Form 990 Schedule F Instructions: Parts, Deadlines, and Penalties

If your tax-exempt organization spent money, made grants, held investments, or ran programs outside the United States, the Form 990 Schedule F instructions require you to disclose those activities across five parts covering general foreign activity by region, grants to foreign organizations, grants to foreign individuals, governance and related filings, and supplemental narrative explanations. The schedule attaches to a full Form 990 whenever certain dollar thresholds are crossed, and each part has its own trigger.¹

Who Has to File Schedule F

Schedule F is only for full Form 990 filers. Organizations filing Form 990-EZ report foreign activities within the program service accomplishments section of that shorter return instead.² Form 990-N (e-Postcard) filers have no foreign activity reporting obligation.

Whether you must attach Schedule F, and which parts you complete, depends on the thresholds you crossed during the tax year:³

Part I is required if aggregate revenues or expenses from grantmaking, fundraising, business, investment, or program services outside the U.S. exceeded $10,000, or if foreign investments had an aggregate book value of $100,000 or more at any point during the year.
Part II is required if the organization gave more than $5,000 to any single foreign organization or foreign government, or to a domestic organization or individual acting as a conduit to a designated foreign recipient.⁴
Part III is required if aggregate grants or assistance to foreign individuals exceeded $5,000.¹

The pass-through rule in Part II catches organizations that assume they’re off the hook because their check was written to a U.S. entity. If a $6,000 grant to a domestic intermediary was earmarked for a foreign partner, Part II still applies. The IRS follows the money to its ultimate destination.⁴

Part I: Activities Outside the United States by Region

Part I captures the organization’s international footprint beyond grantmaking. For each type of activity conducted abroad, you report by geographic region rather than by country, along with the total expenditures, the number of offices maintained, and the number of employees, agents, or independent contractors working in the region.⁵

Organizations triggered into filing by the $100,000 investment threshold also report investment book values by region. Expenditures go to the nearest dollar. The accounting method you used should be described in Part V.

The Ten IRS Reporting Regions

You cannot report by country. Everything slots into one of ten regions:³

Antarctica
Central America and the Caribbean
East Asia and the Pacific (includes China, Japan, Australia, and Pacific Island nations)
Europe (including Iceland and Greenland; includes Turkey and the United Kingdom)
Middle East and North Africa (includes Israel, Egypt, and the Gulf states)
North America (Canada and Mexico only)
Russia and Neighboring States (includes Ukraine, Georgia, Kazakhstan, and other former Soviet states)
South America
South Asia (includes India, Pakistan, Afghanistan, and Bangladesh)
Sub-Saharan Africa

Border-area coding is a common error. Turkey is Europe, not Middle East. Afghanistan is South Asia, not Middle East. If your work spans a regional boundary, check the country-by-region list in the instructions before filing.

Parts II and III: Foreign Grants and Assistance

Part II — Grants to Foreign Organizations

For each foreign recipient that received more than $5,000, Part II asks for the recipient’s name, region, purpose of the grant, and total cash and non-cash amounts. Cash grants require you to identify the disbursement method, such as wire transfer or check. Non-cash assistance requires a description and a fair market value.³

Part II also asks whether you used an equivalency determination or exercised expenditure responsibility for each grantee. These are the two accepted compliance approaches for foreign grantmaking, and the schedule expects you to identify which one you relied on.

Part III — Grants to Foreign Individuals

Grants to foreign individuals are reported in aggregate, not name by name. You report the type of assistance (scholarships, medical aid, emergency relief), the region, the number of recipients, and the total cash and non-cash amounts. Individual names and addresses are not required. Describe the accounting method used to value non-cash assistance in Part V, and be prepared to explain in Part V how you estimated the recipient count.³

Equivalency Determinations vs. Expenditure Responsibility

Foreign grantees don’t have IRS determination letters, so U.S. organizations use one of two approaches to demonstrate that grant funds serve a charitable purpose.

An equivalency determination is a documented, good-faith conclusion that the foreign grantee would qualify as a Section 501(c)(3) public charity if it were a U.S. organization. The strongest support is written advice from a qualified tax practitioner (attorney, CPA, or enrolled agent) subject to Circular 230 standards. That advice is treated as current for up to two years depending on when in the grantee’s tax year it was prepared, and reliance on stale advice or on advice given without full disclosure of the facts fails the good-faith standard.⁶

Expenditure responsibility is the hands-on alternative. It requires four elements:⁷

A pre-grant inquiry into the grantee’s identity, history, management, and practices sufficient for a reasonable person to conclude the funds will be used properly.
A written agreement in which the grantee commits to use the funds only for the grant’s stated purpose, return any unused portion, submit annual reports, maintain accessible books and records, and refrain from lobbying, electioneering, or improper re-granting.
Separate accounting for the grant funds, though not necessarily a segregated bank account.
Annual reports from the grantee on how funds were used and progress toward the grant’s purpose.

