990 Schedule F: Step-by-Step Instructions for Filing

Tax-exempt organizations use Form 990 as their annual information return to the IRS. For organizations with international dealings, Schedule F, “Statement of Activities Outside the United States,” is a component of this filing. This schedule provides the IRS with a detailed look at an organization’s program services, financial transactions, and operational footprint beyond U.S. borders. It is not a standalone form but is attached to Form 990 when specific criteria are met. The process involves evaluating your foreign activities against specific financial thresholds and operational presence tests.

Determining if You Must File Schedule F

An organization must file Schedule F if it answers “Yes” to questions 14b, 15, or 16 on Form 990, Part IV, Checklist of Required Schedules. These questions are designed to identify organizations with significant activity or financial interest outside the United States.

The primary trigger, related to question 14b, is financial. An organization must file if it had aggregate revenues or expenses of more than $10,000 from activities conducted outside the U.S. These activities include grantmaking, fundraising, business operations, and program services. For example, if a charity spends $12,000 on disaster relief efforts in another country, it would meet this expense threshold.

A separate trigger, also linked to question 14b, involves foreign investments. If an organization held investments in foreign entities with an aggregate book value of $100,000 or more at any point during the tax year, it must file Schedule F. The valuation is based on the book value of the investments, not their market value.

The final triggers relate to grants. An organization must file if it provided grants or other assistance totaling more than $5,000 to any single foreign organization or entity, which corresponds to question 15. A similar rule applies to assistance for individuals; if an organization provided more than $5,000 in aggregate grants to foreign individuals, it must file, which is triggered by question 16.

Information and Documentation Required for Schedule F

Gathering all necessary information before starting will help ensure an accurate filing. For Part I, you will need to compile data on your foreign activities by geographic region, including the total amount of foreign expenses, the number of offices, and a count of all employees and agents working in each region.

For grants and other assistance reported in Parts II and III, detailed records for each recipient are necessary. If the recipient is an organization, you will need its legal name, physical address, and EIN if it has one. You must also have the specific cash amount of the grant and a description and fair market value of any non-cash assistance provided.

When reporting assistance to individuals in Part III, the required information is similar but adapted for individual recipients.

If your organization has foreign financial interests, you will need the name and location of any foreign financial institution where the organization maintains an account for Part IV. Finally, for Part V, be prepared to describe your processes for vetting grantees, monitoring the use of funds, and ensuring compliance with U.S. laws.

Completing Schedule F Part-by-Part

General Information

Part I of Schedule F requires a summary of your organization’s activities outside the United States, organized by geographic region. For each region, you must report the number of offices, the number of employees and agents, the types of activities conducted, and the total expenditures.

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

Part II is a detailed table for reporting grants and other assistance provided to foreign organizations. In column (a), enter the legal name of each recipient. Use column (b) for the address and column (c) for its EIN, if applicable. The cash grant amount is entered in column (d), while column (e) is for describing non-cash assistance, with its fair market value in column (f). Column (g) requires the specific purpose of the grant.

Grants and Other Assistance to Individuals Outside the United States

Part III is structured to report assistance given directly to foreign individuals. Unlike Part II, this section does not require you to list each individual recipient by name; you report the information in aggregate for each region. In column (a), select the region, and in column (b), enter the total number of recipients. Column (c) is for listing the types of assistance, followed by the total cash amount in column (d) and a description and value of non-cash assistance in columns (e) and (f).

Foreign Investments

Part IV consists of a series of yes-or-no questions regarding foreign financial accounts. For each question, you must check the appropriate box. If you answer “Yes” to any of these questions, you may be required to file other specific forms with the IRS.

Other Information

Part V is a narrative section where you provide supplemental information to explain or clarify answers from other parts of Schedule F. For example, you would explain if you used a different method to allocate expenses than the one used for Form 990, Part IX. This section is also used to describe the organization’s grantmaking procedures, such as the due diligence performed on grantees.

Filing and Record-Keeping

Once completed, Schedule F must be attached to the organization’s Form 990. For organizations that file electronically, tax preparation software will automatically bundle the schedule with the main form as part of the complete return.

After filing, maintaining thorough records is a compliance practice. The organization should retain copies of the filed Form 990 and all its schedules. All documentation used to prepare the schedule must also be kept, including grant agreements, wire transfer receipts, and financial statements that substantiate the reported foreign activities. These records serve as the primary evidence to support the information on Schedule F in the event of an IRS examination.