IRS Form 990
Commentary & IRS Instructions — Demo

Schedule F (Form 990)
Statement of Activities Outside the United States

Geralyn R. Hurd, CPA, Nicole Bencik, CPA, MST, Rachel Spurlock, CPA, Crowe Horwath LLP, Chicago

Diane Cornwell, CPA, The Starfish Group, Crestwood, KY

The information below includes the complete text of the IRS’s final instructions for the 2008 Schedule F of Form 990, interwoven with commentary by the authors.

Section references are to the Internal Revenue Code unless otherwise noted.

General Instructions

Note. Terms in bold are defined in the Glossary of the Instructions for Form 990.

Commentary

Prior to the introduction of new Schedule F, Form 990 did not request meaningful information regarding the activities conducted by a tax-exempt organization outside the United States. The new Schedule F is the beginning of an expanded effort to identify foreign activities including the general locations, nature, and magnitude of those activities. (The IRS has included Schedule F-1 for organizations to use for information that Schedule F will not accommodate.) It is anticipated that additional detailed information may be required in the future; however, because of concerns regarding the required public nature of the form and possible security issues for activities in selected parts of the world, the information the IRS is requesting is less specific than the Service originally proposed.

Purpose of Schedule

Schedule F (Form 990) is used by an organization that files Form 990 to provide information on its activities conducted outside the United States by the organization at any time during the tax year.

Activities conducted outside the United States include grantmaking, fundraising, unrelated trade or business, program services, or maintaining offices, employees, or agents for the purpose of conducting any such activities, in regions outside the United States. This includes passive investments other than financial accounts that are reported on Form 990, Part V, Statements Regarding Other IRS Filings and Tax Compliance, lines 4a and 4b.

Commentary

Because this information has not been requested previously, most institutions have not created the infrastructure or internal controls to monitor the extent of their international activities. Colleges and universities need to educate faculty and staff involved with international activities on these new information requirements and establish a system to properly document foreign activities.

First identify the awards, prizes, cash allocations, scholarships, fellowships, research grants, and similar payments and distributions made to individuals and organizations outside the United States and then analyze the legal structure of the recipient. The instructions point out that activities that are directly conducted by the reporting U.S. institution, including payments to international programs for housing students and employees, are not considered payments to a foreign organization. However, payments to a wholly owned subsidiary organized in a foreign jurisdiction must be reported. If the subsidiary is legally organized in the United States, but conducts part or all of its operations in a foreign jurisdiction, grant reporting in Part II is not required; however, reporting in Part I is required.

Note also that certain foreign passive investments must be included in determining whether the schedule applies.

United States is defined as the 50 states and the District of Columbia, the Commonwealth of Puerto Rico, the Commonwealth of the Northern Mariana Islands, Guam, American Samoa, and the United States Virgin Islands. A “foreign country” is any sovereignty that is not the United States.

Information is to be reported based on the geographic regions described below. Report activities conducted by the organization directly or indirectly through a disregarded entity, or through a joint venture taxed as a partnership.

For purposes of Schedule F (Form 990), “grantmaking” includes awards, prizes, cash allocations, stipends, scholarships, fellowships, research grants, and similar payments and distributions made by the organization during the tax year to foreign organizations, foreign governments, or foreign individuals. It does not include salaries or other compensation to employees.

Commentary

The instructions specifically state that for purposes of Schedule F, foreign individuals include a U.S. citizen who at the time the grant is paid is living or residing outside the United States. Commenters suggested establishing a minimum time period for the individual to be outside the United States in order to be considered a "foreign individual" for this purpose; however, the IRS did not adopt such a provision in the instructions. As a result, if a student goes abroad to study for example, it appears the individual is considered to be living or residing outside the United States if the grant is paid during the student’s stay in the foreign country. Colleges and universities should weigh various options with regard to grant payment, as the individual’s location at the time the grant is paid appears to be the determining factor.

“Program services” are activities conducted by the organization outside the United States that form the basis of the organization’s exemption from federal income tax. Examples of program services include, but are not limited to, operating an orphanage, school, hospital, church, temple, mosque, or synagogue; disaster relief efforts; and providing indigent relief.

See Glossary in the Instructions for Form 990 for the definition of the following terms.

