Exempt Organizations Annual Reporting Requirements - Foreign Activities: Payments to U.S. Citizens Living Abroad


Should payments to U.S. citizens living abroad be reported in Part III of Schedule F, Form 990?  If so, do we need to list the names of recipients?

Such payments must be reported in Part III if (1) the organization exceeds the $5,000 threshold, (2) the payment is a grant and not compensation and (3) the recipient was living outside the United States at the time the organization distributed the grant(s) to the person. The organization must report each type of grant or assistance in Part III, but to protect the confidentiality of individuals, should not report the names of individual persons who are grant recipients.