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Form 990 Schedule F: Reporting Foreign Activities, Grants and Bank Accounts
Last updated: October 12, 2026 · Independent guide · We do not sell rankings or coverage.
Form 990 Schedule F is the schedule a Form 990 filer attaches to report activities, grants and investments outside the United States. You must complete it if you answer “Yes” on Form 990, Part IV, line 14b (more than $10,000 of foreign revenues or expenses, or $100,000 or more of foreign investments), line 15 (more than $5,000 of grants to or for a foreign organization) or line 16 (more than $5,000 of aggregate grants to foreign individuals). Because it reports by region rather than country, your ledger needs a region and activity tag on every foreign transaction.
The rule in brief
- Who: Form 990 filers that answer “Yes” on Part IV, line 14b, 15 or 16. Form 990-EZ and 990-N filers do not file it.
- Thresholds: Part I above $10,000 of foreign revenues or expenses, or $100,000 or more of foreign investments; Part II above $5,000 to any one foreign organization; Part III above $5,000 in total to foreign individuals.
- Dates: due with Form 990 on the 15th day of the 5th month after year end, extendable on Form 8868. A related FBAR is due April 15, with an automatic extension to October 15.
- Source: IRS Instructions for Schedule F (Form 990), revised December 2024. We checked the rule on October 12, 2026.
What triggers Schedule F
Form 990, Part IV, line 14b asks whether you had “aggregate revenues or expenses of more than $10,000 from grantmaking, fundraising, business, investment, and program service activities outside the United States, or aggregate foreign investments valued at $100,000 or more” (IRS Form 990 (2025), no date shown). Lines 15 and 16 ask about more than $5,000 of grants reported in Part IX, line 3 to or for a foreign organization, and to foreign individuals in aggregate. Line 14a (offices or staff abroad) does not trigger the schedule by itself.
The IRS defines the United States as the 50 states, the District of Columbia, Puerto Rico, the Northern Mariana Islands, Guam, American Samoa and the U.S. Virgin Islands. “Grants and other assistance” includes payments to a U.S. person to pass on to designated foreign beneficiaries, but excludes employee pay, contractor payments and payments to a foreign branch that is not a separate legal entity (IRS Schedule F instructions, page last reviewed April 30, 2026).
What each part requires
Part I: activities outside the United States by region
Lines 1 and 2 apply if you made foreign grants. They ask whether you keep records that substantiate grant amounts, eligibility and selection criteria, and how you monitor the use of funds, with the narrative in Part V. Line 3 is the regional table: region, number of offices, number of employees, agents and contractors (volunteers excluded), activity type, program service description, and total expenditures and investments. You “list each type of activity on a separate line and repeat regions in column (a) as necessary,” and amounts may be rounded to the nearest $1,000.
The seven activity types are grantmaking, fundraising, unrelated business, program services, investments, program-related investments, and board meetings or conferences. Expenditures include regional salaries, travel, office costs, grants, bank fees and agent payments, on your financial-statement method. The instructions say that, for 2023, indirect costs need not be allocated to foreign activities if you do not separately track them. Investments use only columns (a), (d) and (f), take the region of the investee’s legal domicile, and exclude holdings through a U.S. pass-through entity or in foreign entities traded on a U.S. exchange.
Part II: grants to foreign organizations and governments
List each recipient that received more than $5,000 in the year on its own line. The instructions say “Don’t complete Part II, line 1, column (a) or (b),” so names and EINs stay off the form, but you complete region, purpose, cash amount in U.S. dollars, disbursement method, noncash amount, description and valuation method. Region is where the recipient’s principal foreign office sits, or where funds were used. Purpose must be specific; “charitable” is not enough. Line 2 counts recipients that are 501(c)(3)-recognized, recognized as charities by a foreign country or covered by a good-faith equivalency determination, and line 3 counts the rest.
Part III: grants to foreign individuals
Part III aggregates assistance to individuals by type and region, with the number of recipients, cash and noncash amounts, disbursement method and valuation. Earmarked help for a named person, such as a hospital payment for a specific patient, goes here; general aid routed through a foreign organization goes in Part II. Counts may be estimated with a Part V explanation.
