Earlier today you should have received an email from Kim Collins about whether NPCs are “related” to VAMCs for purposes of responding to the question in Line 34 in Part IV of the 2008 and 2009 IRS Form 990. 

The email from Kim includes a NAVREF response to an inquiry from one NPC and was intended to expand on the response the NPC received from the NPPO.  It omits NAVREF’s recommendation that regardless of our own conclusions, the NPC should consult with its own CPA 990 preparer to determine whether the NPC is related.  Relatedness depends on facts and circumstances particular to each NPC, including its IRS sub classification within 501(c)(3) and the composition of its board.  This is consistent with NAVREF’s discussion of relatedness between NPCs and VAMCs in a September 10, 2009, newsletter item.  See:  http://www.navref.org/newsletter/2009/update_09-10-2009.htm#3.__IRS%20Form_990_Schedule_J_and_R_Guidance

Again, NAVREF encourages each NPC to consult with its own accountant to determine whether their NPC is “related” to their VAMC.