Module 18: Citizen Action Card, How To Spot A Pass-Through 501(c)(3) In 10 Minutes

Five Public Filings. One Free Website. One Skill You Can Run On Any Nonprofit In The United States.

How To Spot A Pass-Through 501(c)(3) In 10 Minutes

Shadow Patriots · Module 18 · Citizen Action Card · Project Milk Carton · EIN 33-1323547

Pairs with Module 18: “The Box In The Middle” — How A United States Nonprofit Can Be The Legal Address For Work That Happens Somewhere Else — And How To Walk The Public Filings Yourself

What This Card Does

A “pass-through” 501(c)(3) is a United States nonprofit whose legal address sits in the United States but whose operational work happens substantially somewhere else — often through a sibling or related entity overseas. The arrangement is legal. The disclosure that makes the arrangement legible to the public is also legal — and most of it lives on free, public, no-login websites.

This card teaches the reader five steps for walking that disclosure. Run on a (c)(3) the reader chooses. About ten minutes. No special tools. No subscriptions.

The case in Module 18 is the demonstration. The reader’s own town is the actual reason to learn the skill. Once the reader can walk the five steps, the reader can walk them on any tax-exempt organization registered in the United States — including the foundation, the youth-services nonprofit, the educational trust, the advocacy group, the religious-affiliated charity, or the policy institute three blocks from the reader’s house.

What You’ll Need

• A computer or phone with a web browser.

• About ten minutes.

• The legal name or EIN of one 501(c)(3) you want to look at. (Don’t have one in mind? Pick any nonprofit you’ve donated to, volunteered with, or seen mentioned in a local news story this year.)

The Five Steps

Step 1 — Pull The Form 990 From ProPublica Nonprofit Explorer

Go to projects.propublica.org/nonprofits. The site is free. No account required. No paywall.

Type the nonprofit’s legal name in the search bar. The search returns matching organizations with their EINs, locations, and most recent revenue and expense totals.

Click the organization. The page shows the organization’s filing history. The most recent Form 990 is the one to start with. Click it. The 990 opens as a downloadable PDF.

What you’ve just done: pulled the same public document that journalists, regulators, donors, and analysts pull every day. The Form 990 is required by the Internal Revenue Service for tax-exempt organizations and is publicly disclosable under twenty-six United States Code section six one zero four (d). You have a right to see it. The right is not symbolic. The website you just used is one of several that make exercising the right easy.

Step 2 — Read Schedule F (Statement Of Activities Outside The United States)

Schedule F appears in the back portion of the 990 if the organization conducts activities outside the United States above certain disclosure thresholds. The first page of Schedule F lists the world regions in which the organization operated during the year, the type of activity in each region, and the total expenditures by region.

The second part of Schedule F lists grants to organizations located outside the United States. Each row of the grants table shows: the recipient organization’s identity (a name or, where the IRS allows, an identifier), the country of operation, the type of grant, and the dollar amount.

If Schedule F is empty but the organization clearly operates internationally — based on its website, its mission statement, its public-facing programs — that itself is a fact the reader can note. The IRS form provides space for disclosure. The absence of disclosure where activity exists is a documented gap.

If Schedule F shows large dollar amounts to a small number of overseas recipients, the reader should note: how much of the organization’s total annual expenses does the Schedule F transfer represent? On a five-million-dollar nonprofit, a two-million-dollar Schedule F transfer is a significant fraction. On a fifty-million-dollar nonprofit, the same two million is a small fraction. The ratio is the structural fact.

Step 3 — Read Schedule O (Statement Of Other Information)

Schedule O is the narrative section of the Form 990. Plain English. No jargon required. Organizations use Schedule O to explain anything on the 990 that requires explanation — governance disclosures, related-party transactions, descriptions of foreign-program activity, descriptions of sibling or affiliated organizations.

Open Schedule O. Read it.

