Equivalency determination is the process by which a US private foundation makes a good-faith determination that a foreign grantee is the equivalent of a US public charity, allowing the grant to be treated like a domestic one.
It is a documentation exercise, not a judgement call. The foundation assembles the grantee's governing documents, financial history and description of activities, and written advice from a qualified tax practitioner supports the conclusion.
It is a good-faith determination by a US private foundation, supported by documentation, that a foreign grantee is the equivalent of a US public charity — allowing the grant to be treated much like a domestic one.
The grantee's governing documents showing a charitable purpose and dedication of assets, a description of its actual activities, and financial data covering enough years to test the public support requirements. Written advice from a qualified tax practitioner supports the conclusion.
Equivalency determination is front-loaded work that then allows the grant to be treated like a domestic one. Expenditure responsibility is lighter at the outset but carries continuing obligations for the life of the grant, including grantee reports and disclosure.
No. It is a concept of US tax law, relevant to US private foundations granting internationally. Funders in other jurisdictions face their own cross-border verification requirements, which differ in substance and in documentation.
The newest terms we've added, the words teams managing grants, sponsorship, and CSR come across most often.
Post-award is the phase of the grant lifecycle that follows the funding decision: disbursing funds, tracking how they are spent, collecting grantee reports, measuring outcomes against the objectives set at the start, and closing the grant.
Post-award is where impact is either evidenced or lost. A funder whose attention stops at the payment has spent the money without being able to say what it produced.
Pre-award is the first phase of the grant lifecycle: publishing the call, receiving applications, checking eligibility, scoring and shortlisting — everything that happens before funds are committed.
Pre-award decides a funder's selectivity. How many ineligible applications reach human reviewers, and how consistently the eligible ones are scored, is settled in this phase and cannot be repaired in the next one.
Expenditure responsibility is the set of steps a US private foundation must take when it grants to an organisation that is not a public charity: a pre-grant inquiry, a written agreement restricting the use of funds, separate accounting by the grantee, reports on how the money was spent, and disclosure on the foundation's own return.
The obligation follows the money, not the recipient's good faith. Omitting a step is a compliance failure even where the funds achieved exactly what both parties intended.
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