roup Exemptions | 2
What must a request for a group exemption contain?
The central organization submits a letter to the IRS on behalf of itself and its subordinates. The letter includes:
a. Information verifying the existence of the required relationship;
b. A sample copy of a uniform governing instrument (such as a charter, trust indenture or articles of association) adopted by the
subordinates;
c. A detailed description of the subordinates' purposes and activities including the sources of receipts and the nature of expenditures;
d. An afrmation by a principal ofcer that, to the best of the ofcer’s knowledge, the subordinates' purposes and activities are as
stated in (b) and (c) above;
e. A statement that each subordinate to be included in the group exemption letter has furnished written authorization to the central
organization;
f. A list of subordinates to be included in the group exemption letter to which the IRS has issued an outstanding ruling or determination
letter relating to exemption;
g. If the application for a group exemption letter involves IRC 501(c)(3), an afrmation to the effect that, to the best of the ofcer’s
knowledge and belief, no subordinate to be included in the group exemption letter is a private foundation as dened in IRC 509(a);
h. For each subordinate that is a school claiming exemption under IRC 501(c)(3), the information required by Rev. Proc. 75-50, 1975-2
C.B. 587 (as modied by Rev. Proc. 2019-22, 2019-22 I.R.B 1260) and Revenue Ruling 71-447, 1971-2 C.B. 230; and
i. A list of the names, mailing addresses (including ZIP Code), actual addresses (if different) and employer identication numbers of
subordinates to be included in the group exemption letter. A current directory of subordinates may be furnished in lieu of the list if it
includes the required information and if the subordinates not to be included in the group exemption letter are identied.
The rules for applying for a group exemption are set forth in Rev. Proc. 80-27, 1980-1 C.B. 677.
How does the group exemption process work?
Upon receipt of an application Form 1023, 1024 or 1024-A and a request for group exemption, the IRS rst determines whether the
central organization and the existing subordinates qualify for tax exemption. Once the IRS grants the exemption, the central organization
is responsible for:
1. Ensuring that its current subordinates continue to qualify to be exempt;
2. Verifying that any new subordinates are exempt; and
3. Updating the IRS annually of new subordinates, subordinates no longer to be included and subordinates that have changed their
names or addresses.
What is included in an annual update?
Annual updates must contain:
a. Information about changes in purposes, character or method of operation of subordinates included in the group exemption letter.
b. Lists of:
1. Subordinates that have changed their names or addresses during the year;
2. Subordinates no longer to be included in the group exemption letter because they have ceased to exist, disafliated or
withdrawn their authorization to the central organization; and
3. Subordinates to be added to the group exemption letter because they are newly organized or afliated or have newly authorized
the central organization to include them.
Each list must show the names, mailing address (including ZIP Codes), actual address (if different) and employer identication
numbers of the affected subordinates.
An annotated directory of subordinates will not be accepted for this purpose. If none of these changes occurred, the central
organization must submit a statement to that effect.
c. The same information about new subordinates that was required in the initial request. If a new subordinate does not differ in any
material respects from the subordinates included in the original request, however, a statement to this effect may be submitted in lieu
of detailed information.
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