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ARTICLE · 13 MARCH 2018

Tax-Exempt Organization Restructurings Made Easier

Many tax-exempt organizations can now change their state of organization and retain their current tax exemption.

United StatesTax
Matthew Elkin
Matthew Elkin
Shira Helstrom
Shira Helstrom

Many tax-exempt organizations can now change their state of organization and retain their current tax exemption. 

Revenue Procedure 2018-15 provides that, in most circumstances, tax-exempt organizations no longer need to file new exemption applications if they change their organizational forms or states of incorporation. This Revenue Procedure makes obsolete Revenue Rulings 67-390 and 77-469, which previously required new tax-exemption applications in similar circumstances. The Internal Revenue Service (IRS) published Revenue Procedure 2018-15 in Internal Revenue Bulletin 2018-9 on February 26, 2018.

Restructuring Without a New Tax-Exemption Application

Section 501(c) organizations may engage in certain corporate restructurings without reapplying for recognition of their tax exemptions under the following conditions.

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