• “Unrelated trade or business.”
• “Fundraising activities.”
• “Maintaining offices, employees or agents.”
• “Foreign organization.”
• “Foreign government.”
• “Foreign individual.”

Use Schedule F-1 (Form 990), Continuation Sheet for Schedule F (Form 990), to report additional information for Schedule F (Form 990), Part I, Part II, or Part III. Use as many Schedules F-1 (Form 990) as needed.

Who Must File

Any organization that answered “Yes” to Form 990, Part IV, Checklist of Required Schedules, lines 14b, 15, or 16, must complete the appropriate parts of Schedule F (Form 990) and attach Schedule F (Form 990) to Form 990.

Commentary

These questions probe revenues, expenses, and grants made to organizations and individuals outside the United States.

If the institution had aggregated revenues or expenses of more than $10,000 from grantmaking, fundraising, business, and program activities outside the United States, complete Schedule F, Part I.

If the institution reported more than $5,000 of grants or assistance to any organization or entity located outside the United States on Part IX, line 3, complete Schedule F, Part II.

If the institution reported more than $5,000 aggregate grants or assistance to individuals located outside the United States, complete Schedule F, Part III.

If an organization is not required to file Form 990 but chooses to do so, it must file a complete return and provide all of the information requested including the required schedules.

Regions

Commentary

The instructions identify nine geographic regions and list the countries in each of those regions for purposes of Schedule F reporting. Institutions are not required to, and should not, specifically identify the countries where they conduct activities. The instructions also state that if a country where an institution is operating is not specifically listed, the institution should assign it to an appropriate region.

Reporting on Schedule F (Form 990) is based on the following geographic regions.

Central America and the Caribbean

Antigua & Barbuda, Aruba, Bahamas, Barbados, Belize, Cayman Islands, Costa Rica, Cuba, Dominica, Dominican Republic, El Salvador, Grenada, Guadeloupe, Guatemala, Haiti, Honduras, Jamaica, Martinique, Nicaragua, Panama, St. Kitts & Nevis, St. Lucia, St. Vincent & the Grenadines, Trinidad & Tobago, Turks & Caicos Islands, and British Virgin Islands.

East Asia and the Pacific

Australia, Brunei, Burma, Cambodia, China (including Hong Kong), East Timor, Fiji, Indonesia, Japan, Kiribati, Korea, Laos, Malaysia, Marshall Islands, Micronesia, Mongolia, Nauru, New Zealand, North Korea, Palau, Papua New Guinea, Philippines, Samoa, Singapore, Solomon Islands, South Korea, Taiwan, Thailand, Timor-Leste, Tonga, Tuvalu, Vanuatu, and Vietnam.

Europe (Including Iceland and Greenland)

Albania, Andorra, Austria, Belgium, Bosnia & Herzegovina, Bulgaria, Croatia, Czech Republic, Denmark, Estonia, Finland, France, FYR Macedonia, Germany, Greece, Greenland, Holy See, Hungary, Iceland, Italy, Ireland, Kosovo, Latvia, Liechtenstein, Lithuania, Luxembourg, Monaco, Montenegro, the Netherlands, Norway, Poland, Portugal, Romania, San Marino, Serbia, Slovakia, Slovenia, Spain, Switzerland, Turkey, and the United Kingdom (England, Northern Ireland, Scotland, and Wales).

Middle East and North Africa

Algeria, Bahrain, Djibouti, Egypt, Iran, Iraq, Israel, Jordan, Kuwait, Lebanon, Libya, Malta, Morocco, Oman, Qatar, Saudi Arabia, Syria, Tunisia, United Arab Emirates, West Bank and Gaza, and Yemen.

North America

Canada and Mexico, but not the United States.

Russia and the Newly Independent States

Armenia, Azerbaijan, Belarus, Georgia, Kazakhstan, Kyrgyzstan, Moldova, Russia, Tajikistan, Turkmenistan, Ukraine, and Uzbekistan.

South America

Argentina, Bolivia, Brazil, Chile, Colombia, Ecuador, French Guiana, Guyana, Paraguay, Peru, Suriname, Uruguay, and Venezuela.

South Asia

Afghanistan, Bangladesh, Bhutan, India, Maldives, Nepal, Pakistan, and Sri Lanka.

