Administrative, Procedural, and Miscellaneous

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Part III

Administrative, Procedural, and Miscellaneous

26 CFR 601.201: Rulings and determination letters

(Also: §501; 1.501(a)-1)

Rev. Proc. 2026-8

TABLE OF CONTENTS

SECTION 1. PURPOSE

SECTION 2. BACKGROUND

SECTION 3. DEFINITIONS OF TERMS USED IN THIS REVENUE PROCEDURE

SECTION 4. REQUIREMENTS TO OBTAIN AND MAINTAIN A GROUP EXEMPTION

LETTER

.01

General requirements

(1)

Recognition of exemption

(2)

Minimum number of subordinate organizations

(3)

Only one group exemption letter

.02

The central organization’s relationship with its subordinate organizations

(1)

In general

(2)

Affiliated

(3)

General supervision

(4)

Control

(5)

Example of general supervision when not all subordinate organizations

.03

.04

.05

.06

.07

.08

are required to file annual information returns or notices

Organizations eligible for initial inclusion in a group application, or subsequent

addition to a group exemption letter, as subordinate organizations

(1)

In general

(2)

Requirements for initial inclusion in a group application, or subsequent

addition to a group exemption letter, as a subordinate organization

Organizations not eligible for initial inclusion in a group application, or

subsequent addition to a group exemption letter, as subordinate organizations

Continued inclusion in a group exemption letter

Authorization for initial inclusion in a group application, or subsequent addition to

a group exemption letter, as a subordinate organization

(1)

In general

(2)

Removal

Employer identification numbers (EINs)

Annual information return or notice

SECTION 5. CONSIDERATION OF GROUP APPLICATIONS

.01

Group applications

.02

Non-acceptance

.03

Circumstances under which group exemption letters are not ordinarily issued

SECTION 6. INSTRUCTIONS FOR SUBMITTING A GROUP APPLICATION

.01

Group applications

.02

Electronic submission

.03

Information about the central organization

(1)

In general

(2)

Request concurrent with application

.04

Information about the subordinate organizations

(1)

In general

(2)

Additional requirements

(3)

Updates to a pending group application

.05

New group application after the termination of a group exemption letter

SECTION 7. INFORMATION REQUIRED TO MAINTAIN A GROUP EXEMPTION

LETTER

.01

Information required annually

.02

Supplemental group ruling information (SGRI)

(1)

Change in purpose, character, or method of operation

(2)

Lists of certain changes

(3)

Organizations to be added to the group exemption letter as subordinate

organizations

(4)

Other information

(5)

No change

.03

.04

.05

Electronic submission

Additional information

Exception for central organizations that are churches or conventions or

associations of churches

SECTION 8. TERMINATION OF, OR REMOVAL FROM, THE GROUP EXEMPTION

LETTER

.01

Termination of the group exemption letter

(1)

Termination by the IRS

(2)

Termination by the central organization

.02

Removal from the group exemption letter

(1)

Basis for removal by the IRS

(2)

Basis for removal by the central organization

(3)

Notification

(4)

Group exemption letter remains in effect

SECTION 9. EFFECT OF NON-ACCEPTANCE, NON-ISSUANCE, TERMINATION, OR

REMOVAL

.01

Effect of non-acceptance or non-issuance

.02

Effect of termination

.03

Effect of removal

.04

Churches and conventions or associations of churches

.05

Subsequent recognition of exemption

(1)

In general

(2)

Organization required to file an application

(3)

Organization not required to file an application

.06

Subsequent exemption without recognition from the IRS

.07

Automatic revocation

SECTION 10. EFFECTIVE DATE OF EXEMPTION

.01

Initial inclusion

.02

Subsequent addition

.03

Non-acceptance, non-issuance, termination, or removal

(1)

In general

(2)

Organizations filing an application

(3)

Organizations being included in a new group application

(4)

Organizations being added to a group exemption letter

(5)

Automatic revocation

SECTION 11. DECLARATORY JUDGMENT PROVISIONS OF § 7428

.01

In general

.02

Who must file

SECTION 12. APPLICABILITY

.01

New group exemption letters

.02

Preexisting group exemption letters

(1)

In general

(2)

Transition period for certain requirements applicable to preexisting group

exemption letters and preexisting subordinate organizations

(3)

Certain requirements not applicable to preexisting subordinate

organizations

.03

Examples

(1)

Example 1. Two preexisting group exemption letters for subordinate

organizations described in different paragraphs of § 501(c)

(2)

Example 2. One preexisting group exemption letter with no subordinate

organizations

(3)

Example 3. One preexisting group exemption letter with subordinate

organizations described in different paragraphs of § 501(c)

(4)

Example 4. One preexisting group exemption letter with preexisting

subordinate organizations described in the same paragraph of § 501(c)

(5)

Example 5. Removal of a preexisting subordinate organization from a

preexisting group exemption letter

SECTION 13. PAPERWORK REDUCTION ACT

SECTION 14. EFFECT ON OTHER REVENUE PROCEDURES

SECTION 15. EFFECTIVE DATE

SECTION 16. DRAFTING INFORMATION

SECTION 1. PURPOSE

This revenue procedure modifies and supersedes Rev. Proc. 80-27, 1980-1 C.B. 677

(as modified by Rev. Proc. 96-40, 1996-2 C.B. 301) by setting forth updated procedures

to obtain recognition of exemption from federal income tax on a group basis for

organizations described in § 501(c) of the Internal Revenue Code (Code) 1 that are

1 Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Income Tax

Regulations (26 CFR part 1).

affiliated with and under the general supervision or control of a central organization.

This revenue procedure relieves each subordinate organization included in a group

exemption letter from filing its own application for recognition of exemption. This

revenue procedure also sets forth updated procedures a central organization must

follow to maintain a group exemption letter.

SECTION 2. BACKGROUND

.01 Section 508 provides special rules with respect to organizations described in

§ 501(c)(3), including the general requirement in § 508(a) that organizations must notify

the Secretary of the Treasury or the Secretary’s delegate (Secretary) that they are

applying for recognition of § 501(c)(3) status. Section 505 provides additional

requirements for organizations described in § 501(c)(9) or (17), including the general

requirement in § 505(c) that organizations must notify the Secretary that they are

applying for recognition of exemption under § 501(c)(9) or (17). Sections 1.508-1(a)(1)

and 1.505(c)-1T provide additional information regarding the way the notice required

under §§ 508(a) and 505(c) is given to the Internal Revenue Service (IRS).

Organizations described in other paragraphs of § 501(c), such as social welfare

organizations described in § 501(c)(4), may, but are not required to, apply for

recognition of exemption. However, § 506 generally requires an organization described

in § 501(c)(4) to notify the Secretary, in the manner prescribed in § 1.506-1, of the

organization’s intent to operate as such no later than 60 days after the organization is

established.

.02 Section 508(c)(2)(B) permits the Secretary, by regulation, to except organizations

from the § 508(a) notice requirement if the Secretary determines that full compliance is

not necessary for the efficient administration of the provisions relating to private

foundations.

.03 Section 1.508-1(a)(3)(i) provides that the § 508(a) notice requirement does not

apply to specific types of organizations, including subordinate organizations included in

a group exemption letter.

.04 Rev. Proc. 68-13, 1968-1 C.B. 764, superseded by Rev. Proc. 72-41, 1972-2

C.B. 820, Rev. Proc. 77-38, 1977-2 C.B. 571, and Rev. Proc. 80-27, set forth the first

published procedures for obtaining recognition of exemption from federal income tax on

a group basis for organizations described in § 501(c). The most recent guidance

regarding group exemption letters is set forth in Rev. Proc. 80-27, as modified by Rev.

