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Rev. Proc. 80-27 does not address the

SECTION 5. INSTRUCTIONS FOR

Internal Revenue Bulletin 2020-21 · 2026-10-03 edition · updated 2026-10-04 · United States

REQUESTING A GROUP EXEMPTION LETTER

.01 Group exemption letter request. A group exemption letter request must be made in the manner described by Rev. Proc. 2020-5 (or its successor). In addition, the group exemption letter request must include all of the information described in sections 5.02, 5.03, and, if applicable, 5.04 of this revenue procedure. A subordinate organization included in a group exemption letter should not apply separately for recognition of exemption (except in the circumstances described in section 9 of this revenue procedure).

.02 Information about the central or- ganization. The central organization must

May 18, 2020 852 Bulletin No. 2020–21

(f) A summary of the subordinate organizations’ purposes and activities, including the sources of their receipts and the nature of their expenditures.

(g) A representation that the primary purpose of all the subordinate organizations described in § 501(c) (other than § 501(c)(3)) is described by the same NTEE code and the NTEE code describing the subordinate organizations’ primary purpose (see section 3.03(2)(c) of this revenue procedure).

(h) A statement that each subordinate organization has furnished written authorization described in section 3.05 of this revenue procedure to the central organization.

(i) A statement confirming that all subordinate organizations were organized within 27 months of the postmark date of the group exemption letter request, or, if any such subordinate organizations have been organized for more than 27 months and were not previously recognized by the IRS as being described in § 501(c) or included in a different group exemption letter, a statement that all subordinate organizations are willing to be recognized as exempt from the postmark date of the group exemption letter request (see section 10.01 of this revenue procedure).

(j) If applicable, a statement that any subordinate organizations on behalf of which the central organization will file group returns, as described in section 7.02 of this revenue procedure, are on the same accounting period as the central organization.

(2) Supporting information. The central organization must provide the following supporting information as attachments:

(a) A sample copy of the uniform governing instrument or, if the subordinate organizations are described in § 501(c)(3) and have different purposes, sample copies of the uniform instrument describing each distinct purpose (see section 3.03(2) (d) of this revenue procedure).

(b) A list of the names, mailing addresses, EINs, and dates of formation or incorporation of subordinate organizations to be included in the group exemption letter (a current directory of subordinate organizations may be furnished in lieu of the list if it includes the required information and if the subordinate organizations to be

included in the group exemption letter are identified).

(c) If applicable, a list of subordinate organizations to be included in the group exemption letter to which the IRS has issued determination letters that are still effective (that is, have not been automatically or otherwise revoked).

(3) Additional requirements. In certain cases, the central organization must submit information establishing that its subordinate organizations meet additional requirements. For example, a central organization with subordinate organizations that are private schools, charitable hospitals, or social welfare organizations must submit the information described in this section 5.03(3), as applicable, in addition to the information generally required by section 5 of this revenue procedure.

(a) Private schools. If the group exemption letter request involves subordinate organizations that are or will be private schools described in § 501(c)(3), the central organization must include the information required by Rev. Proc. 7550, 1975-2 C.B. 587, as modified by Rev. Proc. 2019-22, 2019-22 I.R.B. 1260, and such other information necessary to establish that the subordinate organizations comply with the requirements of Rev. Rul. 71-447, 1971-2 C.B. 230. (b) Charitable hospitals. If the group exemption letter request involves subordinate organizations that are or will be hospital organizations or facilities described in § 501(c)(3), the central organization must provide the information necessary to establish that each subordinate organization meets the requirements of § 501(r) and Rev. Rul. 69-545, 1969-2 C.B. 117.

(c) Social welfare organizations. A subordinate organization described in § 501(c)(4) that is included in or subsequently added to a group exemption letter must, no later than 60 days after the date on which the organization was formed as a legal entity, submit a completed electronic Form 8976 to the IRS in the manner described in Rev. Proc. 2016-41, 2016-30 I.R.B. 165 (unless an exception applies). A subordinate organization may authorize an individual representing the central organization to submit Form 8976 on the subordinate organization’s behalf and to receive any communications relating to the subordinate organization’s submis

sion. In its request for the group exemption letter, the central organization must represent that each subordinate organization described in § 501(c)(4) has submitted or will submit Form 8976 (unless an exception applies).

.04 Request for a new group exemp- tion letter after the termination of a group exemption letter. If the IRS terminates a group exemption letter as described in section 8.01(1) of this revenue procedure, the central organization may request a new group exemption letter in the manner described in sections 5.01 through 5.03 of this revenue procedure, but also must include a description of the policies or procedures it intends to implement or has implemented to ensure the continued effectiveness of the new group exemption letter.

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