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Introduction

SECTION 5. RELIANCE ON TAX

Internal Revenue Bulletin 2018-23 · 2026-10-03 edition · updated 2026-10-04 · United States

EXEMPT ORGANIZATION SEARCH (PUB. 78 DATA) AND THE EO BMF EXTRACT FOR PUBLIC CHARITY STATUS

.01 General Reliance Rule .

If an organization listed in or covered by Tax Exempt Organization Search (Pub. 78 data) or the EO BMF as a public charity ceases to qualify as a public charity and the IRS revokes a determination letter or ruling classifying the organization as a public charity, grantors and contributors to that organization may generally rely on the classification information provided in Tax Exempt Organization Search (Pub. 78 data) or the EO BMF Extract for contribution and grant purposes until the date of a public announcement stating that the organization ceases to qualify as a public charity. Grantors and contributors may also rely on any classification of an organization as a Type I, Type II, or Type III functionally or non-functionally integrated supporting organization in Tax Exempt Organization Search (Pub. 78 data) and the EO BMF Extract. Private foundations and sponsoring organizations of donor-advised funds may rely on an organization’s public charity status (or supporting organization type), to the extent set forth in Tax Exempt Organization Search (Pub. 78 data) or the EO BMF Extract, for grant making purposes under §§ 4942, 4945, and 4966, until the date of a public announcement stating that the organization ceases to qualify as a public charity.

The IRS will also issue to a tax-exempt organization an affirmation letter to reflect a name or address change of the tax-exempt organization. See section 3.01(2) of Rev. Proc. 2018–5, 2018–1 I.R.B. 235, or the corresponding provision of any successor revenue procedure.

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