How should foreign investments be reported in Part I of Schedule F, Form 990?

For 2008 and 2009 tax years, the following rules apply.

• Investments must be reported on a region-by-region basis on Line 3, separately from other activities in the region.
• All investments in a particular region may be aggregated for this purpose. For example, all investments in South America may be reported together in one line.
• The organization may use the term investments to describe the foreign activity in column (d).
• In reporting investments in a region, only columns (a) and (d) must be completed; columns (b), (c), (e) or (f) need not be completed with respect to investments for these tax years.
  • Column (a) would reflect the region, as described in the instructions to Schedule F, of the investment.
  • The region of a foreign investment entity is determined by its legal domicile (country whose law governs the entity’s internal affairs).
  • In the case of a foreign pass-through entity such as a foreign partnership, an organization is not required to report the region of the underlying investments held by the pass-through entity, but may report the region based on the legal domicile of the foreign pass-through entity. 
  • An organization need not report, as an investment activity in Schedule F, foreign investments indirectly held through a domestic (United States) pass-through entity, because the domicile of the pass-through entity is not a foreign location.

For 2010 tax years, the same rules apply, modified as follows:

• In reporting investments in a region, only columns (a), (d) and (f) must be completed; columns (b), (c) and (e) need not be completed with respect to investments for these tax years.
• The book value of foreign investments in each particular region would be reported in Part I, column (f) for that region.