# Administrative, Procedural, and Miscellaneous

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URL: https://www.frixlaw.com/law-library/documents/agency%3Airs%3Ab3a35be484f308a0

## Record

- **Collection:** Agency decision
- **Document type:** Agency decision

## Text

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

2
.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

3
.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

4
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).

5
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

6
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

7
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

8
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

9
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

10
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

11
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

12
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.
(c) Exception for subordinate organizations not required to file annual information
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;

13
(c) The subordinate organization’s directors or trustees possessing a majority of
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

14
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.
(c) A exercises general supervision over A’s subordinate organizations that are
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

15
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

16
the subordinate organizations.
(c) Annual accounting period requirement. Subordinate organizations included
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

17
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

18
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-

19
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:

20
(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;
(c) A representation that the subordinate organizations are all described in the
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

21
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

22
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.
(c) Social welfare organizations. If the group application involves subordinate
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

23
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

24
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

25
list.
(c) No annotated directories. An annotated directory of subordinate
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;
(c) A statement that the central organization has written authorization to include
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.

26
(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.

27
.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).
(c) The central organization’s exemption is automatically revoked.
(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

28
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

29
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

30
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-

31
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

32
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;
(c) In circumstances where a group exemption letter is terminated, being

33
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

34
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.

35
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).

36
.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

37
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

38
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

39
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
(c) subordinate organizations added to preexisting group exemption letters on or
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;

40
(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.
(c) More than one group exemption letter. Before the end of the transition
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

41
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

42
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;
(c) Section 4.04(4) of this revenue procedure, providing that a qualified nonprofit
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

43
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

44
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

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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

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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.

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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

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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

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Taxes). For further information regarding this revenue procedure contact Seth J.
Groman on (202) 317-5640 (not a toll-free call).

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Source: Frix Law Library, https://www.frixlaw.com/law-library/documents/agency%3Airs%3Ab3a35be484f308a0. Public record. Not legal advice.