SECTION 6. INSTRUCTIONS — Internal Revenue Bulletin 2026-4

FOR SUBMITTING A GROUP APPLICATION

.01 Group applications. A group application must meet the requirements of this section 6. A subordinate organization included in a group application should not apply separately for recognition of exemption (except in the circumstances described in section 9 of this revenue procedure, regarding the effect of non-acceptance, non-issuance, termination, or removal).

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(o) If the central organization will file a group return on behalf of two or more subordinate organizations, a representation that the subordinate organizations included on such group return are (or will be) on the same annual accounting period as the central organization (see § 1.60332(d) for information on filing group returns); and

(p) Such additional information as the IRS may specify in published guidance in the Internal Revenue Bulletin or in other guidance, such as forms, instructions, publications, or a posting on irs. gov issued with respect to this revenue procedure.

(2) Additional requirements. A central organization with subordinate organizations that are private schools, charitable hospitals, or social welfare organizations must submit the information described in this section 6.04(2), as applicable, in addition to the information generally required by this section 6.

(a) Private schools. If the group application 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. 75-50, 1975-2 C.B. 587, as modified by Rev. Proc. 201922, 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 application 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. If the group application involves subordinate organizations that are or will be described in § 501(c)(4), the central organization must represent that each subordinate organization has complied with or will comply with the requirements of § 506 and Rev. Proc. 2016-41, 2016-30 I.R.B. 165. A subordinate organization may authorize an individual representing a central organization to submit Form 8976, Notice of Intent to Operate Under Section 501(c)(4), on

.02 Electronic submission. Group applications must be submitted electronically on Form 8940 at www.pay.gov, along with all information, documentation, and other materials required by Form 8940 and the instructions thereto, including the appropriate user fee. The IRS may change the procedures for the submission of group applications through guidance published in the Internal Revenue Bulletin or in forms, instructions, publications, or a posting on irs.gov issued with respect to this revenue procedure.

.03 Information about the central orga- nization.

(1) In general. A central organization must include the following information in its group application:

(a) The central organization’s name, address, and EIN; and

(b) Information establishing that it is a central organization described in section 3.05 of this revenue procedure. (2) Request concurrent with application. A central organization described in § 501(c) that has not obtained recognition of exemption at the time it files a group application may submit the group application concurrently with its own application, or, in the case of a central organization that has had its exemption automatically revoked, with its application for reinstatement (see section 4.02(7)(a) of Rev. Proc. 2026-5 (or corresponding section(s) of its successor)).

.04 Information about the subordinate organizations.

(1) In general. A central organization must include the following information and representations regarding the subordinate organizations in its group application:

(a) The name, mailing address, EIN, and date of formation or incorporation of each subordinate organization to be included in the group exemption letter (a current directory of subordinate organizations may be furnished if the directory includes the required information);

(b) A representation that each subordinate organization is affiliated with the central organization and subject to its general supervision or control;

(d) The paragraph of § 501(c) under which the subordinate organizations are or will be described;

(e) A representation that no subordinate organization is organized under the laws of a foreign country;

(f) If the subordinate organizations included in the group application are described in § 501(c)(3), a representation that no subordinate organization is a private foundation under § 509(a) or a Type III supporting organization under § 509(a) (3) and § 1.509(a)-4(i);

(g) A representation that no subordinate organization is a qualified nonprofit health insurance issuer described in § 501(c)(29);

(h) A representation that no subordinate organization (i) has had its exemption automatically revoked and (ii) not had its exemption reinstated after filing an application for reinstatement;

(i) If the subordinate organizations are described in § 501(c)(3) and classified as public charities, the paragraph(s) of §§ 509(a) and 170(b)(1)(A) (if applicable) under which they are classified;

(j) A representation that each subordinate organization sharing the same purpose has adopted a uniform purpose statement (as described in section 4.03(2)(b) of this revenue procedure) as a part of its governing instrument;

(k) The text of the uniform purpose statement(s) adopted by the subordinate organizations sharing the same purpose as part of their governing instruments;

(l) A detailed description of each subordinate organization’s purpose(s) and activities, including the sources of its receipts and the nature of its expenditures;

(m) A representation that each subordinate organization has furnished the central organization the written authorization described in section 4.06 of this revenue procedure;

(n) A representation confirming that all subordinate organizations were organized within 27 months of the submission date of the group application, or, if any subordinate organizations were organized more than 27 months before the submission date, a statement that all subordinate organizations, other than subordinate organizations recognized by the IRS as being described in § 501(c) or included in another group exemption letter immediately prior to being included in the group application, agree to be recognized as exempt from the submission date of the group application;

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behalf of the subordinate organization and to receive any communications relating to the submission.

(3) Updates to a pending group appli- cation. If a central organization determines that any of the information or representations regarding a subordinate organization set forth in a group application is not accurate after the group application has been filed with the IRS, the central organization must submit additional information to the IRS correcting the inaccurate information or representations. For example, if a subordinate organization included in a group application ceases operations and dissolves under state law after the group application was filed with the IRS, the central organization must provide an updated list of subordinate organizations to be included in the group exemption letter that does not include the organization that went out of existence.

.05 New group application 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, a central organization may file a new group application in the manner described in this section 6, but the central organization must include a description of the policies or procedures it has implemented, or intends to implement, to ensure the new group exemption letter satisfies the requirements of this revenue procedure.