The United States Internal Revenue Service (IRS) has established a “Group Exemption” process, the purpose of which is to enable a “central organization” to obtain a determination from the IRS that it (the central organization) and its “subordinate organizations” are exempt from federal income tax. Detailed information regarding the group exemption process is available in IRS Publication 557 (entitled “Tax-Exempt Status for Your Organization” and available on the IRS website at www.irs.gov/pub/irs-pdf/p557.pdf) and IRS Publication 4573 (entitled “Group Exemptions” and available on the IRS website at www.irs.gov/pub/irs-pdf/p4573.pdf).
The General Synod of the Reformed Church in America (as a “central organization”) has obtained a group exemption determination from the IRS. Agencies, institutions, assemblies (regional synods, classes, and local churches), and other entities that are controlled by an assembly of the Reformed Church in America and are located in the United States may be added to the group (and thereby be deemed exempt from federal income taxation), provided certain requirements established by the IRS are satisfied. The General Synod files reports with the IRS annually to update the roster of agencies, institutions, and assemblies of the Reformed Church in America that are a part of the group.
To Apply for Inclusion on Group Exemption Roster
To be included in the group a “subordinate organization” must:
1. Complete and submit a form requesting that it be included in the group. The form must be submitted on the subordinate organization’s letterhead. To do so, open and complete the form, adjust its formatting to fit the letterhead, print and sign it, and mail it to the address on the form. Download the form (Word doc).
2. Have a nine-digit federal employer identification number and include it in the request form described in item 1, above.
3. Submit copies of its organizational documents to General Synod Council staff for its review and approval. Instructions regarding how to submit the documents are in the request form described in item 1, above. In situations involving local churches, at least one of the organizational documents must include a provision substantially in the form of Formulary 15 in the RCA’s Book of Church Order.
4. Not have received a separate determination of exemption from the IRS.
5. Not be a “private foundation,” as defined in Internal Revenue Code Section 509(a).
The organizational documents must, among other things, include evidence that the organization (as the subordinate organization) is related to the RCA and is subject to the general supervision and control (directly or indirectly) of the General Synod (as the central organization). They also must include routine provisions establishing that it is a public charity (for example, that it refrains from participating in political activities, does not engage in substantial lobbying, does not allow earnings to inure to the benefit of individuals, does not operate for the benefit of private interests, and does not have purposes or activities that are illegal or that violate fundamental public policy).
Update Information About Your Organization
To change information about a subordinate organization that is already a part of the group, or to request that a subordinate organization be withdrawn from the group, email a request to groupexemption@rca.org.
Additionally, the United States Internal Revenue Service recently enacted a requirement that any entity with an EIN (Employer Identification Number) report to the IRS any changes to its mailing address, location, or “responsible party.” Filing this information with the IRS is necessary even if you have provided the information to the RCA general counsel’s office (so the group exemption roster can be updated). Click here for additional information.
Obtain Written Confirmation of Inclusion on the Roster
To request a letter confirming that a particular subordinate organization is included in the group, email a request to groupexemption@rca.org. Please include the following information: (a) name of subordinate organization, (b) name, email, and phone number of person requesting confirmation, and (c) relationship (of person requesting information) to the subordinate organization.
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