The Redesigned Form 990, which goes into effect for tax years ending after December 31, 2008, contains a new Schedule F, Statement of Activities Outside the United States. Schedule F, Part I, General Information on Activities Outside the United States, must be completed by organizations that have had aggregate revenues or expenses of more than $10,000 from grantmaking, fundraising, business, and program service activities outside the United States. Part II requires a disclosure of grants or other assistance to organizations or entities outside the United States if over $5,000. Part III requires a disclosure of grants or other assistance to individuals outside the United States if over $5,000. Part IV requires the organization to describe its procedures for monitoring the use of grant funds outside of the United States.
The requirement of disclosing foreign recipients of grants posed concerns of the safety of recipients involved in furthering a U.S. charity’s mission, particularly in areas that are dangerous or hostile to Americans and those who work with American organizations or in furtherance of American interests. The IRS explained that it cannot redact or withhold from public disclosure such information without legislative authority. As a concession, in the 2008 Form, the IRS will require reporting on a regional (rather than on a country by country) basis and not require the identification of individual grantee organizations.