Proc. 96-40.

.05 Rev. Proc. 2018-32, 2018-23 I.R.B. 739, sets forth the extent to which grantors

and contributors may rely on the listing of a central organization in IRS databases of

organizations eligible to receive tax-deductible contributions under § 170, for purposes

of determining whether the grants or contributions to the organization may be deductible

under § 170.

.06 In Notice 2020-36, 2020-21 I.R.B. 840, the Department of the Treasury (Treasury

Department) and the IRS invited comments regarding a proposed revenue procedure

that, if finalized, would modify and supersede Rev. Proc. 80-27 by setting forth updated

procedures for obtaining recognition of exemption from federal income tax on a group

basis for subordinate organizations described in § 501(c), including transition relief for

existing organizations. The Treasury Department and the IRS received 29 comments in

response to Notice 2020-36.

.07 After considering the comments received in response to Notice 2020-36, the

Treasury Department and the IRS issue this revenue procedure to reduce the

administrative burden and increase the efficiency of the group exemption letter program,

improve the integrity of data collected for purposes of oversight of the group exemption

letter program, increase the transparency of the group exemption letter program, and

increase compliance by central organizations and subordinate organizations with

requirements of the group exemption letter program. This revenue procedure also

provides greater certainty and clarity to central organizations and subordinate

organizations under existing group exemption letters and organizations that file an

application for a group exemption letter after the date of publication of this revenue

procedure in the Internal Revenue Bulletin (publication date).

.08 Notice 2020-36 provides that the IRS will not accept applications for group

exemption letters on or after June 17, 2020, until publication of the final revenue

procedure or other guidance in the Internal Revenue Bulletin. The IRS will resume

accepting applications for group exemption letters after January 20, 2026, the

publication date.

SECTION 3. DEFINITIONS OF TERMS USED IN THIS REVENUE PROCEDURE

.01 The term “annual information return or notice” means the return or notice an

organization must file annually under § 6033(a) or (i) of the Code (that is, Form 990,

Return of Organization Exempt From Income Tax; Form 990-EZ, Short Form Return of

Organization Exempt From Income Tax; Form 990-N, Electronic Notice (e-Postcard) for

Tax-Exempt Organizations Not Required to File Form 990 or Form 990-EZ; or, in the

context of a central organization that is a private foundation, Form 990-PF, Return of

Private Foundation).

.02 The term “application” means a request for recognition of exemption from federal

income tax under § 501 in the manner described by Rev. Proc. 2026-5, 2026-1 I.R.B.

258 (or its successor).

.03 The term “application for reinstatement” means an application filed in the manner

described by Rev. Proc. 2014-11, 2014-3 I.R.B. 411, as supplemented by Rev. Proc.

2026-5 (or its successor), after an organization’s exemption has been automatically

revoked.

.04 The term “automatically revoked” means, with respect to an organization, the

revocation of the organization’s exemption by operation of § 6033(j) for failure to file an

annual information return or notice for three consecutive years.

.05 The term “central organization” means an organization described in § 501(c), a

political subdivision or integral part of a political subdivision, or an instrumentality of a

political subdivision that has one or more subordinate organizations under its general

supervision or control.

.06 The term “a church or a convention or association of churches” has the same

meaning as the term in § 170(b)(1)(A)(i).

.07 The term “group application” means an application for a group exemption letter.

.08 The term “group exemption letter” means a letter issued by the IRS to a central

organization recognizing the exemption from federal income tax on a group basis for

subordinate organizations described in § 501(c).

.09 The term “preexisting group exemption letter” means a group exemption letter in

existence on the publication date.

.10 The term “preexisting subordinate organization” means a subordinate

organization included in a preexisting group exemption letter on the publication date. If

a preexisting subordinate organization is removed from a group exemption letter and is

subsequently added back to the group exemption letter from which it was removed, it

will not be a preexisting subordinate organization.

.11 The term “submission date” means(1) In the case of any document filed on paper with the IRS, (a) the postmark date

applied by the United States Postal Service, or (b) for any document given to a

designated delivery service (as such term is defined in § 7502(f)(2)) for delivery, the

date that is recorded electronically to a database by the designated delivery service or

marked on the cover of the document by the designated delivery service; and

(2) In the case of any document filed electronically with the IRS, the date of

transmittal to the IRS.

.12 The term “subordinate organization” means an organization described in § 501(c)

that is a chapter, local, post, or unit of a central organization. It must have a governing

instrument (for example, a charter, trust indenture, articles of association, etc.), whether

or not it is incorporated.

.13 The term “supplemental group ruling information” or “SGRI” means the

information described in section 7.02 of this revenue procedure that a central

organization must submit annually to the IRS about its subordinate organizations unless

an exception applies.

SECTION 4. REQUIREMENTS TO OBTAIN AND MAINTAIN A GROUP EXEMPTION

LETTER

.01 General requirements.

(1) Recognition of exemption. On or before the date it files a group application, a

central organization described in § 501(c) must either (a) be recognized by the IRS as

tax-exempt, (b) have filed an application, or (c) in the case of a central organization that

has had its exemption automatically revoked, have filed an application for

reinstatement.

(2) Minimum number of subordinate organizations. A central organization must

have at least five subordinate organizations to obtain a group exemption letter, and it

must have at least one subordinate organization to maintain the group exemption letter

thereafter (except as provided in section 12.02(2)(a)(i) of this revenue procedure, which

provides a transition period for preexisting group exemption letters).

(3) Only one group exemption letter. A central organization may maintain only one

group exemption letter (except as provided in section 12.02(2)(a)(ii) of this revenue

procedure, which provides a transition period for preexisting group exemption letters).

.02 The central organization’s relationship with its subordinate organizations.

(1) In general. Each subordinate organization initially included in a group

application, or subsequently added to a group exemption letter, must be (1) affiliated

with the central organization, and (2) subject to its general supervision or control, as

such terms are defined in this section 4.02 (except as provided in section 12.02(2)(a)(iii)

of this revenue procedure, which provides a transition period for preexisting subordinate

organizations). The terms “affiliated,” “general supervision,” and “control,” as used in

this revenue procedure, apply only for purposes of this revenue procedure and

§ 1.6033-2(d) (relating to group returns).

(2) Affiliated. A subordinate organization’s affiliation with the central organization is

demonstrated by facts and circumstances showing that it is a chapter, local, post, or unit

of the central organization. For example, a subordinate organization may demonstrate

its affiliation with a central organization by (a) the inclusion of its information on a group

return described in § 1.6033-2(d) that includes the four-digit group exemption number

(GEN); (b) the current inclusion of the subordinate organization in a directory of

subordinate organizations updated annually by the central organization; or (c) in the

case of a subordinate organization that is a church or a convention or association of

churches, the sharing of common religious bonds or convictions with the central

organization.

(3) General supervision.

(a) In general. A subordinate organization is subject to the general supervision

of a central organization if the central organization:

(i) Annually obtains, reviews, and retains information on the subordinate

organization’s finances, activities, and compliance with annual filing requirements; and

(ii) Annually transmits (including electronically) written information to, or

otherwise educates, the subordinate organization about the requirements to maintain

tax-exempt status under the applicable paragraph of § 501(c), including, but not limited

to, annual filing requirements, if applicable.

