IRS to Review Group Ruling Holders

The IRS released a notice that it has randomly selected more than 2,000 “parent” entities holding a group exemption ruling to answer additional questions regarding the relationships between the parent organization and its subordinate organizations.   According to the IRS website, the IRS would like to better understand the relationship between central or parent organizations of group rulings and their subordinates, and learn how they satisfy their exemption and filing requirements.  I estimate that there are fewer than 5,000 entities with a group ruling letter. Therefore, it is important that all parent organizations with a group ruling letter proactively confirm that their relationships are firmly within the IRS established precedents.   Similar to other areas where the IRS has engaged in compliance fact gathering, including compensation procedures and compliance with the community benefit standard, I also believe there is going to be additional audit and IRS activity in this area.  Click here for a link to the IRS questionnaire regarding group ruling relationships.

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