Yesterday, September 14, 2017, the IRS released Revenue Procedure 2017-53, which international grantmakers and their tax advisors have eagerly awaited. As background, private foundations making grants directly to foreign organizations generally must use one of two grantmaking procedures―expenditure responsibility or foreign public charity equivalency. (The latter is known as “FPCE” for short, and also sometimes… Continue Reading
Treasury will release tomorrow final regulations regarding private foundations and their use of a process called “foreign public charity equivalence” or “equivalency determination.” Treasury’s hope in issuing these regulations is to facilitate international grantmaking while ensuring that foundation equivalency determinations are appropriately made. Background and 2012 proposed regulations. As explained in a prior post, before… Continue Reading
In the wake of new private foundation regulations, I had previously written about the concept of foreign public charity equivalence repositories. Our client TechSoup announced yesterday that their repository, built in collaboration with Council on Foundations, is now up and running. It is always exciting to see a client’s hard work come to fruition.
Private foundations making grants directly to foreign organizations generally must use one of two grantmaking procedures―expenditure responsibility or foreign public charity equivalency (“FPCE” for short). In FPCE, a grantor makes a good faith determination, based on an affidavit of the grantee or on an opinion of counsel, that the foreign charity meets the basic 501(c)(3) public… Continue Reading
The Department of the Treasury and the IRS have just released proposed regulations for private foundations. Here’s a look at what they say. Expanding class of tax practitioners on whose opinions private foundations can rely for foreign public charity equivalency. Currently, private foundations wishing to make grants to non-U.S. charities generally have to exercise expenditure responsibility… Continue Reading