(b) Form 990 or Form 990-EZ. A central organization may obtain the information

regarding a subordinate organization required by section 4.02(3)(a)(i) of this revenue

procedure by obtaining a copy of the subordinate organization’s Form 990 or Form 990EZ. A copy of the subordinate organization’s Form 990-N is not sufficient to satisfy the

requirement to obtain the information regarding the subordinate organization required

by section 4.02(3)(a)(i) of this revenue procedure.

returns or notices. If a subordinate organization is not required to file an annual

information return or notice, a central organization may, but is not required to, satisfy

section 4.02(3)(a)(i) of this revenue procedure regarding the subordinate organization.

See section 4.02(5) of this revenue procedure for an example illustrating the operation

of this section 4.02(3).

(4) Control. A subordinate organization is subject to the control of a central

organization if:

(a) The central organization appoints the subordinate organization’s directors or

trustees who possess a majority of the voting power with respect to the subordinate

organization’s governance;

(b) The central organization appoints a majority of the subordinate organization’s

officers;

the voting power with respect to the subordinate organization’s governance are

directors or trustees of the central organization;

(d) A majority of the subordinate organization’s officers are officers of the central

organization; or

(e) The central organization and the subordinate organization enter into a written

agreement that evidences the central organization’s control over the subordinate

organization’s activities and operations. For example, the written agreement may

contain provisions that describe an alternative governance structure in which the central

organization must approve the election of the subordinate organization’s directors or

has the right to remove directors at any time with or without cause. Alternatively, the

central organization may enter into a management agreement with the subordinate

organization giving it direct control over the subordinate organization’s activities and

operations.

(5) Example of general supervision when not all subordinate organizations are

required to file annual information returns or notices.

(a) Central organization A is described in § 501(c)(3). A has a group exemption

letter for subordinate organizations described in § 501(c)(3) that are organized and

operated for charitable, educational, and religious purposes. A is a church and the

subordinate organizations are churches, schools (below college level), and hospitals.

(b) A exercises general supervision over A’s subordinate organizations that are

hospitals by annually obtaining, reviewing, and retaining copies of those subordinate

organizations’ annual information returns and by annually providing each hospital an

electronic link to the current version of Publication 557, Tax-Exempt Status for Your

Organization, available on irs.gov, which provides information about the requirements to

maintain tax-exempt status under § 501(c)(3) and annual filing requirements.

churches and schools by annually providing each church and school an electronic link

to the current version of Publication 1828, Tax Guide for Churches & Religious

Organizations, available on irs.gov, which provides information about the requirements

to maintain tax-exempt status under § 501(c)(3). A is not required to annually obtain,

review, or retain information on the finances, activities, and compliance with annual

filing requirements of the subordinate organizations that are churches or schools

because those subordinate organizations are not required to file annual information

returns or notices pursuant to § 1.6033-2(g)(1)(i).

.03 Organizations eligible for initial inclusion in a group application, or subsequent

addition to a group exemption letter, as subordinate organizations.

(1) In general. An organization described in § 501(c) is eligible for initial inclusion

in a group application, or subsequent addition to a group exemption letter, as a

subordinate organization if it meets the requirements of section 4.03(2) of this revenue

procedure and is not described in section 4.04 of this revenue procedure.

(2) Requirements for initial inclusion in a group application, or subsequent addition

to a group exemption letter, as a subordinate organization. In addition to being affiliated

with the central organization and subject to its general supervision or control, all

subordinate organizations initially included in a group application, or subsequently

added to a group exemption letter, must meet the requirements of this section 4.03(2)

(except as provided in sections 12.02(2) and 12.02(3) of this revenue procedure,

regarding requirements applicable to preexisting subordinate organizations after a

transition period and requirements not applicable to preexisting subordinate

organizations).

(a) Matching requirement. All subordinate organizations under a group

exemption letter must be described in the same paragraph of § 501(c). Subordinate

organizations are not required to be described in the same paragraph of § 501(c) as the

central organization.

(b) Uniform purpose statement requirement. Subordinate organizations that

share the same purpose must have a uniform purpose statement in their governing

instruments (for example, a charter, trust indenture, articles of association, etc.). If one

or more subordinate organizations covered by a group exemption letter have a purpose

that is different from the purpose of other subordinate organizations covered by the

letter, the subordinate organizations that share a purpose must include the same

uniform purpose statement in their governing instruments. For example, if a group

exemption letter includes subordinate organizations that are schools and hospitals, the

subordinate organizations that are schools must include the same uniform purpose

statement in their governing instruments and the subordinate organizations that are

hospitals must include the same uniform purpose statement in their governing

instruments. The uniform purpose statement must generally describe the purpose of

the subordinate organizations.

on a group return filed by the central organization on behalf of those subordinate

organizations must be on the same annual accounting period as the central

organization (see § 1.6033-2(d) for information on filing group returns).

.04 Organizations not eligible for initial inclusion in a group application, or

subsequent addition to a group exemption letter, as subordinate organizations. The

following organizations cannot be initially included in a group application, or

subsequently added to a group exemption letter, as subordinate organizations:

(1) An organization that is organized in a foreign country;

(2) An organization described in § 501(c)(3) that is classified as a private

foundation under § 509(a);

(3) An organization described in § 501(c)(3) that, pursuant to § 509(a)(3)(B)(iii), is

operated in connection with one or more organizations described in § 509(a)(1) or (2)

(that is, an organization classified as a Type III supporting organization under

§ 509(a)(3) and § 1.509(a)-4(i));

(4) A qualified nonprofit health insurance issuer described in § 501(c)(29); and

(5) An organization that has had its exemption automatically revoked and that has

not had its exemption reinstated after filing an application for reinstatement.

.05 Continued inclusion in a group exemption letter. A subordinate organization

initially included in a group application, or subsequently added to a group exemption

letter, must continue to satisfy sections 4.02, 4.03, and 4.04 of this revenue procedure

to remain a subordinate organization under the group exemption letter.

.06 Authorization for initial inclusion in a group application, or subsequent addition to

a group exemption letter, as a subordinate organization.

(1) In general. A subordinate organization must authorize the central organization

to include the subordinate organization in a group application or to add the subordinate

organization to an existing group exemption letter. This authorization must be in writing,

and it must be signed by an officer of the subordinate organization with personal

knowledge of the facts and with authority to legally bind the subordinate organization.

(2) Removal. The authorization described in this section 4.06 must acknowledge

that the central organization may remove the subordinate organization from the group

exemption letter with or without cause, in accordance with section 8.02(2) of this

revenue procedure.

.07 Employer identification numbers (EINs). A central organization, and each

subordinate organization, must have its own EIN. The central organization must obtain

an EIN prior to filing its application, and each subordinate organization (or the central

organization on a subordinate organization’s behalf) must obtain an EIN prior to its initial

inclusion in a group application or subsequent addition to a group exemption letter. If,

pursuant to § 1.6033-2(d), a central organization elects to file a group return for two or

more subordinate organizations, the central organization must obtain an EIN (separate

from the central organization’s EIN) that is issued solely for the purpose of the group

return.

.08 Annual information return or notice. A central organization generally must file its

own annual information return or notice unless an exception applies. Each subordinate

organization initially included in a group application, or subsequently added to a group

exemption letter, generally must also file an annual information return or notice or have

its information included in a group return described in § 1.6033-2(d) filed by the central

organization unless an exception applies.

SECTION 5. CONSIDERATION OF GROUP APPLICATIONS

.01 Group applications. The IRS will consider group applications that meet the

requirements of section 6 of this revenue procedure.

.02 Non-acceptance. A group application that is missing any information required by

section 6 of this revenue procedure or Rev. Proc. 2026-5 (or its successor) will be

deemed incomplete and will not be accepted for processing by the IRS.

.03 Circumstances under which group exemption letters are not ordinarily issued.

