Sample Questions - International Activities

 

Applications for exemption and miscellaneous determination requests are assigned to Exempt Organizations specialists for review. If additional information is necessary to make a determination, a specialist will contact the organization for the information. Here's a list of questions that might be asked on this topic.


1. Your application shows you [conduct activities, provide assistance or distribute funds or goods to individuals or other entities] outside the United States. Provide the following:

  • Identify the specific countries (and regions within the countries) in which you operate or plan to operate.
  • Describe your [activities/purpose for use of funds/goods/assistance] in each country.

2. Provide the following information about grants you will make to organizations or individuals located in foreign countries:

  • A list of the organizations to which you have (or will) distributed funds or goods. If the IRS has recognized them as tax-exempt, state their exempt status.
  • A list of the distributions (in funds or goods) you made to date. Include the recipient's names and the amount and type of distribution. Describe how the distributions furthered your exempt purposes.
  • An explanation of your process for reviewing and approving requests for funds or goods. Describe any pre- grant inquiries you conduct with respect to potential grantees. Include how you determine grant amounts.
  • Whether you enter into a written grant agreement with grantees. If so, send representative copies of the grant agreements.
  • Whether a grant recipient is eligible for repeated grants. If so, explain whether they must reapply and continue to provide information about how they use funds or goods.
  • Whether you accept donations earmarked for organizations or individuals.
  • A description of how you exercise control and responsibility over the use of any funds or goods you grant to foreign organizations or individuals (for example, requiring grantees to submit periodic reports, etc.).
  • Whether you share board members or key personnel with recipient organizations.
  • Provide any communications or materials you provide or will provide to donors/potential donors regarding your planned distributions.

Formed in Foreign Country

3. Your application shows that you were formed under the laws of a foreign country. Provide the following:

  • Why you applied for recognition of exemption
  • How you make donors aware that contributions to you are not tax deductible under IRC Section 170
  • Whether your stated investment income or unrelated business income comes from U.S. sources
  • Whether you had interactions in the U.S. or U.S. source income prior to your application date
  • Whether any of your income will be used to compensate domestic or international employees

Additional information

See the complete list of Applying for Exemption/Miscellaneous Determination Sample Questions by topic.