These rules originate in the private foundation excise tax regulations, but public charities routinely follow the same framework for foreign grants and must disclose their approach on Schedule F.

Part IV: Governance, Oversight, and Related Filings

Part IV moves from what you did to how you controlled it. You describe your procedures for monitoring the use of foreign grants, disclose whether you maintain bank accounts outside the U.S., and describe your record-keeping for foreign transactions.

Part IV also asks whether the organization was required to file other IRS forms tied to foreign activity. The most common are:

Form 926, required when a U.S. person transfers property to a foreign corporation and either holds at least 10% of its voting power or value after the transfer, or transfers more than $100,000 in cash to it within a 12-month period.⁸
Form 5471, required for U.S. persons owning 10% or more of the voting power or value of a foreign corporation, with multiple filing categories.⁹
Form 3520, for transactions with foreign trusts and receipt of certain large gifts from foreign persons.

Answering “yes” is not itself a red flag; it confirms you’re meeting separate obligations. Answering “no” when the correct answer is “yes” creates compounding problems.

OFAC Screening

Organizations making foreign grants are expected to screen recipients against the Treasury Department’s Specially Designated Nationals list maintained by the Office of Foreign Assets Control. Executive Order 13224 prohibits U.S. persons from any transaction with designated terrorists and terrorist organizations, including contributions of funds, goods, or services benefiting blocked persons, subsidiaries, front organizations, or associates.¹⁰ Schedule F doesn’t ask the screening question outright, but skipping it creates legal exposure well beyond the schedule.

FBAR

If your organization holds foreign financial accounts whose aggregate value exceeded $10,000 at any point during the calendar year, file FinCEN Form 114 (the FBAR).¹¹ The FBAR goes to FinCEN, not the IRS, and is separate from Form 990. It’s due April 15 with an automatic extension to October 15 that requires no paperwork.¹²

Part V: Supplemental Information

Part V is the narrative section that fills gaps left elsewhere on the schedule. The instructions expect you to cover, at minimum:³

Your monitoring procedures for grants and assistance outside the U.S. (referenced from Part I, line 2).
The accounting method used for expenditures, cash grants, and non-cash assistance (referenced across Parts I, II, and III).
How you estimated the number of recipients reported in Part III.

Identify which part and line each narrative response supports. Terse answers elsewhere can be expanded here, and this is where the IRS expects you to show your work.

Deadlines and Extensions

Schedule F rides on the Form 990 deadline: the 15th day of the 5th month after the tax year ends. Calendar-year filers are due May 15.¹³ Form 8868 gives an automatic six-month extension (November 15 for calendar-year filers). No explanation is needed, and no approval is issued. Extending the filing deadline does not extend any time to pay tax owed.¹⁴

Penalties for Late or Incomplete Filing

Schedule F has no separate penalty. An incomplete Schedule F makes the entire Form 990 incomplete, and the daily penalties for a late or incomplete Form 990 apply.

The base statutory penalty is $20 per day, capped at the lesser of $10,000 or 5% of gross receipts, for most organizations. Organizations with gross receipts above $1,000,000 face $100 per day up to $50,000.¹⁵ Those base amounts are adjusted for inflation each year, so actual penalties run somewhat higher than the statutory figures.

To request abatement, attach a written statement to the Form 990, signed under penalties of perjury, explaining why the return was late or incomplete, what prevented the organization from requesting an extension, how it exercised ordinary business care despite the failure, and what steps have been taken to prevent recurrence.¹⁶ The IRS reviews these case by case, and vague explanations rarely succeed. You need to show circumstances genuinely beyond the organization’s control.

1
Internal Revenue Service. Exempt Organizations Annual Reporting Requirements – Foreign Activities (Form 990, Schedule F)
2
Internal Revenue Service. Form 990-EZ Reporting Requirements for Foreign Activities
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Internal Revenue Service. Instructions for Schedule F (Form 990) – Statement of Activities Outside the United States
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Internal Revenue Service. Instructions for Schedule F (Form 990) (12/2024)
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Internal Revenue Service. Exempt Organizations Annual Reporting Requirements (Activities Reported)
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Internal Revenue Service. Revenue Procedure 2017-53
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eCFR. 26 CFR 53.4945-5 – Grants to Organizations
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Internal Revenue Service. Form 926 – Filing Requirement for U.S. Transferors of Property to a Foreign Corporation
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Internal Revenue Service. Instructions for Form 5471 (12/2025)
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U.S. Department of State. Executive Order 13224
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Financial Crimes Enforcement Network. Report Foreign Bank and Financial Accounts
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Internal Revenue Service. Report of Foreign Bank and Financial Accounts (FBAR)
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Internal Revenue Service. Exempt Organization Filing Requirements – Form 990 Due Date
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Internal Revenue Service. Extension of Time to File Exempt Organization Returns
15
Office of the Law Revision Counsel. 26 USC 6652 – Failure to File Certain Information Returns
16
Internal Revenue Service. Abatement of Late Filing Penalties