The IRS may decline to issue a group exemption letter if it is not in the interest of sound

tax administration. For example, the IRS may decline to issue a group exemption letter

if the activities described in the group application involve complex facts and

circumstances that are more appropriately evaluated on an organization-by-organization

basis.

SECTION 6. INSTRUCTIONS FOR SUBMITTING A GROUP APPLICATION

.01 Group applications. A group application must meet the requirements of this

section 6. A subordinate organization included in a group application should not apply

separately for recognition of exemption (except in the circumstances described in

section 9 of this revenue procedure, regarding the effect of non-acceptance, non-

issuance, termination, or removal).

.02 Electronic submission. Group applications must be submitted electronically on

Form 8940 at www.pay.gov, along with all information, documentation, and other

materials required by Form 8940 and the instructions thereto, including the appropriate

user fee. The IRS may change the procedures for the submission of group applications

through guidance published in the Internal Revenue Bulletin or in forms, instructions,

publications, or a posting on irs.gov issued with respect to this revenue procedure.

.03 Information about the central organization.

(1) In general. A central organization must include the following information in its

group application:

(a) The central organization’s name, address, and EIN; and

(b) Information establishing that it is a central organization described in section

3.05 of this revenue procedure.

(2) Request concurrent with application. A central organization described in

§ 501(c) that has not obtained recognition of exemption at the time it files a group

application may submit the group application concurrently with its own application, or, in

the case of a central organization that has had its exemption automatically revoked, with

its application for reinstatement (see section 4.02(7)(a) of Rev. Proc. 2026-5 (or

corresponding section(s) of its successor)).

.04 Information about the subordinate organizations.

(1) In general. A central organization must include the following information and

representations regarding the subordinate organizations in its group application:

(a) The name, mailing address, EIN, and date of formation or incorporation of

each subordinate organization to be included in the group exemption letter (a current

directory of subordinate organizations may be furnished if the directory includes the

required information);

(b) A representation that each subordinate organization is affiliated with the

central organization and subject to its general supervision or control;

same paragraph of § 501(c);

(d) The paragraph of § 501(c) under which the subordinate organizations are or

will be described;

(e) A representation that no subordinate organization is organized under the laws

of a foreign country;

(f) If the subordinate organizations included in the group application are

described in § 501(c)(3), a representation that no subordinate organization is a private

foundation under § 509(a) or a Type III supporting organization under § 509(a)(3) and

§ 1.509(a)-4(i);

(g) A representation that no subordinate organization is a qualified nonprofit

health insurance issuer described in § 501(c)(29);

(h) A representation that no subordinate organization (i) has had its exemption

automatically revoked and (ii) not had its exemption reinstated after filing an application

for reinstatement;

(i) If the subordinate organizations are described in § 501(c)(3) and classified as

public charities, the paragraph(s) of §§ 509(a) and 170(b)(1)(A) (if applicable) under

which they are classified;

(j) A representation that each subordinate organization sharing the same

purpose has adopted a uniform purpose statement (as described in section 4.03(2)(b) of

this revenue procedure) as a part of its governing instrument;

(k) The text of the uniform purpose statement(s) adopted by the subordinate

organizations sharing the same purpose as part of their governing instruments;

(l) A detailed description of each subordinate organization’s purpose(s) and

activities, including the sources of its receipts and the nature of its expenditures;

(m) A representation that each subordinate organization has furnished the

central organization the written authorization described in section 4.06 of this revenue

procedure;

(n) A representation confirming that all subordinate organizations were organized

within 27 months of the submission date of the group application, or, if any subordinate

organizations were organized more than 27 months before the submission date, a

statement that all subordinate organizations, other than subordinate organizations

recognized by the IRS as being described in § 501(c) or included in another group

exemption letter immediately prior to being included in the group application, agree to

be recognized as exempt from the submission date of the group application;

(o) If the central organization will file a group return on behalf of two or more

subordinate organizations, a representation that the subordinate organizations included

on such group return are (or will be) on the same annual accounting period as the

central organization (see § 1.6033-2(d) for information on filing group returns); and

(p) Such additional information as the IRS may specify in published guidance in

the Internal Revenue Bulletin or in other guidance, such as forms, instructions,

publications, or a posting on irs.gov issued with respect to this revenue procedure.

(2) Additional requirements. A central organization with subordinate organizations

that are private schools, charitable hospitals, or social welfare organizations must

submit the information described in this section 6.04(2), as applicable, in addition to the

information generally required by this section 6.

(a) Private schools. If the group application involves subordinate organizations

that are or will be private schools described in § 501(c)(3), the central organization must

include the information required by Rev. Proc. 75-50, 1975-2 C.B. 587, as modified by

Rev. Proc. 2019-22, 2019-22 I.R.B. 1260, and such other information necessary to

establish that the subordinate organizations comply with the requirements of Rev. Rul.

71-447, 1971-2 C.B. 230.

(b) Charitable hospitals. If the group application involves subordinate

organizations that are or will be hospital organizations or facilities described in

§ 501(c)(3), the central organization must provide the information necessary to establish

that each subordinate organization meets the requirements of § 501(r) and Rev. Rul.

69-545, 1969-2 C.B. 117.

organizations that are or will be described in § 501(c)(4), the central organization must

represent that each subordinate organization has complied with or will comply with the

requirements of § 506 and Rev. Proc. 2016-41, 2016-30 I.R.B. 165. A subordinate

organization may authorize an individual representing a central organization to submit

Form 8976, Notice of Intent to Operate Under Section 501(c)(4), on behalf of the

subordinate organization and to receive any communications relating to the submission.

(3) Updates to a pending group application. If a central organization determines

that any of the information or representations regarding a subordinate organization set

forth in a group application is not accurate after the group application has been filed with

the IRS, the central organization must submit additional information to the IRS

correcting the inaccurate information or representations. For example, if a subordinate

organization included in a group application ceases operations and dissolves under

state law after the group application was filed with the IRS, the central organization

must provide an updated list of subordinate organizations to be included in the group

exemption letter that does not include the organization that went out of existence.

.05 New group application after the termination of a group exemption letter. If the

IRS terminates a group exemption letter as described in section 8.01(1) of this revenue

procedure, a central organization may file a new group application in the manner

described in this section 6, but the central organization must include a description of the

policies or procedures it has implemented, or intends to implement, to ensure the new

group exemption letter satisfies the requirements of this revenue procedure.

SECTION 7. INFORMATION REQUIRED TO MAINTAIN A GROUP EXEMPTION

LETTER

.01 Information required annually. Except as provided in section 7.05 of this revenue

procedure (regarding central organizations that are churches or conventions or

associations of churches), a central organization must submit the information described

in this section 7 to the IRS annually at least 30 days, but no more than 90 days, before

the close of the central organization’s annual accounting period. A central organization

may provide additional updates at any time.

.02 Supplemental group ruling information (SGRI).

(1) Change in purpose, character, or method of operation. A central organization

must submit information regarding all changes in the purposes, character, or method of

operation of all subordinate organizations included in the group exemption letter.

(2) Lists of certain changes.

(a) Categories. A central organization must submit a separate list for each of the

following categories of changes (as applicable):

(i) Subordinate organizations that have changed their name and/or mailing

address during the year;

(ii) Subordinate organizations that are no longer included in the group

exemption letter;

(iii) Subordinate organizations whose exemptions have been automatically

revoked; and

(iv) Subordinate organizations that are being added to the group exemption

letter.

(b) Required information. Each list described in this section 7.02(2) must include

the name, mailing address, and EIN for each subordinate organization identified in the

list.

organizations is not acceptable for purposes of this section 7.02(2).

