SECTION 6. CERTAIN
Internal Revenue Bulletin 2018-23 · 2026-10-03 edition · updated 2026-10-04 · United States
LIMITATIONS ON TAX-EXEMPT AND PUBLIC CHARITY STATUS RELIANCE
.01 Reliance Provisions Apply Only to Certain Names of Organization .
The reliance on tax-exempt and public charity status provided by sections 4 and 5 of this revenue procedure applies only to grants or contributions made to an organization listed in or covered by Tax Exempt Organization Search (Pub. 78 data) or the EO BMF Extract in the organization’s official name, its recognized popular name, or a contraction of either of these names that is reasonably identifiable or widely known. The reliance on tax-exempt and public charity status provided by sections 4 and 5 of this revenue procedure does not apply to contributions or grants made nominally to an organization listed in or covered by Tax Exempt Organization Search (Pub. 78 data) or the EO BMF Extract but with the understanding or on a condition that they be made available to or for the use of an organization not listed in or covered by Tax Exempt Organization Search (Pub. 78 data) or the EO BMF Extract.
.02 Reliance Provisions Do Not Apply to Organizations Until They Are Listed in or Covered by Tax Exempt Organization Search (Pub. 78 Data) or the EO BMF Extract .
The provisions of sections 4 and 5 of this revenue procedure do not apply to an
organization until it is listed in or covered by Tax Exempt Organization Search (Pub. 78 data) or the EO BMF Extract.
.03 Reliance Provisions Do Not Apply to Subordinate Organizations .
The reliance on tax-exempt and public charity status provided by sections 4 and 5 of this revenue procedure does not apply to a subordinate organization covered by a group exemption letter regardless of whether the subordinate organization appears in the EO BMF Extract. For further information concerning reliance on group exemptions, consult the official subordinate listing approved by the listed central organization or contact the central organization directly. See Publication 4573, Group Exemptions.
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