Search the text for: any reference to a sibling, related, affiliated, or partner organization. Search for: any reference to an organization in another country. Search for: the term “Amuta” (the Hebrew term for an Israeli nonprofit association), the term “stiftung” (a German foundation), the term “asbl” (a Belgian association), or any other country-specific nonprofit term — these terms signal a related entity registered under another country’s law.

The Schedule O narrative is often where a structural relationship between a United States (c)(3) and an overseas sibling entity is described in the most direct language anywhere in the filing. It is also one of the most-overlooked sections. Five minutes spent reading Schedule O carefully pays back the rest of the audit in clarity.

Step 4 — Search The FARA Registry

The Foreign Agents Registration Act registry is operated by the United States Department of Justice. The registry is free and public at efile.fara.gov.

In the search bar, type the legal name of the nonprofit you’re auditing. The search returns any FARA registrations associated with that name.

If the nonprofit is registered under FARA, the registration document discloses the foreign principal on whose behalf the nonprofit is acting and the nature of the activity. The registration is public.

If the nonprofit is not registered under FARA but the Schedule F and Schedule O disclosures the reader just walked show substantial foreign-principal-adjacent operations, the reader can note the gap — without alleging anything. The FARA statute requires registration when five specific elements are met (see the article body in Module 18 for the full list). The fifth element — directional control — is the highest evidentiary bar. The reader is not the Department of Justice. The reader’s job is to read the public record accurately. The accuracy itself is the documented finding.

Step 5 — Run The Same Four Steps On One Nonprofit In Your County

This is the step that converts the audit from an exercise into a skill.

Pick any 501(c)(3) registered in your county or city. A community foundation. A youth-services nonprofit. An educational trust. A religious-affiliated charity. A policy institute. A medical foundation. A historic-preservation society. The reader has options.

Pull the most recent Form 990 from ProPublica. Read Schedule F. Read Schedule O. Search the FARA registry. Take ten minutes. Write down what is on each section. Write down what is not.

You will know more about the legal architecture of one nonprofit in your town than ninety-five percent of the people who live in your town.

That is not a small thing. The audit skill the reader just learned is the same skill federal regulators, journalists, and academic researchers use every day. The reader has it now. The reader can use it on the foundation that funded the road project last year. The reader can use it on the youth-services nonprofit that received a county grant. The reader can use it on the educational trust that hosts the after-school program. The reader can use it on the religious-affiliated charity that runs the food pantry.

Most of the time, the audit will show a clean, transparent, well-governed nonprofit doing exactly what it says it does. That is itself worth knowing. Trust earned by audit is more durable than trust given by default. The skill exists either way.

What You Saw

The skill running on the place you live, where it actually matters

The Tools Frame

This is a tool. Tools don’t pick sides. The side that shows up owns the tool. If you don’t show up, somebody else will — and they may not have your town in mind. Will they have the safety of your children in mind?

Companion Reading

• Module 18 — The Box In The Middle — the lead article this card pairs with. Walks the case study in detail and the FARA five-element framework.

• Module 19 — Three Hats, One Head — dropping mid-week. The paired mirror module on the same architectural family, applied to the personnel-overlap mechanism.

• Module 16 — The Engine That Looks Like Seven Engines — the domestic blue-coat counterpart on the bipartisan firewall.

• Module 17 — The One Point Six Billion Dollar Donation You Never Voted On — the domestic red-coat counterpart.

• Module 21 — How To Read A Form 990 — the upcoming Part Five module on the canonical 990 walk. The skill in this card is one specific application of the broader 990-literacy skill that module teaches.

Shadow Patriots · Module 18 · Citizen Action Card · Project Milk Carton · 501(c)(3) · EIN 33-1323547

This card is part of the Shadow Patriots civic-investigations series. Each module ships one Citizen Action Card alongside its lead article. The card teaches a transferable audit skill the reader can run, in about ten minutes, on any tax-exempt organization in the reader’s own town. The product is the skill. The architecture is the diagnosis. The citizen is the destination.

No criminality is alleged in this card. No assertion is made that any individual, organization, foundation, or trust has violated any statute. The card teaches the reader to walk the public record accurately. The accuracy itself is the documented finding.

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