The American Institute of CPAs has sent the Internal Revenue Service a spreadsheet-full of comments on the draft instructions for the revised Form 990 that will be used by tax-exempt organizations to file their returns next year.

The AICPA objected to the expansion of the definition of a "key employee" to include anyone who manages a segment or activity representing 5 percent or more of a charity's activities, assets, income, expenses, capital expenditures, operating budget or employee compensation. The institute contended that the 5 percent threshold was unrealistic and would result in an "exponential increase" in the number of key employees, especially for larger organizations.

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