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Foreign Activities Reporting Requirements for Exempt Organizations: Form 990 Schedule F and Other Returns

Identifying Required Disclosures and Tracking Location and Nature of Foreign Accounts For Nonprofits

Recording of a 110-minute CPE webinar with Q&A

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Conducted on Tuesday, January 14, 2020

Recorded event now available

or call 1-800-926-7926

This course will provide an in-depth exploration into the determinations, calculations, disclosures, and tax reporting of foreign investments, accounts, and activities held or engaged in by nonprofit/exempt organizations. The panel will offer practical guidance into identifying foreign investments that do--and do not--require disclosure on Form 990 Schedule F and other returns, tracking the location of foreign accounts and investments, and reporting operations in a boycotting country.


The IRS has increased its focus and scrutiny of foreign-based assets owned by U.S. taxpayers, and this scrutiny extends to exempt organizations. In recent years, the Service has released several information-gathering forms in an attempt to quantify overseas activities of U.S. taxpayers. While tax-exempt organizations do not face the same degree of disclosure requirements that for-profit entities or individuals face, nonprofits must frequently disclose foreign activities on several information forms.

Exempt organizations with foreign assets or activities above a specified threshold are subject to filing Forms 926, 8621, 8865, 5471, and the FBAR, and may have to report their foreign activities on Schedule F of Form 990. Most reporting of grants and exempt activity in foreign countries is relatively straightforward. However, the various requirements to account for foreign-based income and assets are more complex, and failure to complete foreign disclosure information filings can result in substantial penalties.

Understanding the assets and transactions to report, and on what form, presents significant challenges to exempt organization tax advisers. With the high costs of even innocent mistakes, tax professionals must know the rules for disclosing foreign assets, transfers, and income.

Listen as our experienced panel provides detailed guidance on navigating the various disclosure requirements for exempt organizations engaged in foreign activities or holding foreign investments, with concrete examples of completed forms and schedules.



  1. Definition of reportable foreign activities
  2. Form 990 Schedule F
    1. Reporting grants and exempt activities
    2. Schedule F, Part IV: statements of transfer to or ownership of foreign assets
  3. Other forms
    1. Form 926, Transfers of Property to a Foreign Corporation
    2. Form 5471, Information Return of U.S. Persons With Respect to Foreign Corporations
    3. Form 8621, Passive Foreign Investment Company
    4. Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships
    5. Form 5713, International Boycott Report
  4. The FBAR
  5. Case study with illustrations


The panel will discuss these and other critical issues:

  • What are the thresholds for various reporting obligations of foreign transfers, asset ownership, or income?
  • What is the interplay among Form 990 Schedule F and other foreign informational forms?
  • Interpreting K-1s with foreign holdings and other foreign income and asset statements to determine how and where to report activities and ownership of foreign assets.


Coburn, Jackie
Jackie Coburn, CPA

Tax Senior Manager

Ms. Coburn has experience in tax Compliance and Planning, including representation with taxing authorities -- federal,...  |  Read More

Kranich, Kristin
Kristin Kranich, CPA

Senior Manager International Tax

Ms. Kranich serves clients in multiple industries, including the manufacturing, distribution, retail, and service...  |  Read More

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