How can we assure our lawyers and auditors that EDs issued by NGOsource can be relied upon?


Premier tax law firm Caplin & Drysdale has written a legal opinion stating that grantmakers can fully rely on NGOsource equivalency determinations to meet their IRS requirements for international grants. The legal opinion is available to grantmakers upon request and pursuant to a nondisclosure agreement. To request a copy, please contact

In September 2015, the U.S. Department of the Treasury and Internal Revenue Service issued final rules on equivalency determinations (EDs). These rules finalize the proposed regulations first issued in September 2012, upon which experts have been relying in the interim. The final regulations further strengthen grantmakers’ ability to confidently rely on EDs provided through our repository because they strongly affirm the unique approach that NGOsource has taken to provide ED repository services from the time we launched. Specifically, the regulations reinforce NGOsource’s decision to staff our ED repository with qualified tax practitioners (QTPs), i.e., the attorneys in charge of our legal review process.