Group Exemption Letters to Become More Restrictive
Proposed changes to IRS group exemption letters could result in organizations needing to re-structure their operations or seek new exemption rulings from the IRS. In Notice 2020-36 (available here), the IRS announced that as of June 17, 2020, it would no longer accept applications for group rulings under Rev. Proc. 80-27. All applications for group rulings after that date would be decided under a new final revenue procedure or other IRS guidance. Exempt organizations covered under a group letter should review the proposed changes and make plans now to comply with the changes once they become final.
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