SECTION 5. EFFECT OF
Internal Revenue Bulletin 2015-7 · 2026-10-03 edition · updated 2026-10-04 · United States
DETERMINATION LETTER OR RULING RECOGNIZING EXEMPTION
A determination letter or ruling recognizing exemption under § 501(c)(29) is usually effective as of the later of the date of the QNHII’s formation or March 23, 2010 (the date of enactment of the Affordable Care Act) if:
The QNHII’s purposes and activities prior to the date of issuance of the determination letter or ruling were consistent with the requirements for exemption; and
The QNHII submits a substantially completed letter application within 15
February 17, 2015 600 Bulletin No. 2015–7
months of the date of its fully executed Loan Agreement with CMS. If the Service requires the QNHII to alter its activities or make substantive amendments to its enabling instrument, exemption will be recognized effective as of the date specified in the determination letter or ruling. If the Service requires the QNHII to make a nonsubstantive amendment, exemption will ordinarily be recognized as of the later of the date of the QNHII’s formation or March 23, 2010.
If a QNHII does not submit a substantially completed letter application within 15 months of the date of its fully executed Loan Agreement with CMS, it may not
qualify for exempt status before the postmark date of the letter application.
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