What Should a UK Charity's Website Show US Donors and Funders?
Key takeaways
- IRS Publication 526 lists foreign organisations, other than certain Canadian, Israeli or Mexican charities, among those to which US donors' contributions are not deductible.
- When a US private foundation grants to a foreign organisation without IRS recognition, the IRS describes two routes: an equivalency determination prepared by a qualified tax practitioner, or expenditure responsibility exercised by the foundation.
- The IRS guidelines for an equivalency determination, Revenue Procedure 2017-53, rest on the grantee's governing document, charitable purposes, activities, financial data and affiliated organisations, all of which a charity website can make findable.
- A US 501(c)(3) affiliate carries its own IRS disclosure duties, so its returns belong on its own website and the UK site links to them rather than hosting copies.
- Publication 526 says a contribution earmarked to go to a foreign organisation is not deductible, so how either site describes where a US gift goes is a question for the affiliate's tax adviser.
- The UK site and the affiliate's site should describe their relationship in the same words and name, by legal name, the organisation that receives a US gift.
Summary
A UK charity with American supporters deals with two kinds of US organisation, and its website has to keep them apart. A US private foundation that grants to the charity runs its own review, and the IRS guidelines for that review rest on documents a charity website already publishes: the governing document, the accounts and a description of the work. A US donor who wants a deduction generally gives to a US organisation, such as the charity's own affiliate, which carries its own disclosure duties and publishes them on its own site. This post sets out what the UK site should make findable for each and how it should say which organisation receives a US gift.
The Short Answer
Show each US reader the organisation they are actually dealing with. A US private foundation granting to your charity runs its own review of you, and that review reads the documents you already publish: the governing document, the accounts and a description of your work. A US donor who wants a tax deduction generally gives to a US organisation, not to you. If you have a US affiliate, your site names it, says how the two are related and links to its own site for its tax disclosures.
Most "US donors" pages explain how to give from America. Few say to whom.
The NGO website section checklist carries three rows for this, listed at the end.
Two Organisations, Two Questions
A UK charity with American supporters usually meets two kinds of US organisation. One is the grantmaker, a private foundation deciding whether it can fund you. The other, where one exists, is your own US affiliate: a separate organisation with its own board of directors, raising money from American donors and granting it on.
They ask your website different questions. The foundation asks whether your charity is what it says it is. The donor asks which organisation receives the gift and issues the receipt. One page can answer both only if it keeps the two organisations apart.
What a US Foundation's Review Reads
The IRS sets out four common scenarios when a private foundation grants to a foreign organisation. For a UK charity with no IRS recognition of its own, two of them keep the grant from being treated as a taxable expenditure. The foundation can make a "good faith determination" that you qualify as a public charity, known as an equivalency determination, prepared by a qualified tax practitioner (an attorney, CPA or enrolled agent). Or it can exercise expenditure responsibility: making sure the grant is spent only for its purpose, obtaining full reports from you on how the money was spent and reporting to the IRS itself.
Which route a foundation takes is its decision, made with its own advisers. Your website does not choose it. What the website can do is make the facts behind either route easy to find, and keep them consistent with what you send.
The IRS guidelines for the practitioner's written advice, Revenue Procedure 2017-53, list what that advice usually covers. Five of those facts are things a charity website already publishes, or should:
- The governing document by which the charity is formed and governed. Publish the current version, as amended, not a summary of it.
- Charitable purposes. Your objects, in the same words as the governing document and the register, belong on the About page.
- Activities, past, current and anticipated, with sources of receipts and types of expenditure. Programme pages that match the accounts show this in public.
- Finances, from the most recent completed year where a financial test applies. That means your latest filed accounts, dated, with earlier years kept.
- Affiliated organisations that control the charity or are operated in connection with it. A US affiliate or an overseas parent may be one, and the site should state the relationship.
The revenue procedure also lets the practitioner rely on an affidavit from the charity, attested by an officer or trustee with personal knowledge of the facts. A trustee signing a statement about your activities should be able to point to a website that says the same thing.
Take a hypothetical case. A practitioner's memo describes your work from an affidavit a trustee signed in March. The foundation's programme officer then opens your site and finds a programme that closed last year still presented as current, and accounts two years out of date. Nothing in the memo is false. The website has given the reader a reason to ask.
Expenditure responsibility asks less of the website. Its reports go to the foundation, not the public. A programme officer can still check that the programme the grant funds is on your site, described as the grant agreement describes it.
None of this is new work for a charity with a sound governance section. The checks a UK funder runs are in what grant funders check, and the UK publishing duties in Charity Commission website requirements. A US review reads the same documents for a different purpose.
What the US Affiliate Owes
A US affiliate recognised under section 501(c)(3) is a US tax-exempt organisation, and the IRS disclosure rules apply to it, not to you. It must make its annual returns and its exemption application available for public inspection, and posting them online removes the duty to supply copies, though not in-person inspection (IRS). What that means for the affiliate's own site, including why its status and EIN belong there, is set out in what a 501(c)(3) should show online.
For the UK site the consequence is structural. The affiliate's disclosures live on the affiliate's website, kept current by the affiliate. Your site links to them. It does not host copies of another organisation's returns, which go stale the day the affiliate files its next one.
