelated business income: advertising in member magazines, paid listings in directories, insurance or affinity programs, and sponsorship arrangements that look more like advertising. If gross income from an unrelated business is $1,000 or more, the association files Form 990-T. Our guide to unrelated business income examples walks through common cases.

501(c)(7) social clubs

Limits on nonmember income

A social club stays exempt only if it is supported mainly by its members. A club can receive up to 35% of its gross receipts, including investment income, from sources outside its membership, and no more than 15% of gross receipts may come from the general public's use of club facilities. For this test only, gross receipts are the club's income from its usual activities (charges, admissions, dues, assessments and investment income) and exclude initiation fees, capital contributions and unusual items such as selling the clubhouse.

Form 990, Part V, line 10 asks a club to report the initiation fees and capital contributions included in revenue, and its gross receipts from public use of club facilities.

Tax on nonmember income

For a social club, unrelated business taxable income is broadly all gross income from nonmembers, less directly connected expenses. That includes the restaurant and bar revenue from nonmember guests and, unlike for most other exempt organizations, investment income: interest, dividends and gains. A club with $1,000 or more of such gross income files Form 990-T, reporting investment income in Schedule A (Form 990-T), Part VII. Amounts set aside for charitable purposes can be excluded.

A club also can't have a written policy that discriminates on the basis of race, color or religion; Form 990, Part V asks about it.

Schedule B for these organizations

501(c)(4), (6) and (7) organizations complete Schedule B under the $5,000 general rule if they have contributors that meet it, but they enter "N/A" instead of names and addresses, keeping that information in their own records for the IRS. Clubs and fraternal organizations follow a special rule for gifts made exclusively for charitable purposes. Our Schedule B guide has the details.

990IRS.com is a private company, not the IRS. This page is general information, not legal or tax advice for your organization. Example organizations and figures are hypothetical.