IRS Presents Central Organizations with New Form for Group Exemption Reporting

It was an early Christmas for central organizations responsible for submitting information about their group exemptions to the Internal Revenue Service (IRS). On July 14, 2026, the IRS gifted them new Form 15644 (Supplemental Group Ruling Information) to help central organizations capture and report newly required information about their subordinate organizations.

During 2026, the IRS has worked to update and streamline rules and procedures for the group exemption. On March 3, 2026, Krokidas & Bluestein LLP issued a client alert, New Group Exemption Requirements, detailing January 2026 IRS Revenue Procedure 2026-8, which updated the procedures for obtaining and maintaining a group tax exemption. As part of these procedures, the IRS specified a list of information that all central organizations must submit annually to maintain a group exemption.

While unclear if the IRS checked that list twice, the required information includes: any changes to a subordinate organization’s purpose, character, method of operation, name, or mailing address; if a subordinate organization has been removed from the group exemption letter or had its exemption automatically revoked; if a subordinate organization is to be added to the group exemption; and, if no changes to subordinate organizations have been made, a statement to that effect.

To ensure that central organizations package all this required information together, the IRS developed Form 15644. Consistent with the IRS list, central organizations may use Form 15644 to:

• Update IRS records on subordinate organizations under the group exemption;
• Add or remove subordinate organizations under the group exemption;
• Terminate the group exemption;
• Notify the IRS that the group exemption is going out of existence; and
• Provide notice to the IRS of any other changes, as required by Revenue Procedure 2026-8.

All central organizations (except those that are churches or conventions or associations of churches) must complete and fax Form 15644 at least 30 days, but not more than 90 days, prior to the close of its fiscal year to the IRS at (833) 312-5228. Or, like the gift that keeps on giving, a central organization may also use the form year-round to provide updates on the above to the IRS at any time.

If you have any questions about group exemptions or tax-exemption compliance, please reach out to K&B Nonprofit attorneys Elka Sachs (esachs@kb-law.com), Jonathan Cohen (jcohen@kb-law.com), and Marguerite Lombardo (mlombardo@kb-law.com).

Krokidas & Bluestein’s Nonprofit Law Practice provides a full array of advice and guidance to nonprofit organizations of all types, on a wide range of legal matters, including tax exemption, nonprofit governance, public charities law, mergers, acquisitions and corporate affiliations, regulatory and compliance matters, employment, real estate, financing and litigation.

¹ See M.G.L. c. 93H and 201 CMR 17.00.