Sub-Saharan Africa

Angola, Benin, Botswana, Burkina Faso, Burundi, Cameroon, Cape Verde, Central African Republic, Chad, Comoros, Democratic Republic of the Congo, Republic of the Congo, Cote D’Ivoire, Equatorial Guinea, Eritrea, Ethiopia, Gabon, Gambia, Ghana, Guinea, Guinea Bissau, Kenya, Lesotho, Liberia, Madagascar, Malawi, Mali, Mauritania, Mauritius, Mozambique, Namibia, Nigeria, Rwanda, Sao Tome & Principe, Senegal, Seychelles, Sierra Leone, Somalia, South Africa, Sudan, Swaziland, Tanzania, Togo, Uganda, Zambia, and Zimbabwe.

If an organization’s activities involve a country not listed earlier, designate the appropriate region for the country.

Specific Instructions

Part I. General Information on Activities Outside the United States

Complete Part I if the organization answered “Yes” to Form 990, Part IV, line 14b. This means the organization had aggregate revenues or expenses of more than $10,000 from or attributable to grantmaking, fundraising, business, and program services outside the United States.

Commentary

Part I reporting includes direct foreign activities of the reporting organization, including direct operations and grantmaking to foreign organizations and/or individuals. As the following IRS Tip states, in those instances when the organization's activities include grantmaking to foreign organizations and/or individuals, the activity may be reported twice — first in Part I and then in Parts II (organizations) or III (individuals), depending on the recipients and amounts involved. In determining whether reporting in Part II is required, it is important to review the legal structure of the recipient organization. The instructions point out that activities directly conducted by the reporting U.S. organization, including payments to branches and employees, are not considered payments to a foreign organization. For example, if a college owns and operates a campus in a foreign country, payments to employees of the campus would not be reported in Part II. However, it appears that payments to a wholly owned subsidiary legally organized in a foreign jurisdiction would require reporting in Part II. If the subsidiary were legally organized in the United States, but conducted part or all of its operations in a foreign jurisdiction, grant reporting would not be required in Part II.

If the filing organization meets this $10,000 threshold, it must also report information from all off-shore investments, even if those investments are passive, unless the institution indicates on Form 990, Part V, line 4B, that it has filed Form TD F 90-22.1 for these investments.

TIP: If an organization that completes Part I makes grants to foreign organizations or foreign individuals, it may also need to complete, as applicable, Parts II or III. If the organization does not make any such grants, it does not need to complete Parts II or III.

Lines 1–2. Complete these lines only if the organization made grants directly to foreign organizations, foreign governments, or foreign individuals.

Indicate “Yes” or “No” regarding whether the organization maintains records to substantiate amounts, eligibility, and selection criteria used for grants. Describe how the organization monitors its grants to ensure that such grants are used for proper purposes or are not otherwise diverted from the intended use. For example, the organization may describe periodic reports required or field investigations conducted; or it may indicate that the organization is a “friends of” organization that supports specified foreign organizations. Use Part IV of this schedule for the narrative response to line 2.

Commentary

It is important to first determine whether the institution is making grants to a "foreign organization" or a "foreign individual." “Foreign organization” is defined in the Glossary as a “foreign estate or trust, nonprofit or other nongovernmental organization, partnership, corporation, or other entity that is not created or organized in the United States or under the laws of the United States. A foreign organization includes an affiliate that is organized as a legal entity separate from the filing organization, but does not include any branch office, account, or employee of the organization located outside the United States.”

A “foreign individual,” as defined in the Glossary, is “a person, including a U.S. citizen or resident, who lives or resides outside the United States at the time the grant is paid or distributed to the individual.”

Thus, if the institution only transfers funds to its own branch or employees, then these questions should not be answered. If the institution includes "grants" as one of its listed activities in line 3(d), the questions should be answered.

Part IV of the schedule is used for the narrative responses to line 2 describing the procedures for monitoring use of grant funds.

Although not specified in the instructions, an IRS response to a question posed during its Form 990 educational session, Tax Talk Today, indicates that an institution must respond to questions on the form based on policies and procedures that were in place at the end of the tax year, not based on any policies and procedures adopted after the close of the tax year.

Line 3. Enter the details for each type of activity conducted at any time during the tax year in each region on a separate line of Part I. Use the regions listed earlier.

