Proposed revenue procedure, updated group exemption letter program for section 501(c) organizations

Notice 2020-36: Proposed revenue procedure

The IRS today released an advance version of Notice 2020-36 as a “proposed revenue procedure” with updated procedures under which recognition of exemption from federal income tax for organizations under section 501(c) may be obtained on a group basis for subordinate organizations affiliated with and under the general supervision or control of a central organization.


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The proposed revenue procedure contained in Notice 2020-36 also sets forth updated procedures a central organization must follow to maintain a group exemption letter.

The proposed revenue procedure would modify and supersede Rev. Proc. 80-27 (as modified by Rev. Proc. 96-40).

Notice 2020-36 [PDF 174 KB] states that this guidance is being issued in proposed form to provide an opportunity for public comment because the IRS recognizes that, if finalized, the proposed revenue procedure would make substantial changes to the procedures set forth in Rev. Proc. 80-27 and that the application of these new procedures may impose an additional administrative burden on central organizations with group exemption letters in existence on the date the final revenue procedure is published in the Internal Revenue Bulletin (preexisting group exemption letters).

The purpose of this TaxNewsFlash is to provide text of the 63-page IRS notice.

For more information, contact a tax professional with KPMG’s Washington National Tax practice:

Ruth Madrigal | +1 202 533 8817 |

Preston Quesenberry | +1 202 533 3985 | 

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