(3) Organizations to be added to the group exemption letter as subordinate

organizations. A central organization must submit the following statements and

information regarding the subordinate organizations being added to the central

organization’s group exemption letter:

(a) The date of formation or incorporation of each subordinate organization;

(b) A statement that the information upon which the group exemption letter was

based (see section 6.04 of this revenue procedure, regarding information about

subordinate organizations to be included with a group application), as updated by the

current or previous SGRI submissions, is applicable in all material respects to each

subordinate organization;

the subordinate organizations in the group exemption letter (see section 6.04(1)(l) of

this revenue procedure);

(d) A statement regarding the accounting period of subordinate organizations on

behalf of which the central organization will file a group return, if applicable (see section

6.04(1)(n) of this revenue procedure); and

(e) Any additional information required by section 6.04(2) of this revenue

procedure (pertaining to private schools, charitable hospitals, and social welfare

organizations), if applicable.

(4) Other Information. A central organization must submit any other information

that the IRS may specify in guidance published in the Internal Revenue Bulletin or

in forms, instructions, publications, or a posting on irs.gov issued with respect to this

revenue procedure.

(5) No change. If there are no changes that are required to be reported under this

section 7, a central organization must submit a statement that it has no reportable

changes.

.03 Electronic submission. The information required in this section 7 must be

submitted electronically. If the IRS has not published procedures for electronic

submission of the information required in this section 7 by the publication date, then the

information must be sent to the address set forth below. The IRS may change the

address below and procedures for the submission of information required by this section

7 through guidance published in the Internal Revenue Bulletin or in forms, instructions,

publications, or a posting on irs.gov issued with respect to this revenue procedure.

Ogden Service Center

Mail Stop 6271

1000 South 1200

Ogden, UT 84404-4749

.04 Additional information. Submission of the information required by this section 7

does not relieve a central organization or any of its subordinate organizations of the

duty to submit such additional information as the IRS may require to determine whether

the conditions for continued exemption are met. See §§ 6001 and 6033 and the

regulations thereunder.

.05 Exception for central organizations that are churches or conventions or

associations of churches. A central organization described in § 501(c)(3) that is a

church or a convention or association of churches and that maintains a group

exemption letter may, but is not required to, submit the information described in this

section 7.

SECTION 8. TERMINATION OF, OR REMOVAL FROM, THE GROUP EXEMPTION

LETTER

.01 Termination of the group exemption letter.

(1) Termination by the IRS. Subject to the applicability provisions set forth in

section 12 of this revenue procedure, the IRS may terminate a group exemption letter

for any of the reasons set forth in this section 8.01(1). See section 6.05 of this revenue

procedure if a central organization files a new group application after the IRS terminates

the central organization’s group exemption letter.

(a) The central organization notifies the IRS that the central organization is going

out of existence.

(b) The IRS determines that the central organization is no longer described in

§ 501(c) and therefore is not exempt under § 501(a).

(d) The central organization (other than a church or a convention or association

of churches) fails to submit timely and complete SGRI.

(e) The central organization has no subordinate organizations.

(f) The central organization fails to exercise general supervision or control over

one or more subordinate organizations.

(g) More than half of the subordinate organizations have had their exemptions

automatically revoked.

(h) More than half of the subordinate organizations fail to satisfy the matching or

uniform purpose statement requirement in section 4.03(2) of this revenue procedure.

(i) The central organization otherwise fails to satisfy the requirements of this

revenue procedure.

(2) Termination by the central organization. A central organization may terminate

its group exemption letter at any time by submitting a statement in the same manner as

an SGRI submission as set forth in section 7.03 of this revenue procedure. The central

organization should notify each subordinate organization of the termination and provide

information regarding how the subordinate organization may obtain recognition of its

exemption (see section 9.05 of this revenue procedure) or claim exemption without

recognition (see section 9.06 of this revenue procedure).

.02 Removal from the group exemption letter.

(1) Basis for removal by the IRS.

(a) The IRS will remove a subordinate organization from a group exemption letter

if:

(i) The IRS determines that the subordinate organization is no longer described

in § 501(c) and therefore is not exempt under § 501(a);

(ii) The IRS determines that the subordinate organization is an organization not

eligible for initial inclusion in a group application, or subsequent addition to a group

exemption letter, because it is a foreign organization, private foundation, Type III

supporting organization, or qualified nonprofit health insurance issuer;

(iii) The subordinate organization’s exemption is automatically revoked; or

(iv) The IRS determines that the subordinate organization is described in a

paragraph of § 501(c) that is different from the paragraph in which the central

organization stated that the subordinate organizations would be described in its group

application.

(b) The IRS may remove a subordinate organization from a group exemption

letter if the IRS determines that the subordinate organization otherwise fails to meet the

requirements of this revenue procedure or guidance published in the Internal Revenue

Bulletin or in forms, instructions, publications, or a posting on irs.gov issued with respect

to this revenue procedure.

(2) Basis for removal by the central organization. A subordinate organization will

cease to be included in a group exemption letter on the date the central organization

notifies the IRS, through an SGRI submission consistent with section 7.02(2)(a)(ii) of

this revenue procedure, that the subordinate organization is no longer included in the

group exemption letter. Removal of a subordinate organization by the central

organization can be with or without cause. The central organization may not submit the

SGRI removing the subordinate organization prior to the end of the 30-day period set

forth in section 8.02(3) of this revenue procedure.

(3) Notification. A central organization must provide a subordinate organization

with at least 30 days’ notice prior to removing the subordinate organization from the

central organization’s group exemption letter. After removing the subordinate

organization from the group exemption letter by submitting SGRI to the IRS, the central

organization also must notify the subordinate organization that it has been removed

from the group exemption letter and provide the subordinate organization with

information regarding how it may obtain recognition of its exemption (see section 9.05 of

this revenue procedure) or claim exemption without recognition (see section 9.06 of this

revenue procedure).

(4) Group exemption letter remains in effect. After the removal of one or more

subordinate organizations under this section 8.02, a group exemption letter will remain

in effect for all subordinate organizations that were not removed. However, if no

subordinate organizations remain after the removal, the IRS will terminate the central

organization’s group exemption letter. (See section 8.01(1)(e) of this revenue

procedure.)

SECTION 9. EFFECT OF NON-ACCEPTANCE, NON-ISSUANCE, TERMINATION, OR

REMOVAL

.01 Effect of non-acceptance or non-issuance. Except as provided in this section 9,

if the IRS does not accept a group application because it lacks information required by

this revenue procedure or if the IRS declines to issue a group exemption letter in the

interest of sound tax administration, the IRS will not recognize the exemption of any

organization included in the group application as a subordinate organization. If the IRS

previously issued a determination letter to such subordinate organization individually

and that determination letter is still effective on the date of non-acceptance or non-

issuance, as applicable, then the IRS will recognize the existing determination letter.

Alternatively, the subordinate organization may obtain recognition of its exemption by

completing one of the actions set forth in section 9.05 of this revenue procedure,

relating to subsequent recognition of exemption. (See section 9.06 of this revenue

procedure for subordinate organizations not required to apply for recognition of

exemption under § 505 or § 508.)

.02 Effect of termination. Except as provided in this section 9, if the IRS or a central

organization terminates a group exemption letter for all subordinate organizations, the

IRS will not thereafter recognize the exemption of any subordinate organization included

in the group exemption letter unless such subordinate organization completes one of

the actions described in section 9.05 of this revenue procedure, relating to subsequent

recognition of exemption. (See section 9.06 of this revenue procedure for subordinate

organizations not required to apply for recognition of exemption under § 505 or § 508.)