Commentary

The institution may wish to develop a matrix for its records to support the summary information provided on Schedule F. The matrix could include each country within the region, each activity for that country, numbers of offices, etc. Using the matrix, you can determine the subtotals for each region and report them on Schedule F. If the institution is audited, the matrix would provide support for the Schedule F information.

Column (a). Identify each region in which the organization conducts grantmaking, fundraising, business, or program service activities.

Column (b). If the organization answered “Yes” to Form 990, Part IV, line 14a, and the organization maintained offices outside the United States, list in this column the number of offices maintained by the organization in each region listed during the tax year. See Glossary for definition of “maintaining offices.”

Commentary

The Glossary defines “maintaining offices” as follows:

For purposes of Schedule F, Statement of Activities Outside the United States, includes principal, regional, district, or branch offices, such offices maintained by agents, and persons situated at those offices paid wages for services performed. “Agent” is defined under traditional agency principles (but does not include volunteers).

It’s important to determine the legal structure of the operation in order to determine whether the institution is “maintaining an office.” If a separate legal entity (such as a subsidiary) is conducting activities, it would be the responsibility of that legal entity to report the “maintenance of an office.” The institution would then report a grant to the subsidiary in Part II. If the institution was actually paying employees, establishing a satellite campus, renting space or teaching programs, it would describe those offices here.

Column (c). If the organization answered “Yes” to Form 990, Part IV, line 14a, and the organization maintained employees or agents outside the United States, list in this column the total number of employees and agents working in each region listed, during the tax year. Do not include in this number any of the organization’s employees or agents whose only presence in the region is to conduct on-site visits, or persons who serve as volunteers. See Glossary for definition of “maintaining employees or agents.”

Commentary

Line 14a asks whether the institution maintained an office, employees, or agents outside the U.S.

The definition in the Glossary makes it clear that for purposes of Schedule F, "agent" is defined under traditional agency principles and does not include volunteers. The instructions are not clear as to how the institution determines the number of employees/agents to be reported. Arguably an FTE approach or any other method that reflects an accurate picture of the level of activity should be acceptable. The institution should document its methodology and consider disclosing the approach taken in determining the number reported in Part IV of this schedule.

Column (d). Specify in this column the type(s) of activity(ies) conducted in each region. Types of activities include the following: grantmaking, fundraising, unrelated trade or business, or program services. If multiple activities are conducted per region, list each type of activity on a separate line and repeat regions in column (a) as necessary.

Commentary

Column (d) is a listing of the various activities conducted in the region. There is no requirement that detailed expenditure levels, staffing, etc. be provided for each activity. Note that if the institution reports grantmaking as an activity, it then must determine whether Part II or III of the schedule must be completed.

Column (e). If “program services” is the listed activity in column (d), provide a description of the specific program service.

Commentary

The descriptions for program services provided here should be consistent with the college or university’s stated exempt purposes and other sections of Form 990.

Column (f). Enter the total amount of expenditures for activities conducted in each listed region. Expenditures include salaries, wages, and other employment-related costs paid to or for the benefit of employees located in the region; rent and other costs relating to offices located in the region; grants to recipients located in the region; bank fees and other financial account maintenance fees and costs; and payments to agents located in the region. Report expenditures based on the method used to account for them on the organization’s financial statements, and describe this method in Part IV.

Commentary

It is only necessary to report the total expenditures related to the activities in each region. For reporting purposes, the detail of those expenditures regarding each type of activity (e.g., program services, grants to recipients) or type of expenditure (e.g., salaries, rent) need not be reported. However, the institution should retain the underlying detail in the event of an IRS audit. Institutions may use Part IV of this schedule for additional explanations necessary for this column.

Part II. Grants and Other Assistance to Organizations or Entities Outside the United States

Commentary

For definitions, see Commentary to Part I, lines 1–2.

The section is only necessary if the college or university has paid more than $5,000 to any foreign organization. This does not include transfers to a foreign campus or location that is not structured as a separate legal entity or office of the college of university. It does appear to include "grants" to a separately established foreign subsidiary. It is important to understand the legal structure of the awardee organization and the nature of payments made. If no one recipient organization received more than $5,000, the box at the top of the Part II should be checked, and the schedule need not be completed. This test appears to be on a recipient basis and is cumulative for the reporting period.

