Private Letter Ruling 202551046 Released December 19, 2025 Approved Transcribed from scan

IRS relieves a church-affiliated mission society from filing Form 990

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This page covers one taxpayer's ruling from 2025, which can't be cited as precedent. Ezel answers your situation under the current Code and IRS guidance, with citations.

Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
Transcribed from a scanned original: the IRS released this determination as an image-only PDF. The full text below is a machine transcription, proofread against the scan. Check the original PDF before quoting exact language.
View official IRS release (PDF)

Plain-English summary

A tax-exempt organization asked the IRS to be excused from filing the annual
Form 990 information return. A Treasury regulation, Section 1.6033-2(g)(1)(iv),
exempts a "mission society" from that filing requirement if the society is
sponsored by or affiliated with one or more churches and conducts more than
half of its activities in and directed at persons in foreign countries. The
IRS reviewed the organization's information, found it fit that description, and
determined it is not required to file Form 990. The letter reminds the group
that it still has other obligations as a 501(c)(3) public charity. This matters
because it removes a recurring annual filing burden for qualifying
church-based foreign mission organizations.

Ruling snapshot

  • Question: Is the organization, as a church-affiliated foreign mission society, exempt from the Form 990 filing requirement?
  • Outcome: Approved
  • Key authorities: Treas. Reg. § 1.6033-2(g)(1)(iv); IRC § 501(a); § 501(c)(3); § 6033

Full text (IRS public release)

Department of the Treasury
Internal Revenue Service
Date: 09/26/2025

Tax Exempt and Government Entities

Employer ID number:

Person to contact:
Name:
ID number:
Telephone:

Form 990 required:

Release Number: 202551046
Release Date: 12/19/2025

UIL: 6033.01-00

Dear

Why you're receiving this letter
This is in response to your request to be exempt from the requirement to file Form 990,
Return of Organization Exempt from Income Tax.

Treasury Regulation Section 1.6033-2(g)(1)(iv) provides that a mission society exempt from taxation under
Internal Revenue Code (IRC) Section 501(a), and sponsored by, or affiliated with, one or more churches or
church denominations that has more than one-half of the activities of such society conducted in and directed at
persons in foreign countries, isn't required to file Form 990. Based on the information you provided, we determined
you're such a mission society. Therefore, in accordance with the above regulation, you're not required to file
Form 990. We'll update our records accordingly.

What you need to know
As an organization exempt from federal income tax under IRC Section 501(c)(3), you must fulfill other
requirements. You can find helpful information about your responsibilities as tax exempt organization in
Publication 4221-PC, Compliance Guide for 501(c)(3) Public Charities.

Additional information
We'll make this determination letter available for public inspection after making deletions as
required by IRC Section 6110, such as the names, addresses, and other identifying details.
We've enclosed Letter 437, Notice of Intention to Disclose Rulings, and a copy of the letter
that shows our proposed deletions.

  • If you disagree with our proposed deletions, follow the instructions in the Letter 437 on
    how to notify us.
  • If you agree with our deletions, you don't need to take any further action.

If you have questions, you can call the contact person shown at the top of this letter. Keep a
copy of this letter for your records.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:
Letter 437

Redacted Letter 4715

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