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Rules Governing Practice before IRS

Exempt Organizations Annual Reporting Requirements - Foreign Activities (Form 990 Schedule F): Reporting Foreign Investments in Part I

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

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.
  • 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.
    • 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.
    • The organization may use the term investments to describe the foreign activity in column (d).
    • The book value of foreign investments in each particular region would be reported in Part I, column (f) for that region.
    • 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.

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