Complete Part II if the organization answered “Yes” on Form 990, Part IV, line 15. A “Yes” response means that the organization reported on Form 990, Part IX, Statement of Functional Expenses, line 3, more than $5,000 of grants or assistance to any particular foreign organization or entity (including a foreign government).

Caution: Do not complete columns (a) or (b). However, complete columns (c) through (i) as if columns (a) and (b) were completed.

Commentary

Column (a), Name of Organization, and Column (b), IRS code section and EIN (if applicable), are not required until the IRS issues further guidance. Organizations had expressed concern about security if detailed grantee information were required for foreign grants due to the public disclosure requirements associated with Form 990. Although not required for filing, you may wish to develop a detailed schedule that includes the names of the recipient organizations, IRS code section, EIN, and other relevant information for your records. The Form 990 that your institution files would not include this information. It should be noted that most foreign organizations will not have an EIN and will not have an identified IRS code section.

Line 1. Enter information only for each recipient organization or entity that received more than $5,000 total of grants or assistance from the organization for the tax year.

TIP: If the organization checked the box on Schedule F (Form 990), Part II, that no one recipient received more than $5,000, do not complete line 1.

Enter the details of each organization or entity on a separate line. If there are more organizations or entities to report in Part II than space available, report the additional organizations or entities on Schedule F-1 (Form 990), Part II. Use as many Schedules F-1 (Form 990) as needed.

Column (c). Specify the region where the principal office of the recipient organization or entity is located. See Regions earlier.

Column (d). Describe the purpose or ultimate use of the grant funds. Do not use general terms, such as charitable, educational, religious, or scientific. Use more specific descriptions such as general support, school or hospital construction, purchase of medical supplies or equipment, purchase of school books or school supplies, provision of clothing, food, etc. In the case of specific disaster assistance, include a description of the disaster, such as tsumani or earthquake relief.

Column (e). Enter total dollar amount of cash grants, in U.S. dollars, to each recipient foreign organization or entity for the tax year. Cash grants include grants or allocations paid by cash, check, money order, wire transfers, and other charges against funds on deposit at a financial institution.

Column (f). Describe the manner of cash disbursement, such as by cash payment, money order, electronic fund or wire transfer, check, other charges against funds on deposit at a financial institution, or other. List all that apply for each recipient.

Column (g). Enter the fair market value of any noncash property in U.S. dollars.

Column (h). For noncash property or assistance, enter a description of the property or assistance. List all that apply. Examples of noncash assistance include medical supplies or equipment, pharmaceuticals, blankets, books or other educational supplies.

Column (i). Describe the method of valuation. Report property with a readily determinable market value at its fair market value. When fair market value cannot be readily determined, use an appraised or estimated value.

Line 2. Add number of recipient foreign organizations listed on line 1(a) that are recognized by the Internal Revenue Service as exempt from federal income tax as described in section 501(c)(3); (b) that are recognized as a charity by a foreign country; or (c) for which the grantmaker has made a good faith determination, based on an affidavit from the grantee or the opinion of counsel, that the grantee is the equivalent of a public charity. Enter total number of such organizations.

Commentary

The IRS does not require all grant recipients to qualify as charities under either U.S. or foreign law, as long as the purpose of the grant is consistent with the exempt purpose of the institution. As part of an institution’s support for and tracking of its grants, the institution should identify whether the recipient is a U.S. charity (as published in Pub. 78, Cumulative List of Organizations Described in Section 170(c) of the Internal Revenue Code of 1986). The institution also should document how the grant serves its exempt purpose.

Line 3. Enter total number of recipient foreign organizations listed on line 1 that are not described on line 2 above.

Commentary

Although it is not a requirement that all grant recipients qualify as charities under either U.S. or foreign law, a large number or amount of grants to these non-qualifying types of organizations may subject the institution to greater scrutiny by the IRS and/or general public.

Part III. Grants and Other Assistance to Individuals Outside the United States

Complete Part III if the organization answered “Yes” on Form 990, Part IV, line 16. A “Yes” response means that the organization reported on Form 990, Part IX, line 3, more than $5,000 of grants or assistance to foreign individuals.

