b'EXPENDITURE RESPONSIBILITY & EQUIVALENCY DETERMINATIONThe IRS has designated two tools for U.S. foundations to use when substantiating the charitable purpose of grants made to support non-U.S. charities and charitable activities. Expenditure Responsibility (ER)Expenditure Responsibility involves CAF America funding a specific charitable project that our grantee is delivering one that we can determine is in line with the IRS definition of charitable purpose. ER can be used to fund: Specific charitable projects Charitable projects of for-profit entitiesER cannot be used to fund: Purchases of capital assets, construction, or general support Organizational Endowments Regranting (sending funds to a further beneficiary), in most casesEquivalency Determination (ED)Equivalency Determination involves CAF America making a good faith determination that the entire grantee organization is governed in a way that would otherwise be considered equivalent to a U.S. Public Charity under Sections 501(c)(3) and 509(a) of the Tax Code. Any grants made under an ED can be considered unrestricted, although CAF America may choose to enter into a grant agreement for accountability purposes. IRS Revenue Procedure 92-94 provides a specific procedure for making this determination, including a list detailing information that must be obtained from foreign charitable organizations.16 CHARITIES AID FOUNDATION AMERICA | SOLUTIONS FOR CROSS-BORDER GIVING'