SECTION 2. BACKGROUND

.01 Section 508 provides special rules with respect to organizations described in § 501(c)(3), including the general requirement in § 508(a) that organizations must notify the Secretary of the Treasury or the Secretary’s delegate (Secretary) that they are applying for recognition of § 501(c) (3) status. Section 505 provides additional requirements for organizations described in § 501(c)(9) or (17), including the general requirement in § 505(c) that organizations must notify the Secretary that they

are applying for recognition of exemption under § 501(c)(9) or (17). Sections 1.508-1(a)(1) and 1.505(c)-1T provide additional information regarding the way the notice required under §§ 508(a) and 505(c) is given to the Internal Revenue Service (IRS). Organizations described in other paragraphs of § 501(c), such as social welfare organizations described in § 501(c)(4), may, but are not required to, apply for recognition of exemption. However, § 506 generally requires an organization described in § 501(c)(4) to notify the Secretary, in the manner prescribed in § 1.506-1, of the organization’s intent to operate as such no later than 60 days after the organization is established.

.02 Section 508(c)(2)(B) permits the Secretary, by regulation, to except organizations from the § 508(a) notice requirement if the Secretary determines that full compliance is not necessary for the efficient administration of the provisions relating to private foundations.

.03 Section 1.508-1(a)(3)(i) provides that the § 508(a) notice requirement does not apply to specific types of organizations, including subordinate organizations included in a group exemption letter.

.04 Rev. Proc. 68-13, 1968-1 C.B. 764, superseded by Rev. Proc. 72-41, 1972-2 C.B. 820, Rev. Proc. 77-38, 1977-2 C.B. 571, and Rev. Proc. 80-27, set forth the first published procedures for obtaining recognition of exemption from federal

income tax on a group basis for organizations described in § 501(c). The most recent guidance regarding group exemption letters is set forth in Rev. Proc. 80-27, as modified by Rev. Proc. 96-40.

.05 Rev. Proc. 2018-32, 2018-23 I.R.B. 739, sets forth the extent to which grantors and contributors may rely on the listing of a central organization in IRS databases of organizations eligible to receive tax-deductible contributions under § 170, for purposes of determining whether the grants or contributions to the organization may be deductible under § 170.

.06 In Notice 2020-36, 2020-21 I.R.B. 840, the Department of the Treasury (Treasury Department) and the IRS invited comments regarding a proposed revenue procedure that, if finalized, would modify and supersede Rev. Proc. 80-27 by setting forth updated procedures for obtaining recognition of exemption from federal income tax on a group basis for subordinate organizations described in § 501(c), including transition relief for existing organizations. The Treasury Department and the IRS received 29 comments in response to Notice 2020-36.

.07 After considering the comments received in response to Notice 2020-36, the Treasury Department and the IRS issue this revenue procedure to reduce the administrative burden and increase the efficiency of the group exemption letter program, improve the integrity of data

1 Unless otherwise specified, all “section” or “§” references are to sections of the Code or the Income Tax Regulations (26 CFR part 1).

January 20, 2026 382 Bulletin No. 2026–4

collected for purposes of oversight of the group exemption letter program, increase the transparency of the group exemption letter program, and increase compliance by central organizations and subordinate organizations with requirements of the group exemption letter program. This revenue procedure also provides greater certainty and clarity to central organizations and subordinate organizations under existing group exemption letters and organizations that file an application for a group exemption letter after the date of publication of this revenue procedure in the Internal Revenue Bulletin (publication date).

.08 Notice 2020-36 provides that the IRS will not accept applications for group exemption letters on or after June 17, 2020, until publication of the final revenue procedure or other guidance in the Internal Revenue Bulletin. The IRS will resume accepting applications for group exemption letters after January 20, 2026, the publication date.