.03 Effect of removal. If the IRS or the central organization removes a subordinate

organization from a group exemption letter, the IRS will not thereafter recognize the

exemption of that subordinate organization unless such subordinate organization

completes one of the actions described in section 9.05 of this revenue procedure,

relating to subsequent recognition of exemption. (See section 9.06 of this revenue

procedure for subordinate organizations not required to apply for recognition of

exemption under § 505 or § 508.)

.04 Churches and conventions or associations of churches. The tax-exempt status

of any organization that is described in § 501(c)(3) that is a church or convention or

association of churches and is (1) included as a subordinate organization in a group

application that is not accepted or not issued, (2) part of a group exemption letter that is

terminated, or (3) removed from a group exemption letter in accordance with section 8

of this revenue procedure, will not be affected by such non-acceptance or non-issuance,

termination, or removal. See § 508(c)(1)(A).

.05 Subsequent recognition of exemption.

(1) In general. Notwithstanding sections 9.01, 9.02, and 9.03 of this revenue

procedure, and subject to section 9.07 of this revenue procedure, an organization that

(i) is included as a subordinate organization in a group application that is not accepted

or for which the IRS declines to issue a group exemption letter, (ii) is a subordinate

organization under a group exemption letter that is terminated, or (iii) is a subordinate

organization that is removed from a group exemption letter, may obtain recognition of

exemption by completing one of the actions described in this section 9.05, as

applicable.

(2) Organization required to file an application. An organization required to apply

for recognition of exemption under § 505 or § 508 that has not had its exemption

automatically revoked may obtain recognition of exemption by:

(a) Filing an application for which the IRS issues a favorable determination;

(b) In circumstances where a group application is not accepted or a group

exemption letter is not issued by the IRS, being included by the same central

organization in a new group application, if the group exemption letter is issued;

included by the same central organization in a new group application, if the group

exemption letter is issued;

(d) Being included by a different central organization in a new group application,

if the group exemption letter is issued;

(e) In circumstances where a subordinate organization is removed from a group

exemption letter, being added back to the group exemption letter from which it was

removed; or

(f) Being added to a group exemption letter maintained by a different central

organization.

(3) Organization not required to file an application. An organization (including a

church or convention or association of churches) that is not required to apply for

recognition of exemption under § 505 or § 508 and that has not had its exemption

automatically revoked may obtain recognition of its exemption in the same manner

described in section 9.05(2) of this revenue procedure, relating to procedures for an

organization required to apply for recognition of exemption under § 505 or § 508, but the

organization is not required to do so. An organization that intends to operate as an

organization described in § 501(c)(4) is required to submit a completed Form 8976 in

the manner described in Rev. Proc. 2016-41 (unless an exception applies).

.06 Subsequent exemption without recognition from the IRS. Notwithstanding

sections 9.01, 9.02, and 9.03 of this revenue procedure, and subject to section 9.07 of

this revenue procedure, an organization that is not required to apply for recognition of

exemption under § 505 or § 508 may qualify for tax-exempt status without applying for

recognition of exemption from the IRS, provided that the organization satisfies the

requirements for tax-exempt status and files annual information returns or notices

(unless an exception to the annual return or notice requirement applies). An

organization that intends to operate as an organization described in § 501(c)(4) is

required to submit a completed Form 8976 in the manner described in Rev. Proc. 201641 (unless an exception applies).

.07 Automatic revocation. If a subordinate organization’s exemption has been

automatically revoked, it must file an application for reinstatement to qualify for taxexempt status, regardless of whether the organization was originally required to apply

for recognition of exemption under § 505 or § 508. See § 6033(j)(2). An organization

whose exemption has been automatically revoked can be included in a new group

application as a subordinate organization or added to a group exemption letter as a

subordinate organization only after being reinstated pursuant to Rev. Proc. 2014-11.

See section 4.04(5) of this revenue procedure.

SECTION 10. EFFECTIVE DATE OF EXEMPTION

.01 Initial inclusion. If all the subordinate organizations included in a group

application were organized within 27 months of the submission date of the group

application, the effective date of exemption for each subordinate organization will be the

subordinate organization’s date of formation. If a group application includes one or

more subordinate organizations that were organized more than 27 months before the

submission date of the group application, the effective date of exemption for each

subordinate organization will generally be the submission date of the group application.

However, in this latter context, the effective date of exemption of a subordinate

organization that was recognized by the IRS as being described in § 501(c) or included

in another group exemption letter immediately prior to being included in a group

application will be the effective date of the organization’s exemption immediately prior to

being included in the group application. For purposes of this section 10, “immediately

prior” means that the organization was recognized by the IRS as being described in

§ 501(c) on the date the new group application is submitted.

.02 Subsequent addition. The effective date of exemption of an organization that is

subsequently added to a group exemption letter as a subordinate organization depends

on the organization’s tax-exempt status immediately prior to its addition to the group

exemption letter. If, at such time, the organization was recognized by the IRS as being

described in § 501(c), the effective date of exemption will be the effective date of the

organization’s exemption immediately prior to its addition to the group exemption letter

to which it is being added. If an organization is not recognized by the IRS as being

described in § 501(c) immediately prior to its addition to the group exemption letter, its

effective date of exemption will be its date of formation if the organization was organized

within 27 months of the submission date of the SGRI adding the organization to the

group exemption letter. Alternatively, if the organization was organized more than 27

months before the submission date of the SGRI adding the organization to the group

exemption letter, its effective date of exemption will be the submission date of the SGRI

adding it to the group exemption letter. Cf. section 6.09 of Rev. Proc. 2026-5 (or

corresponding section(s) of its successor).

.03 Non-acceptance, non-issuance, termination, or removal.

(1) In general. The effective date of exemption for any organization seeking

subsequent recognition of exemption in accordance with section 9.05 of this revenue

procedure depends on the action taken by such organization, as set forth in this section

10.03.

(2) Organizations filing an application.

(a) Non-acceptance or non-issuance. If the IRS does not accept a group

application, or if the IRS declines to issue a group exemption letter, and an organization

included in the group application as a subordinate organization subsequently files an

application, the effective date of exemption for the organization will be determined in

accordance with section 6.09 of Rev. Proc. 2026-5 (or corresponding section(s) of its

successor), provided that the organization otherwise meets the requirements for taxexempt status.

(b) Termination or removal.

(i) In general. If the IRS or a central organization terminates a group

exemption letter or if the IRS or a central organization removes a subordinate

organization from a group exemption letter and the subordinate organization

subsequently files an application, the effective date of exemption for such subordinate

organization will be determined under section 10.03(2)(b)(ii) or (iii) of this revenue

procedure, as applicable.

(ii) Application filed within 27 months of termination or removal. If an

organization included in a group exemption letter as a subordinate organization files an

application within 27 months of the date on which the group exemption letter was

terminated or the subordinate organization was removed from the group exemption

letter, the effective date of exemption for the subordinate organization will be the date

on which the group exemption letter was terminated or the subordinate organization

was removed from the group exemption letter, provided that the subordinate

organization otherwise meets the requirements for tax-exempt status.

(iii) Application filed more than 27 months after termination or removal. If an

organization included in a group exemption letter as a subordinate organization files an

application more than 27 months after the date on which the group exemption letter was

terminated or the subordinate organization was removed from the group exemption

letter, the effective date of exemption for the former subordinate organization will be the

submission date of its application, provided that the organization otherwise meets the

requirements for tax-exempt status.

