SECTION 10. EFFECTIVE DATE OF

EXEMPTION

.01 Initial inclusion. If all the subordinate organizations included in a group application were organized within 27 months of the submission date of the group application, the effective date of exemption for each subordinate organization will be the subordinate organization’s date of formation. If a group application includes one or more subordinate organizations that were organized more than 27 months before the submission date of the group application, the effective date of exemption for each subordinate organization will generally be the submission date of the group application. However, in this latter context, the effective date of exemption of a subordinate organization that was

Bulletin No. 2026–4 389 January 20, 2026

recognized by the IRS as being described in § 501(c) or included in another group exemption letter immediately prior to being included in a group application will be the effective date of the organization’s exemption immediately prior to being included in the group application. For purposes of this section 10, “immediately prior” means that the organization was recognized by the IRS as being described in § 501(c) on the date the new group application is submitted.

.02 Subsequent addition. The effective date of exemption of an organization that is subsequently added to a group exemption letter as a subordinate organization depends on the organization’s tax-exempt status immediately prior to its addition to the group exemption letter. If, at such time, the organization was recognized by the IRS as being described in § 501(c), the effective date of exemption will be the effective date of the organization’s exemption immediately prior to its addition to the group exemption letter to which it is being added. If an organization is not recognized by the IRS as being described in § 501(c) immediately prior to its addition to the group exemption letter, its effective date of exemption will be its date of formation if the organization was organized within 27 months of the submission date of the SGRI adding the organization to the group exemption letter. Alternatively, if the organization was organized more than 27 months before the submission date of the SGRI adding the organization to the group exemption letter, its effective date of exemption will be the submission date of the SGRI adding it to the group exemption letter. Cf. section 6.09 of Rev. Proc. 2026-5 (or corresponding section(s) of its successor).

.03 Non-acceptance, non-issuance, ter- mination, or removal.

(1) In general. The effective date of exemption for any organization seeking subsequent recognition of exemption in accordance with section 9.05 of this revenue procedure depends on the action taken by such organization, as set forth in this section 10.03.

(2) Organizations filing an application . (a) Non-acceptance or non-issuance. If the IRS does not accept a group application, or if the IRS declines to issue a group exemption letter, and an organiza

tion included in the group application as a subordinate organization subsequently files an application, the effective date of exemption for the organization will be determined in accordance with section 6.09 of Rev. Proc. 2026-5 (or corresponding section(s) of its successor), provided that the organization otherwise meets the requirements for tax-exempt status.

(b) Termination or removal. (i) In general . If the IRS or a central organization terminates a group exemption letter or if the IRS or a central organization removes a subordinate organization from a group exemption letter and the subordinate organization subsequently files an application, the effective date of exemption for such subordinate organization will be determined under section 10.03(2)(b)(ii) or (iii) of this revenue procedure, as applicable.

(ii) Application filed within 27 months of termination or removal. If an organization included in a group exemption letter as a subordinate organization files an application within 27 months of the date on which the group exemption letter was terminated or the subordinate organization was removed from the group exemption letter, the effective date of exemption for the subordinate organization will be the date on which the group exemption letter was terminated or the subordinate organization was removed from the group exemption letter, provided that the subordinate organization otherwise meets the requirements for tax-exempt status.

(iii) Application filed more than 27 months after termination or removal. If an organization included in a group exemption letter as a subordinate organization files an application more than 27 months after the date on which the group exemption letter was terminated or the subordinate organization was removed from the group exemption letter, the effective date of exemption for the former subordinate organization will be the submission date of its application, provided that the organization otherwise meets the requirements for tax-exempt status.

(3) Organizations being included in a new group application. The effective date of exemption for any subordinate organization described in section 9.05(2) or (3) of this revenue procedure seeking recognition of exemption by being included in a

new group application by the same central organization or a different central organization is as set forth in section 10.01 of this revenue procedure.

(4) Organizations being added to a group exemption letter. The effective date of exemption for any subordinate organization seeking recognition of exemption by being added back to the group exemption letter from which it was removed or by being added to a group exemption letter maintained by a different central organization is as set forth in section 10.02 of this revenue procedure.

(5) Automatic revocation. The effective date of exemption for an organization whose exemption was automatically revoked and that files an application for reinstatement is the effective date of the organization’s reinstatement, determined in accordance with Rev. Proc. 2014-11. If the organization is subsequently included in a new group application as a subordinate organization or added to a group exemption letter as a subordinate organization, the organization’s effective date of exemption will be determined pursuant to section 10.01 or 10.02 of this revenue procedure, as applicable.