Can ED be conducted on a government entity?

ED is expressly available (per U.S. tax law) for non-U.S. organizations that are equivalent to U.S. public charities. NGOsource will also issue legal opinions – similar to EDs – verifying that an organization is a “foreign government agency or instrumentality,” by applying a set of facts and circumstances promulgated by the IRS. For more information on this topic, see our article on government entities.