Automatic Exemption Revocation for Non-Filing: Treatment of Subordinates in Group Rulings


My organization is a subordinate in a group exemption and has filed all of its returns. My parent/central organization was automatically revoked for failing to file for three years. Does that affect my exemption?

When a parent/central organization is automatically revoked, the group exemption letter ceases to have effect regardless of whether the subordinates filed their own returns or the parent/central organization filed a group return on behalf the subordinates.  The continued effectiveness of a group exemption letter as to a particular subordinate is based on continued qualification of the parent/central organization for exemption.

Now that the group exemption is no longer in effect, the subordinates may be required to file income tax returns. A subordinate that wishes to be recognized as tax-exempt by the IRS must file an application for exemption.