Navigating Foreign Activities Reporting Requirements for Exempt Organizations: Form 990 Sch. 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

Conducted on Wednesday, January 6, 2016

Recorded event now available

or call 1-800-926-7926
Program Materials

This webinar 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 on 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, nonprofit must frequently disclose foreign activities on a number of information forms.

Exempt organizations with foreign assets or activites above a specified threshold are subject to filing Forms 926, 8621, 8865, and FinCEN 114 (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 fairly 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 what assets and transactions must be reported, and on what form, can present significant challenges to exempt org tax advisers, and with the costs of even innocent mistakes being so high, 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 3520, Transactions With Foreign Trusts
    3. Form 5471, Information Return of U.S. Persons With Respect to Foreign Corporations
    4. Form 8621, Passive Foreign Investment Company
    5. Form 8865, Return of U.S. Persons With Respect to Certain Foreign Partnerships
    6. Form 5713, International Boycott Report
  4. FinCen 114 (formerly TDF 90-22.1 or 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.


Brian Yacker
Brian Yacker

Managing Partner
YH Advisors | The Exempt Org Experts

Mr. Yacker has more than 20 years of tax, legal and accounting advisory work with exempt organizations. In that time,...  |  Read More

Alycia Mecchella
Alycia Mecchella
Tax Manager
Grant Thornton

Ms. Mecchella works in her firm's not-for-profit and corporate practices. She is experienced serving clients...  |  Read More

April Stith, CPA
April Stith, CPA

Tax Senior Manager
Moss Adams

Ms. Stith is well-versed in foreign reporting. Her practice focuses on tax-exempt organizations as well as trust and...  |  Read More

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