Rev. Proc. 80-27 requires a subordinate organization to authorize the central

organization to include it in the request for a group exemption letter. Section 3.05(1) of the proposed revenue procedure retains this requirement, but section 3.05(2) of the proposed revenue procedure adds the requirement that the authorization permit the central organization to remove the subordinate organization from the group exemption letter if the subordinate organization fails to comply with the requirements of the proposed revenue procedure. Consistent with Rev. Proc. 80-27, section 3.05(3) of the proposed revenue procedure requires the central organization to retain the authorization but clarifies that the central organization must retain the authorization only while the group exemption letter includes the particular subordinate organization, rather than for the entire duration the group exemption letter is in effect.

(6) Information required to maintain a group exemption letter.

Both Rev. Proc. 80-27 and the proposed revenue procedure require a central organization to submit certain information (supplemental group ruling information, or SGRI) annually to maintain a group exemption letter. Under section 6.01 of the proposed revenue procedure, a central organization must submit the SGRI at least 30 days, rather than 90 days as required by Rev. Proc. 80-27, before the close of its annual accounting period. This change is intended to increase the accuracy of the SGRI submitted by the central organization. Nonetheless, the proposed revenue procedure explains that a central organization may provide additional updates at any time. Section 6.05 of the proposed revenue procedure includes the exception to the SGRI filing requirement originally included in Pub. 4573 for central organizations described in § 501(c)(3) that are churches or conventions or associations of churches. More specifically, section 6.05 of the proposed revenue procedure provides that a central organization that is a church or a convention or association of

churches may, but is not required to, submit the SGRI.

(7) Declaratory judgment provisions of § 7428.

In 1976, Congress enacted § 7428 to permit organizations described in § 501(c) (3) to file a declaratory judgment action in the case of an actual controversy involving determinations made by the IRS. See Tax Reform Act of 1976, Public Law 94455 (90 Stat. 1520 (1976)). The PATH Act extended application of § 7428 to all organizations described in § 501(c).