The relationship needs one sentence, in the same words on both sites: what the affiliate is, that it is a separate organisation with its own board of directors and what it does for your charity. How closely the two are tied varies by structure. Presenting that relationship is covered in federated website governance and, for a fundraising body set up beside an operating charity, in the independent foundation challenge.
Which Organisation Receives the Gift
IRS Publication 526 lists foreign organisations, other than certain Canadian, Israeli or Mexican charities, among those to which contributions are not deductible. That is a rule about the donor's tax return, not a publishing duty on you. It still decides what your page for US supporters has to make plain.
The same publication goes further. A contribution to a qualifying US organisation is not deductible if it is earmarked to go to a foreign organisation. A gift for a programme run by a foreign charity may be deductible where the US organisation approves the programme as furthering its own purposes and keeps control over the funds. A line such as "US donors: your gift comes straight to us" sits uncomfortably beside that rule. How the affiliate's donation pages describe where money goes is a question for the affiliate's tax adviser, and both sites should use the wording that adviser approves.
The National Trust shows the plain version. Its page for US residents calls the Royal Oak Foundation "our US membership affiliate" and says its members "receive tax deductions for their support and help the organisation make grants towards our work". The donor gives to the affiliate, and the affiliate makes grants. The Royal Oak Foundation's FAQ describes it as a US tax-exempt 501(c)(3), and its financial information page lists Forms 990 labelled 2023, 2024 and 2025. I loaded all three pages on 30 September 2026 and have not assessed either organisation's arrangements; the pages show the pattern.
Where there is no US route, the page says so. A gift made through your site goes to a UK charity, named by its legal name, and US taxpayers are pointed to their own adviser before they give. The page can also say that other routes for US gifts exist and that the donor's adviser can explain them, without naming any. Which route suits a donor is a tax question, and naming one is a recommendation.
One Page, One Owner
Put it together as one page for US supporters, reachable from the donate page and from any page written for funders. It carries:
- The recipient. Which organisation receives a US gift, by legal name, and whether it is your charity or a separate one.
- The affiliate. Its legal name, the relationship sentence and links to its site and its disclosures.
- The documents. Links to your governing document, your latest accounts, your register entry and your programme pages, with a named contact for grantmakers.
The UK page is owned by the UK charity. The affiliate's pages are owned by the affiliate and answer to its board of directors. The page needs checking whenever either organisation files new accounts or returns, amends its governing document or changes the relationship, because each of those events breaks a link or a sentence somewhere.
A US foundation and a US donor arrive with different questions, and both need the same thing first: the name of the organisation in front of them. Get the names and the relationship right and most of the rest is linking to documents you already have. The documents are rarely the problem. The names are.
Further Reading
- NGO Website Section Checklist: row 9, Ways to give
- NGO Website Section Checklist: row 21, US funder information
- NGO Website Section Checklist: row 90, US disclosures
- Why a 501(c)(3) Should Show Its Status and EIN Online
- What Grant Funders Check on a Charity Website
- Charity Commission Website Requirements
- Federated Governance: Website Architecture for Multi-Affiliate Nonprofits
- Foundation Governance
What This Post Does Not Cover
This is about the website: what it makes findable for each organisation and who keeps it current. It is not tax or legal advice. Whether a gift is deductible, which route a foundation takes and how an affiliate is structured are questions for your advisers, the affiliate's and the donor's own. The IRS process is described only as far as the IRS's own pages describe it. Three things are not covered here: grants from US public charities (donor-advised fund sponsors among them), the position of dual US and UK taxpayers and US state solicitation rules.
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Frequently asked questions
- Can a US donor deduct a gift made directly to a UK charity?
Generally not. IRS Publication 526 lists foreign organisations, other than certain Canadian, Israeli or Mexican charities, among the organisations to which contributions are not deductible. That is a rule about the donor's tax return, not a publishing duty on your charity, and any individual case is a question for the donor's own tax adviser. The ways to give row of the section checklist records why a US route is best practice rather than a requirement.
- Does our UK charity have to publish a Form 990?
Not as a UK charity. The duty to make annual returns and the exemption application available falls on a US tax-exempt organisation, such as a 501(c)(3) affiliate, under the IRS public disclosure rules. What that organisation should show online is set out in what a 501(c)(3) should show online. If your charity holds IRS recognition of its own, ask your US adviser what follows from it.
- What is an equivalency determination?
The IRS describes it as a US private foundation's good faith determination that a foreign organisation qualifies as a public charity, made by a qualified tax practitioner (an attorney, CPA or enrolled agent), with written advice that can generally be relied on for two consecutive tax periods (IRS). The foundation commissions it, not your charity. Your part is to supply the facts, and to make sure your website says the same thing.
- Should our website host our US affiliate's Forms 990?
No. Link to them on the affiliate's own site. The affiliate is the organisation with the disclosure duty, and copies on your site go out of date the day it files its next return. The US disclosures row of the section checklist sets out what the affiliate's site carries.
- What should the page say if we have no US affiliate?
Say plainly that a gift made through your site goes to a UK charity, name it by its legal name and suggest that US taxpayers check the tax position with their own adviser before giving. Publication 526 is the IRS source for the general rule. The page should not describe a gift as tax-deductible in the US unless your adviser has confirmed a route that makes it so.