The IRS recently released Revenue Procedure 2026-8, replacing decades-old guidance governing group exemptions and introducing a new form: Form 15644, Supplemental Group Ruling Information.

If your central organization is a church or a convention or association of churches that holds a group exemption, you may be required to file this new IRS Form 15644.

Under the old way of doing things, the central organization used to report changes to their group exemption in an IRS letter. If you're a sole entity, this may not apply to you. Even so, this IRS update is an important reminder for every denomination, convention, association of churches, and church network to evaluate its governance and compliance practices.

What Has Changed?

With this change, central organizations that maintain a group exemption will generally use Form 15644 to:

• Update IRS records for subordinate organizations
• Add or remove subordinate organizations
• Report required organizational changes
• Terminate a group exemption, if necessary

The IRS created this new reporting process to ensure accurate and standardized information for organizations operating under group exemptions.

Why This Matters

Whether or not your organization is required to file Form 15644, every denomination and church network should ask:

• Do we have an accurate list of every subordinate organization?
• Are our governance and compliance records current?
• Do we have a documented process for adding or removing churches?
• Is someone responsible for monitoring our tax-exempt compliance throughout the year?

Leadership transitions, church plants, mergers, and reorganizations can leave outdated records in place for years. This IRS update is an excellent opportunity to review your governance systems before they become a problem.

It appears that organizations holding group exemptions have until January 2027 to bring their structures into compliance.

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We're Here to Help

At The Church Attorney®, we've spent more than two decades helping churches, denominations, and faith-based organizations navigate complex legal and tax-exempt issues with confidence.

Whether you need assistance reviewing your governance practices, evaluating your tax-exempt structure, or strengthening your compliance framework, we'd be honored to serve your ministry.

We look forward to seeing you at the webinar and the Church Law & Leadership Summit!

Blessings!