(3) Organizations being included in a new group application. The effective date of

exemption for any subordinate organization described in section 9.05(2) or (3) of this

revenue procedure seeking recognition of exemption by being included in a new group

application by the same central organization or a different central organization is as set

forth in section 10.01 of this revenue procedure.

(4) Organizations being added to a group exemption letter. The effective date of

exemption for any subordinate organization seeking recognition of exemption by being

added back to the group exemption letter from which it was removed or by being added

to a group exemption letter maintained by a different central organization is as set forth

in section 10.02 of this revenue procedure.

(5) Automatic revocation. The effective date of exemption for an organization

whose exemption was automatically revoked and that files an application for

reinstatement is the effective date of the organization’s reinstatement, determined in

accordance with Rev. Proc. 2014-11. If the organization is subsequently included in a

new group application as a subordinate organization or added to a group exemption

letter as a subordinate organization, the organization’s effective date of exemption will

be determined pursuant to section 10.01 or 10.02 of this revenue procedure, as

applicable.

SECTION 11. DECLARATORY JUDGMENT PROVISIONS OF § 7428

.01 In general. Section 10 of Rev. Proc. 2026-5 (or corresponding section(s) of its

successor) generally explains when and how a declaratory judgment proceeding under

§ 7428 may be filed in the United States Tax Court, the United States Court of Federal

Claims, or the District Court of the United States for the District of Columbia.

.02 Who must file. An organization must file a declaratory judgment action under

§ 7428 on its own behalf. Thus, a subordinate organization must file a declaratory

judgment action under § 7428 regarding an IRS determination affecting the subordinate

organization’s initial or continuing qualification or classification. (A central organization

cannot file a declaratory judgment action under § 7428 on behalf of one or more of its

subordinate organizations.) Similarly, a subordinate organization cannot file a

declaratory judgment action under § 7428 on behalf of its central organization. For

more information on the application of § 7428, see section 10 of Rev. Proc. 2026-5 (or

corresponding section(s) of its successor).

SECTION 12. APPLICABILITY

.01 New group exemption letters. This revenue procedure applies to group

exemption letters applied for after January 20, 2026.

.02 Preexisting group exemption letters.

(1) In general. Except as otherwise provided in this section 12.02, this revenue

procedure applies to:

(a) all central organizations with one or more preexisting group exemption letters;

(b) preexisting subordinate organizations; and

after the publication date.

(2) Transition period for certain requirements applicable to preexisting group

exemption letters and preexisting subordinate organizations.

(a) In general. Certain provisions of this revenue procedure do not apply to

preexisting group exemption letters and preexisting subordinate organizations during

the period that begins on the publication date and ends on January 22, 2027 (transition

period). The sections of this revenue procedure described in this section 12.02(2) do

not apply to preexisting group exemption letters and preexisting subordinate

organizations during the transition period:

(i) Section 4.01(2) of this revenue procedure, providing that a central

organization must have at least one subordinate organization to maintain a group

exemption letter;

(ii) Section 4.01(3) of this revenue procedure, providing that a central

organization can maintain only one group exemption letter;

(iii) Section 4.02 of this revenue procedure, describing the central

organization’s relationship with its subordinate organizations, as it relates to the

affiliation and general supervision or control requirements between a central

organization and its preexisting subordinate organizations; and

(iv) Section 4.03(2)(a) of this revenue procedure, providing that all subordinate

organizations initially included in a group application, or subsequently added to a group

exemption letter must be described in the same paragraph of § 501(c).

(b) Minimum number of subordinate organizations. Before the end of the

transition period, a central organization that has a preexisting group exemption letter but

does not have at least one subordinate organization must either:

(i) add at least one subordinate organization to its group exemption letter in

accordance with section 7.02(2)(a)(iv) of this revenue procedure, or

(ii) terminate the group exemption letter in accordance with section 8.01(2) of

this revenue procedure.

period, a central organization that maintains more than one preexisting group exemption

letter must terminate either all or all but one of its preexisting group exemption letters.

The central organization must choose which, if any, preexisting group exemption letter it

intends to maintain. The central organization must provide the IRS copies of all its

preexisting group exemption letters and terminate the preexisting group exemption

letters it does not intend to maintain in accordance with section 8.01(2) of this revenue

procedure.

(d) Central organization’s relationship with its subordinate organizations. Before

the end of the transition period, a central organization must ensure that each preexisting

subordinate organization is affiliated with and subject to its general supervision or

control, within the meaning of section 4.02(2) and (3) or 4.02(4) of this revenue

procedure. If a central organization is unable to ensure that a preexisting subordinate

organization is affiliated with and subject to its general supervision or control, it must

remove the subordinate organization from the group exemption letter in accordance with

section 8.02(2) of this revenue procedure.

(e) Preexisting subordinate organizations described in different paragraphs of

§ 501(c). Before the end of the transition period, a central organization that has a

preexisting group exemption letter that includes preexisting subordinate organizations

that are described in a paragraph of § 501(c) that is not the paragraph specified in the

group application must remove the preexisting subordinate organizations that are not

described in the paragraph of § 501(c) specified in the group application, in accordance

with section 8.02(2) of this revenue procedure.

(f) Timing of actions. The actions required under this section 12.02(2) are

accomplished through SGRI submissions and must be completed before the transition

period ends on January 22, 2027.

(3) Certain requirements not applicable to preexisting subordinate organizations.

The sections of this revenue procedure described in this section 12.02(3) do not apply

to preexisting subordinate organizations:

(a) Section 4.03(2)(b) of this revenue procedure, regarding the requirement that

subordinate organizations sharing the same purpose have a uniform purpose

statement;

(b) Section 4.04(3) of this revenue procedure, providing that a Type III supporting

organization cannot be a subordinate organization;

health insurance issuer described in § 501(c)(29) cannot be a subordinate organization;

and

(d) Section 4.06(2) of this revenue procedure, regarding the requirement that the

authorization for initial inclusion in a group application, or subsequent addition to a

group exemption letter, described in section 4.06(1) of this revenue procedure

acknowledge that the central organization may remove the subordinate organization

from the group exemption letter with or without cause.

.03 Examples. The application of this section 12 is illustrated by the following

examples.

(1) Example 1. Two preexisting group exemption letters for subordinate

organizations described in different paragraphs of § 501(c). Central organization B has

two preexisting group exemption letters, one for subordinate organizations described in

§ 501(c)(3) and one for subordinate organizations described in § 501(c)(4). Under

section 4.01(3) of this revenue procedure, a central organization may maintain only one

preexisting group exemption letter. This requirement, however, does not apply until

after the transition period (see section 12.02(2)(a)(ii) of this revenue procedure).

Assuming B intends to maintain one of the two preexisting group exemption letters,

before the end of the transition period B must identify the preexisting group exemption

letter it intends to retain, provide copies of both group exemption letters to the IRS, and

notify the IRS of the group exemption letter it will terminate. B (and not the IRS) is

responsible for informing the subordinate organizations under the terminated group

exemption letter that they may obtain recognition of exemption by taking an action

described in section 9.05 of this revenue procedure (see section 9.02 of this revenue

procedure, regarding the effect of termination).

(2) Example 2. One preexisting group exemption letter with no subordinate

organizations. Central organization C has a single preexisting group exemption letter

for subordinate organizations described in § 501(c)(3), but it currently does not have

any subordinate organizations under the preexisting group exemption letter. Under

section 4.01(2) of this revenue procedure, a central organization must have at least one

subordinate organization to maintain a group exemption letter. This requirement,

however, does not apply to preexisting group exemption letters until after the transition

period (see section 12.02(2)(a)(i) of this revenue procedure). Before the end of the

transition period, C must either add at least one subordinate organization described in

§ 501(c)(3) to the preexisting group exemption letter or notify the IRS that it will

terminate the preexisting group exemption letter (see section 12.02(2)(b) of this revenue

procedure). If C adds a subordinate organization to the preexisting group exemption

letter, C must submit the SGRI described in section 7.02(3) of this revenue procedure

before the end of the transition period. The subordinate organization that is added to

the preexisting group exemption letter is not a preexisting subordinate organization.

