Health Law Advisor

On January 16, the IRS released two documents – Notice 2026-8 and Rev. Proc. 2026-8 – which provide updated guidance for organizations regarding group tax exemptions.

The guidance also removes the 5+ year moratorium on new exemption rulings. The guidance modifies and supersedes Rev. Proc. 80-27, and incorporates updates from the 2020 notice (Notice 2020-36).

Central organizations and those of their subordinates that are included in the group exemption will generally have one year to come into compliance with the updated guidance. Under IRS Treasury regulations and related guidance, specifically regarding group exemption letters, a central organization is defined as the head or parent organization that holds a group exemption letter and exercises general supervision or control over one or more subordinate organizations. A subordinate organization is defined as a "chapter, local, post, or unit of a central organization".