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Applying for Exemption/Misc. Determination: Sample Questions

Mission Society

Applications for exemption and miscellaneous determination requests are assigned to Exempt Organizations specialists for review. If additional information is necessary to make a determination, a specialist will contact the organization for the information. Here’s a list of questions that might be asked on this topic.

1. Please explain how you qualify as a mission society within the meaning of Section 1.6033-2(g)(1)(iv) of the Treasury Regulations by providing responses to the following items.

a. Please confirm that you are not described in Section 509(a)(3) of the Internal Revenue 
   Code.

b. Please confirm that more than one-half of your activities are conducted in, or directed 
    at persons in, a foreign country.

c. Please describe, in detail, how you are sponsored by or affiliated with one or more 
    churches or church denominations. Information on how you are sponsored by or affiliated 
    with one or more churches or church denominations that you may wish to provide 
    includes, but is not limited to, items in the list below. Please note that you may, but are not 
    required to, submit one or more of these items.

  • who your sponsoring/affiliated church(es) or denomination(s) are;
  • whether you share any common bonds, such as whether the affiliated or sponsoring church(es) or denomination(s) are of the same denomination as your organization;
  • whether there is an institutional relationship between you and the church(es) or denomination(s) that is affirmed by the church(es) or denomination(s), or a designee thereof; and
  • whether the church(es) or denomination(s) may direct your work or monitor how you use your funds, and, if so, how they may do so;
  • whether you have any board members you share with the church(es) or denomination(s), or that are members of their congregation(s);
  • whether the church(es) or denomination(s) have the authority to appoint or
    remove, or to control the appointment or removal of, at least one of your officers or directors;
  • whether you provide to the church(es) or denomination(s) any reports or
    speaking engagements;
  • whether you enter into written agreements with the church(es) or denomination(s)
  • whether you are covered by a group exemption letter issued under an applicable administrative procedure (such as Rev. Proc. 80-27, 1980-1 C.B. 677) to the church(es) or denomination(s);
  • whether your enabling instrument (corporate charter, trust instrument, articles of association, constitution or similar document) or by-laws affirm that you share common religious doctrines, principles, disciplines, or practices with the church(es) or denomination(s);
  • whether your corporate name indicates an institutional relationship with the church(es) or denomination(s);
  • whether you report at least annually on your financial and general operations to the church(es) or denomination(s); or
  • in the event of dissolution, your assets are required to be distributed to the church(es) or denomination(s), or to an affiliate thereof.

Please describe how any of the factors listed in Question c, above apply to you. If none of these factors describe your affiliation with or sponsorship by one or more churches or church denominations, describe any other relevant facts and circumstances that demonstrate you are affiliated with or sponsored by the church(es) or denomination(s). Submit a copy of any document that supports a determination that the relevant facts and circumstances show you are affiliated with or sponsored by the church(es) or denomination(s).

More information:

See the complete list of Applying for Exemption/Miscellaneous Determination Sample Questions by topic.

Page Last Reviewed or Updated: 21-Feb-2014