Fall 2008 issue of Horizons

knowledge. commitment. value. CERTIFIED PUBLIC ACCOUNTANTS AND BUSINESS CONSULTANTS

• Has, or shares, the authority to control 5 percent of the organization’s capital expenditures, operating budget or employee compensation Compensation is defined as the amounts reported in Box 5 of Form W-2 for employees or Box 7 of Form 1099- Misc. for any directors or trustees. Other items management should note within Form 990 include questions in section VI under “Policies.” The questions require “yes” or “no” answers regarding the implementation of the following: • “Conflict of Interest Policy” • “Annual Disclosure of Interests” • “Enforcement of Conflicts Policy” • “Whistleblower and Document Retention Policy” These are fairly self-explanatory and are some of the best practice policies pulled from the Sarbanes- Oxley guidance that should be implemented by tax- exempt organizations. Form 990 also requests a “yes” or “no” answer covering the organization’s process for determining compensation reported in Part VII for the CEO, executive director and other top management. The question asks if there is 1) a review and approval by the governing body or compensation committee, 2) use of data for comparison to similar qualified positions in comparable organizations, and 3) retention of documentation with respect to the deliberations and decisions regarding the compensation arrangement. All of the items noted above may require some additional thought and consideration prior to the end of the club’s fiscal year and filing of the related Form 990.

Questions? Contact:

Jim Mather, CPA Partner-in-Charge Hospitality and Gaming Services Group 314.290.3470 jim.mather@rubinbrown.com

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