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Reporting Gifts from Foreign Sources

  • 1.  Reporting Gifts from Foreign Sources

    Posted 04-13-2019 10:22 AM
    Many years ago when I was at Duke I was made aware of an obscure IRS requirement for reporting gifts from a foreign source of $100,000 or more. I simply let my CFO know when this happened and he took it from there. Is anyone aware of whether such a requirement still exists for nonprofit organizations? And, if so, what IRS forms are required? I cannot find anything in my quick search of the IRS website. John John H. Taylor Principal, John H. Taylor Consulting 2604 Sevier St. Durham, NC 27705 johntaylorconsulting@gmail.com 919.816.5903 (cell/text) Serving the Advancement Community Since 1987


  • 2.  Re: Reporting Gifts from Foreign Sources

    Posted 04-14-2019 01:21 PM
    Thank you - I note that the old $100,000 reporting requirement has been bumped to $250,000! John Taylor 919.816.5903 johntaylorconsulting@gmail.com Big ideas; small keyboard > On Apr 14, 2019, at 1:56 PM, Jon Garrow


  • 3.  Re: Reporting Gifts from Foreign Sources

    Posted 04-14-2019 07:57 PM
    Section 117? This only applies to some higher ed organizations and I don't believe involves the IRS. https://studentaid.ed.gov/sa/about/data-center/school/foreign-gifts Jon W. Garrow Director of Prospect Development Office of Development Montefiore Health System Albert Einstein College of Medicine 718.430.2564 office jon.garrow@einstein.yu.edu ________________________________ From: Advancement Services Discussion List [FUNDSVCS@LISTSERV.FUNDSVCS.ORG] on behalf of John Taylor [johntaylorconsulting@GMAIL.COM] Sent: Saturday, April 13, 2019 11:22 To: FUNDSVCS@LISTSERV.FUNDSVCS.ORG Subject: [FUNDSVCS] Reporting Gifts from Foreign Sources Many years ago when I was at Duke I was made aware of an obscure IRS requirement for reporting gifts from a foreign source of $100,000 or more. I simply let my CFO know when this happened and he took it from there. Is anyone aware of whether such a requirement still exists for nonprofit organizations? And, if so, what IRS forms are required? I cannot find anything in my quick search of the IRS website. John John H. Taylor Principal, John H. Taylor Consulting 2604 Sevier St. Durham, NC 27705 johntaylorconsulting@gmail.com


  • 4.  RE: Reporting Gifts from Foreign Sources

    Posted 10-08-2019 08:59 AM
    I am meeting with our general counsel on this next week. As I understand from one of our GC, this reporting is required now regardless of dollar amount, the definition of "institution" is now to include affiliated entities, anonymous gifts are disallowed, and some bad consequences for willful non-compliance.

    I don't know the definition of "foreign source". I guess it could be an individual who lives outside the U.S., an organization located outside the US. A grantee located outside the US. A foreign country (wouldn't be a gift)? On the gift side we ran a report of all gifts in the past year where the donor's address is outside the US. Would that be sufficient from the Advancement Office?  

    I've been doing Advancement Services work since 2000 and have never submitted such a report to any government entity or to any office within any university I've worked at.

    Does anyone have any further info before I meet w/our GC?

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    Robert Saunders
    Assistant Vice Chancellor, Advancement Operations
    University of North Carolina at Greensboro
    robssaunders@gmail.com
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  • 5.  RE: Reporting Gifts from Foreign Sources

    Posted 10-08-2019 09:12 AM

    Yes, we do this every six months and use non-USA addresses as the parameter. For us, the threshold is $250K. Here is an article regarding that.

     

    https://www.insidehighered.com/news/2019/07/09/colleges-call-more-clarity-rules-requiring-disclosure-foreign-gifts-and-contracts

     

    Aaron

     

    Aaron Forrest CPA

    Senior Director Gift and Donor Services

    University of Rochester Office of Advancement

    Larry and Cindy Bloch Alumni and Advancement Center

    300 East River Road

    Rochester NY 14627

    Office 585.275.2799 / Fax 585-273-4558

    Email aaron.forrest@rochester.edu

     

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  • 6.  RE: Reporting Gifts from Foreign Sources

    Posted 10-08-2019 09:30 AM





  • 7.  RE: Reporting Gifts from Foreign Sources

    Posted 10-08-2019 09:42 AM

    Thank you for this. I will send to Legal.

     

    Aaron

     

    Aaron Forrest CPA

    Senior Director Gift and Donor Services

    University of Rochester Office of Advancement

    Larry and Cindy Bloch Alumni and Advancement Center

    300 East River Road

    Rochester NY 14627

    Office 585.275.2799 / Fax 585-273-4558

    Email aaron.forrest@rochester.edu

     

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  • 8.  RE: Reporting Gifts from Foreign Sources

    Posted 12-16-2019 01:09 PM
    Hi Aaron,

    Do you pull on all active non-US addresses or only home address? We have donors with active, primary US home addresses AND non-US secondary home addresses. We pulled them in our initial lists since they had an active non US address on their records. For extra precaution our team, consisting of General Accounting, Legal, Compliance and Risk assessment, has agreed to include them in our foreign gifts reporting. I am hesitant to include them as a foreign source but cannot verify their US citizenship with any certainty. Have you come across this and do you include all active addresses or only primary home addresses? 

    Iz

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    Izabel DeAraujo
    Assistant VP, Advancement Systems and Technology
    Drexel University
    idd23@drexel.edu
    ------------------------------