SECTION 12. RELIANCE

.01 By a central or subordinate orga- nization. In general, a central organization and its subordinate organizations may rely on a group exemption letter that continues to meet the requirements of this revenue procedure (except as provided in section 14.02(2) of this revenue procedure, which provides a transition period for preexisting group exemption letters). However,

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see section 11.02 of Rev. Proc. 2020-5 (or its successor) regarding limitations on reliance.

.02 By grantors and contributors. To verify that contributions to a subordinate organization are deductible under § 170, a donor should consult the central organization’s listing in Tax Exempt Organization Search (Pub. 78 Data), which will indicate that contributions to its subordinate organizations are also deductible. Section 3.02 of Rev. Proc. 2018-32, 2018-23 I.R.B. 739. The donor should then confirm that the subordinate organization is covered by the group exemption letter by contacting the central organization. See generally section 6.03 of Rev. Proc. 2018-32. Donors may rely on the central organization’s written verification with respect to deductibility of contributions to one or more subordinate organizations included in a group exemption letter.