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Rev. Proc. 2026-8

SECTION 5. CONSIDERATION OF

Internal Revenue Bulletin 2026-4 · 2026-10-03 edition · updated 2026-10-04 · United States

GROUP APPLICATIONS

.01 Group applications. The IRS will consider group applications that meet the requirements of section 6 of this revenue procedure.

.02 Non-acceptance. A group application that is missing any information required by section 6 of this revenue procedure or Rev. Proc. 2026-5 (or its successor) will be deemed incomplete and will not be accepted for processing by the IRS.

.03 Circumstances under which group exemption letters are not ordinarily issued. The IRS may decline to issue a group exemption letter if it is not in the interest of sound tax administration. For example, the IRS may decline to issue a group exemption letter if the activities described in the group application involve complex facts and circumstances that are more appropriately evaluated on an organization-by-organization basis.

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▸Contents — Internal Revenue Bulletin 2026-4

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