Accordingly, the requirements of section 4 of this revenue procedure (regarding the

requirements to obtain and maintain a group exemption letter) apply, other than section

4.01 of this revenue procedure. In addition, because the subordinate organization that

is added to the preexisting group exemption letter is not a preexisting subordinate

organization, sections 12.02(2)(a)(iii) and (iv) and 12.02(3) of this revenue procedure do

not apply.

(3) Example 3. One preexisting group exemption letter with subordinate

organizations described in different paragraphs of § 501(c). Central organization D has

a preexisting group exemption letter with multiple subordinate organizations. The group

application D filed pursuant to Rev. Proc. 80-27 stated that the subordinate

organizations would be described in § 501(c)(3). In addition to subordinate

organizations described in § 501(c)(3), some of the subordinate organizations under the

preexisting group exemption letter are described in § 501(c)(4). Under section

4.03(2)(a) of this revenue procedure, all subordinate organizations must be described in

the same paragraph of § 501(c). Before the end of the transition period, D must remove

the subordinate organizations described in § 501(c)(4), in accordance with the removal

provision in section 8.02(2) of this revenue procedure.

(4) Example 4. One preexisting group exemption letter with preexisting

subordinate organizations described in the same paragraph of § 501(c). Central

organization E has a preexisting group exemption letter for subordinate organizations

described in § 501(c)(3). The preexisting group exemption letter has more than one

preexisting subordinate organization. E is not required to make any changes to the

group exemption letter during the transition period provided it has at least one

subordinate organization, all the subordinate organizations are described in the same

paragraph of § 501(c), and E’s relationship with its subordinate organizations, as it

relates to the affiliation and general supervision or control requirements, satisfies the

requirements of section 4.02 of this revenue procedure. The preexisting subordinate

organizations are subject to the requirements of this revenue procedure except as set

forth in section 12.02(3) of this revenue procedure. If E adds a subordinate organization

to the preexisting group exemption letter after the publication date, E must submit the

SGRI described in section 7.02(3) of this revenue procedure. The subordinate

organization that is added to the preexisting group exemption letter is not a preexisting

subordinate organization. Accordingly, the requirements in section 4 of this revenue

procedure (regarding the requirements to obtain and maintain a group exemption letter)

apply to the subordinate organization that is added to the preexisting group exemption

letter, other than section 4.01 of this revenue procedure. Furthermore, because the

subordinate organization that is added to the preexisting group exemption letter is not a

preexisting subordinate organization, sections 12.02(2)(a)(iii) and (iv) and 12.02(3) of

this revenue procedure do not apply.

(5) Example 5. Removal of a preexisting subordinate organization from a

preexisting group exemption letter. Central organization F has a preexisting group

exemption letter for subordinate organizations described in § 501(c)(3). There are

multiple preexisting subordinate organizations under the preexisting group exemption

letter. F removed one preexisting subordinate organization from the preexisting group

exemption letter for failure to comply with one or more of the requirements of this

revenue procedure. Under section 8.02(4) of this revenue procedure, the preexisting

group exemption letter remains effective for all preexisting subordinate organizations

that were not removed. Pursuant to section 9.05(2)(e) of this revenue procedure, the

preexisting subordinate organization that was removed from the preexisting group

exemption letter may obtain recognition of its exemption by being added back to the

preexisting group exemption letter; however, if the preexisting subordinate organization

was automatically revoked, it must be reinstated pursuant to Rev. Proc. 2014-11 first

(see section 9.07 of this revenue procedure). If F adds the organization that was

removed back to the preexisting group exemption letter, the organization that is added

back to the preexisting group exemption letter is not a preexisting subordinate

organization under the definition preexisting subordinate organization in section 3.10 of

this revenue procedure. Accordingly, the requirements of section 4 of this revenue

procedure (regarding the requirements to obtain and maintain a group exemption letter)

apply to the organization that is added back to the preexisting group exemption letter,

other than section 4.01 of this revenue procedure. Furthermore, because the

organization that is added back to the preexisting group exemption letter is not a

preexisting subordinate organization, sections 12.02(2)(a)(iii) and (iv) and 12.02(3) of

this revenue procedure do not apply.

SECTION 13. PAPERWORK REDUCTION ACT

The Paperwork Reduction Act of 1995 (44 U.S.C. 3501-3520) (PRA) generally

requires that a Federal agency obtain the approval of the Office of Management and

Budget (OMB) before collecting information from the public, whether such collection of

information is mandatory, voluntary, or required to obtain or retain a benefit. An agency

may not conduct or sponsor, and a person is not required to respond to, a collection of

information unless it displays a valid control number assigned by the Office of

Management and Budget.

The collections of information included in this revenue procedure are reporting and

third-party disclosures in sections 6, 7, and 8 of this revenue procedure. The

information in section 6 of this revenue procedure is required to be submitted by the

central organization to obtain a group exemption letter. This information will be used to

determine whether a central organization may obtain recognition of exemption from

federal income tax on a group basis for organizations described in § 501(c) that are

affiliated with and under its general supervision or control. The information in section 7

of this revenue procedure is required to be submitted by the central organization

annually to maintain a group exemption letter. The information in section 8 of this

revenue procedure is required for a central organization to inform the subsidiaries of a

revocation by the IRS or the organization, and for a central organization to inform the

IRS of a decision to revoke a group exemption. This information will be used to allow

the IRS to maintain up to date records regarding group exemption letters and to ensure

compliance with the requirements of this revenue procedure. The collections of

information are required to obtain a benefit. The likely respondents are central

organizations that are tax-exempt organizations and their authorized representatives.

The estimated annual frequency of responses (used for reporting requirements only)

is once for group applications and annually for SGRI submissions. Books or records

relating to a collection of information must be retained as long as their contents may

become material in the administration of any internal revenue law. Generally, tax

returns and tax return information are confidential, as required by § 6103.

The collections contained in this revenue procedure have been submitted to the

Office of Management and Budget for approval in accordance with the 5 CFR 1320.10,

under OMB Control Number 1545-0047.

SECTION 14. EFFECT ON OTHER REVENUE PROCEDURES

.01 Rev. Proc. 80-27 (as modified by Rev. Proc. 96-40) is modified and superseded.

.02 Section 2.02(1) of Rev. Proc. 2026-5 is modified to cite this revenue procedure in

lieu of Rev. Proc. 80-27.

.03 Rev. Proc. 2026-5 is modified by deleting all provisions referring to the IRS not

accepting requests for group exemption letters, including section 3.02(11) of Rev. Proc.

2026-5, and any internal references to section 3.02(11) of Rev. Proc. 2026-5

SECTION 15. EFFECTIVE DATE

This revenue procedure is effective on and after January 20, 2026.

SECTION 16. DRAFTING INFORMATION

The principal author of this revenue procedure is Seth J. Groman of the Office of

Associate Chief Counsel (Employee Benefits, Exempt Organizations, and Employment

Taxes). For further information regarding this revenue procedure contact Seth J.

Groman on (202) 317-5640 (not a toll-free call).

This is a copy of a public record, reproduced as it was published. It is not legal advice, and it may not be the version a court would rely on. Check the official source before you cite it.