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.
- Provide a list of the names, addresses, and EINs for all subordinate organizations to be included in the group exemption. If a subordinate does not have its own EIN, complete a Form SS-4 to obtain an EIN.
- If any subordinate organizations were organized more than 27 months from the date of the submission of the application, state whether those subordinate organizations are willing to be recognized as exempt only from the date of application. Please note, this does not apply for subordinate organizations that are churches as classified under Sections 509(a)(1) and 170(b)(1)(A)(i).
- Are all of your subordinate organizations exempt under the SAME paragraph of Section 501(c) (e.g., 501(c)(3), 501(c)(4), etc.)?
- Are any of your subordinate organizations classified as private foundations instead of public charities? If so, those organizations may not be included in a group exemption letter and should apply for their own recognition separately.
- Are any of your subordinate organizations a foreign organization? An organization that is organized and operated in a foreign county may not be included in a group exemption letter.
- Provide a detailed description of the purposes and activities of each of your subordinate organizations, including the sources of receipts and the nature of expenditures.
- Provide information verifying that the subordinate organizations to be included in the group exemption are (1) affiliated with your organization and (2) subject to your general control and supervision.
- Submit any policies or other documents that set forth how the central organization exercises supervision or control over the subordinate organizations.
- Provide a sample copy of a uniform governing instrument (and any amendments) which has been adopted by the subordinate organizations, or, in its absence, copies of representative instruments.
- Has each subordinate organization provided you with written authorization, signed by a duly authorized officer of the subordinate, to include that subordinate in your group exemption?
- Provide a list of the subordinate organizations that have previously been recognized as exempt from federal income tax (if any) by the IRS.
Subordinate organizations that have individual tax exemption rulings from the IRS will need to give up their individual rulings in order to be a part of this group exemption. They cannot keep both exemptions.
Also, provide a statement that you informed these subordinate organization(s) that they are giving up their individual exemption rulings from the IRS in order to be a part of this group exemption. Once part of a group, if a subordinate organization wants to re-establish its individual tax exemption, it is required to reapply to the IRS and pay the appropriate user fee.
If a subordinate wishes to keep its own individual ruling and not be a part of this group exemption, remove the subordinate from your subordinate list. Simply state that it wishes to keep its individual exemption and will not be included in this group.
See the complete list of Applying for Exemption/Miscellaneous Determination Sample Questions by topic.