Part IV: foreign forms questions
Every Schedule F filer answers lines 1 to 6 (IRS Schedule F (Form 990), Rev. December 2024). A “Yes” means you may need to file the related form.
| Line | Question | Form that may be required |
|---|---|---|
| 1 | U.S. transferor of property to a foreign corporation | Form 926 |
| 2 | Interest in a foreign trust | Form 3520 and/or 3520-A (filed separately) |
| 3 | Ownership interest in a foreign corporation | Form 5471 |
| 4 | Shareholder of a passive foreign investment company or qualified electing fund | Form 8621 |
| 5 | Ownership interest in a foreign partnership | Form 8865 |
| 6 | Operations in or related to boycotting countries | Form 5713 (filed separately) |
Form 926 applies to a cash transfer to a foreign corporation if you hold at least 10% of its vote or value afterward, or if your cash transfers in the preceding 12 months exceed $100,000; it is filed with the exempt organization return (IRS Form 926 instructions, revised November 2018). Form 5471 covers, among other categories, crossing 10% ownership of a foreign corporation and controlling one through more than 50% of vote or value (IRS Form 5471 instructions, revised December 2025).
FBAR is a separate Form 990 question
Schedule F does not ask about bank accounts. Form 990, Part V, line 4a asks whether you had an interest in or signature authority over a foreign financial account during the calendar year. If the aggregate value exceeded $10,000 at any time, you file FinCEN Form 114 through the BSA E-Filing System, not with the return (IRS FBAR page, last reviewed July 30, 2026).
The ten regions in the instructions
You report the region, never the country. The instructions list ten regions with example countries; for an unlisted country you choose the appropriate region.
| Region | Examples from the IRS list |
|---|---|
| Antarctica | No countries listed |
| Central America and the Caribbean | Cuba, Haiti, Jamaica, British Virgin Islands |
| East Asia and the Pacific | China (including Hong Kong), Taiwan, Japan, Korea, Australia |
| Europe (including Iceland and Greenland) | Turkey, United Kingdom, Greenland |
| Middle East and North Africa | Israel, West Bank and Gaza |
| North America | Canada and Mexico, but not the United States |
| Russia and Neighboring States | Russia, Ukraine |
| South America | Listed in the IRS instructions |
| South Asia | India, Pakistan |
| Sub-Saharan Africa | South Africa, Nigeria |
Note that Mexico is in North America and Turkey is in Europe. Load the full IRS country list into your system once so nobody assigns regions from memory.
Who is exempt
The instructions describe Schedule F as a schedule for organizations that file Form 990, so Form 990-EZ and 990-N filers do not complete it, and private foundations report on Form 990-PF. A Form 990 filer below all three thresholds answers “No” on lines 14b, 15 and 16. These are “more than” tests, so exactly $10,000 of foreign expenses does not trigger Part I. Branch costs are not Part II grants, but they still count as your own Part I expenditures.
Deadlines and penalties
Schedule F is due with Form 990. The FBAR follows the calendar year whatever your fiscal year. Omitting a required schedule makes the return incomplete: the 2025 instructions set $25 a day, up to the lesser of $13,000 or 5% of gross receipts, for “failing to complete a required line item or a required part of a schedule,” and $130 a day, up to $65,000, above $1,309,500 of gross receipts (IRS Instructions for Form 990 (2025), no date shown). A missed Form 926 costs 10% of the property’s value, capped at $100,000 unless intentional (IRS Form 926 instructions), and a missed Form 5471 costs $10,000 per foreign corporation per year (IRS Form 5471 instructions).
Records you must keep
For each foreign grant, keep the approval, agreement, payment record with exchange rate, grantee reports, equivalency or charity-status evidence and noncash valuation support. The Form 990 instructions call for supporting records to be kept at least three years from the later of the filing or due date. FBAR records (account number, bank name and address, account type, maximum value) are kept for five years from the FBAR due date, according to the IRS FBAR page.
What to set up in your systems
Tag every foreign transaction line with a Schedule F region and activity type, and every payee record with its type and charity status. Grant purpose, disbursement method and valuation usually live in the grant management system.
Sage Intacct. Intacct’s user-defined dimensions “become available throughout the company wherever dimensions are displayed,” and dimension relationships can autofill a region from a customer (Sage Intacct Help, last modified October 8, 2026). Additional fees can apply, and a dimension cannot be deactivated once used, so settle the value list first. See our Sage Intacct for nonprofits page.
Blackbaud Financial Edge NXT. Transaction codes are set up under Settings, General ledger, GL setup, Transaction codes. You get up to five, and each fund can require a code on income statement accounts or every account (Blackbaud help, modified October 8, 2026). Region and activity type would use two of the five.
