Yes, you're correct in assuming that a chief executive should be listed in both Part VII-A and schedule J regardless of compensation. The person's title has less to do with the requirement than the person's level of responsibility. The organization's top financial official must also be listed, whether this is a board member or a staff member.

I just sent in the 501-c-3 application to the IRS. I have to laugh, my tiny agency hasn't cracked the $5,000 per year limit yet and I'm reading about $1 & 2.5 million dollar agencies-I'll download the form and read it all the way through, I'm sure my sides will hurt by the end of it!

I guess a girl can dream big!

A confusing bit from the IRS's revised 990 instruction pdf...

First this, regarding the $0 compensation threshold for the reporting of "officer" salaries and payments...

* current officers, directors, and trustees (no minimum compensation threshold)

Then this bit that seems to define the senior day-to-day staff person, executive director, or general manager as an officer (no matter how the organization's by-laws treat him/her)...

For purposes of Form 990 reporting, including Part VII, Section A and Schedule J, treat as an officer the following persons, regardless of their titles:

1. Top management official. The person who has ultimate responsibility for implementing the decisions of the governing body or for supervising the management, administration, or operation of the organization.

That would mean that the compensation of a chief executive earning well under the $150,000 "key employee" threshold, must still be reported under the officers, directors, and trustees disclosure (even if that salary were $1/year).

Do y'all agree with my reading of it?