Commentary

The instructions specifically state that for purposes of Schedule F, foreign individuals include a U.S. citizen who at the time the grant is paid is living or residing outside the United States. Commenters suggested that the IRS specify some minimum time period for the individual to be outside the United States in order to be considered a "foreign individual" for this purpose; however, the IRS did not adopt such a provision in the instructions. As a result if a U.S. citizen or resident goes abroad to study, for example, it would appear he or she would be considered to be living or residing outside the U.S. if a grant is paid during that time. Colleges and universities might review their options for paying grants because the grantee’s residential status at the time the grant is paid appears to be the determining factor as to whether the grantee is a foreign individual for purposes of the schedule.

Enter information for grants or assistance directly made to or for the benefit of foreign individual recipients. Do not complete Part III for grants or assistance provided to individuals through another organization or entity. Instead, complete Part II for such grants or assistance. For example, report in Part III a payment designated to cover the medical expenses of a foreign individual to a hospital located outside the United States. Report in Part II a contribution to provide a service to the general public or to unspecified charity patients in a hospital located outside the United States.

Enter the details of each type of grantor assistance to individuals on a separate line. If there are more types than space available, report the additional items on Schedule F-1 (Form 990), Part III. Use as many Schedules F-1 (Form 990) as needed.

Commentary

Part III of the instructions is intended for reporting of scholarships or grants paid to non-U.S. citizens, whether these grants are for learning activities in the United States or on a non-U.S. campus. Based on the information, the IRS will be able to identify institutions with significant foreign activities or nonresident aliens in the United States. While the instructions aren't exactly clear, it appears that scholarships paid to any non-U.S. citizen or green card holder would be reported on Schedule F rather than on Schedule I.

Column (a). Specify type(s) of assistance provided, or describe the purpose or use of grant funds. List all that apply for each region. Do not use general terms such as charitable, educational, religious, or scientific. Use more specific descriptions, such as scholarships, food, clothing, shelter for indigents or disaster victims, direct cash assistance to indigents, medical supplies or equipment, books or other educational supplies, etc. In the case of specific disaster assistance, include a description of the disaster, such as tsumani or earthquake.

Column (b). List each region in which grants or other assistance were provided to foreign individual recipients. See Regions, earlier.

Column (c). For each type of assistance provided in each region listed, enter the number of recipients that received the type of assistance in that region. If the filing organization does not have a way to determine a specific number, estimate the number. Explain in Part IV how the organization arrived at the estimate.

Column (d). Enter aggregate amount of cash grants, in U.S. dollars, provided to recipients in each region for each type of assistance. Cash grants include only grants or allocations paid by cash, checks, money orders, electronic fund or wire transfers, and other charges against funds on deposit at a financial institution.

Commentary

Although it is not necessary to report assistance amounts paid to individuals, a college or university should consider maintaining detailed documentation to support the amounts, broken out by region, so that it is available in the event of an IRS audit. In addition, the total of all amounts in column (d) should match the amount reported on Form 990, Part IX, Statement of Functional Expenses, line 3.

Column (e). Describe the manner of cash disbursement, such as by cash payment, money order, electronic fund or wire transfer, check, other charges against funds on deposit at a financial institution, or other. List all that apply for each region.

Column (f). Enter the fair market value of noncash property, in U.S. dollars for each type of assistance. If multiple properties were transferred for the type of assistance, enter information for each.

Column (g). For noncash property, enter a description of the property. If multiple properties were transferred, enter a description of each.

Column (h). Describe the method of valuation. Report property with a readily determinable market value at its fair market value. When fair market value cannot be readily determined, use an appraised or estimated value.

Part IV Supplemental Information

Use Part IV to provide narrative information required in Part I, line 2, regarding monitoring of funds. Use Part IV to describe the method used to account for expenditures in Part I, line 3, column (f). Use Part IV to explain how the organization estimated the number of recipients reported in Part III, column (c). Also use Part IV to provide other narrative explanations and descriptions, as needed. Identify the specific part and line(s) that the response supports. Part IV may be duplicated if more space is needed.

Commentary

Depending upon the volume of a college or university’s programs and activities outside the United States, Schedule F may not provide sufficient room to record all the requested information. The IRS has provided Schedule F-1, which mirrors all parts of Schedule F, to use for additional information.

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