MIP Fund Accounting. MIP supports non-balancing segments that track revenues and expenditures without requiring each code to balance (MIP documentation, no date shown). That suits region, since Schedule F reports spending, not regional balance sheets.
Fluxx and Foundant GLM. Tech Impact, an independent nonprofit, reports that Fluxx supports custom fields and CSV or Excel exports, and that it charges extra for finance integrations and multi-currency (Tech Impact, July 15, 2024). It reports that Foundant GLM allows custom codes and Excel or API exports but lacks multi-currency in GLM itself (Tech Impact, July 15, 2024). Fluxx’s BILL integration supports chart of account, department and location mapping from Fluxx to BILL (Fluxx, 2025). Foundant’s QuickBooks Online integration is a paid add-on, and Foundant says the systems do not sync automatically when amounts change (Foundant, July 17, 2026). Our grant management software guide compares options.
An illustration (hypothetical figures). A charity spends $180,000 on a clinic in Kenya, grants $40,000 to a Guatemalan partner and pays four $1,500 scholarships in India. Part I shows Sub-Saharan Africa program services and Central America and the Caribbean grantmaking, Part II lists the partner, and the $6,000 of scholarships puts one South Asia line in Part III. For currency setup, see our international nonprofit software guide.
How we researched this
We read the IRS Schedule F instructions and form, the 2025 Form 990 and its instructions, the Form 926 and 5471 instructions and the IRS FBAR page on October 12, 2026. Software details come from vendor documentation and Tech Impact’s independent guide. The top search results are mostly e-file vendor pages, so we added the region list, the FBAR question, Part IV thresholds and ledger setup.
Related guides
- Form 990 Schedule R: Related Organizations Guide
- Form 990 Schedule O: Required Lines and Sample Wording
- Form 990 Preparation Software: From Ledger to E-File
Frequently asked questions
Do I have to file Schedule F if we only have a foreign bank account?
Not on that basis alone. A foreign bank account is reported on Form 990, Part V, line 4a, and may require an FBAR if the aggregate value exceeded $10,000. Schedule F is required only if you also meet a line 14b, 15 or 16 threshold, for example through program spending from that account.
Does a grant to a U.S. charity that works overseas count?
Generally it is a grant to a domestic organization and does not go on Schedule F. It becomes a foreign grant for Schedule F when you pay a U.S. person to provide grants to designated foreign beneficiaries, which the instructions treat as grants and other assistance outside the United States.
How do I report exchange rates on Schedule F?
The instructions require U.S. dollars but give no exchange-rate rule. Use the rate your financial statements apply and describe your method in Part V. For the FBAR, FinCEN points to Treasury’s reporting rates of exchange (FinCEN, no date shown).
What happens if we leave Schedule F off the return?
The IRS treats a missing required schedule as an incomplete return, with penalties of $25 a day up to the lesser of $13,000 or 5% of gross receipts, or $130 a day up to $65,000 above $1,309,500 of gross receipts.
Sources
- IRS, Instructions for Schedule F (Form 990), revised December 2024, page last reviewed April 30, 2026
- IRS, Schedule F (Form 990), Rev. December 2024
- IRS, Form 990 (2025), no date shown
- IRS, Instructions for Form 990 (2025), no date shown
- IRS, Instructions for Form 926, revised November 2018, page last reviewed April 30, 2026
- IRS, Instructions for Form 5471, revised December 2025
- IRS, Report of Foreign Bank and Financial Accounts (FBAR), last reviewed July 30, 2026
- FinCEN, Report Foreign Bank and Financial Accounts, no date shown
- Sage Intacct Help, Dimensions overview, last modified October 8, 2026 (vendor)
- Blackbaud, Financial Edge help, Transaction Codes, modified October 8, 2026 (vendor)
- MIP Fund Accounting documentation, Account Segments Panel, no date shown (vendor)
- Tech Impact, Fluxx Grantmaker system profile, last modified July 15, 2024
- Tech Impact, Foundant Grant Lifecycle Manager system profile, last modified July 15, 2024
- Fluxx, BILL Integration, 2025 (vendor)
- Foundant Help Center, QuickBooks Online Integration, updated July 17, 2026 (vendor)
Sherman Hsieh
Independent analysis of enterprise software — ERP, CRM and more
