Revenue Procedure 2017-53 (Rev. Proc. 2017-53) was issued by the IRS on September 14, 2017. It updates and modifies 1992 IRS guidance (Rev. Proc. 92-94) with respect to foreign public charity equivalency determinations (“EDs”). Similar to the Treasury Regulations issued in late 2015, the new Revenue Procedure largely confirms NGOsource’s current practices in preparing and issuing EDs for grantmakers. In addition, Rev. Proc. 2017-53 suggests several “preferred” practices in issuing EDs.
NGOsource’s EDs remain fully compliant with the law, and generally reflect best practices in the field; nonetheless we are currently considering whether we should make any changes as a result of Rev. Proc. 2017-53. Our goal continues to be to provide a process that meets relevant legal standards in a way that is efficient for grantmakers and accessible for their grantees. We will keep our members apprised of any relevant changes to our process.
In the meantime, please don’t hesitate to let us know if you have questions or suggestions of your own. For an excellent summary of the new Revenue Procedure, we encourage you to read the following article published by Adler & Colvin: IRS Releases Revenue Procedure 2017-53 on Foreign Public Charity Equivalence Determinations.
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