Ezel / IRS Rulings / 202616006
Determination Letter 202616006 Released April 17, 2026 Approved Transcribed from scan

Governmental unit affiliate need not file Form 990

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 excuse it from filing Form 990, the
annual information return most exempt organizations must submit. The IRS
agreed. Under IRC § 6033(a)(3)(B), the IRS has discretion to exempt certain
organizations from the Form 990 filing requirement, and Revenue Procedure 95-48
uses that authority to relieve governmental units and their affiliates that are
exempt under § 501(a). Based on the facts provided, the IRS classified the
organization as a governmental unit or an affiliate of one and confirmed it is
not required to file Form 990. The organization remains a § 501(c)(3) entity
with all the other duties that status carries. This matters to
government-affiliated charities: qualifying under Rev. Proc. 95-48 removes the
annual Form 990 filing burden entirely.

Ruling snapshot

  • Question: Is the organization exempt from filing Form 990 as a governmental unit or affiliate of one?
  • Outcome: Approved (filing exemption granted)
  • Key authorities: IRC § 6033(a)(3)(B); Rev. Proc. 95-48; IRC §§ 501(a), 501(c)(3)

Full text (IRS public release)

Department of the Treasury
Internal Revenue Service
IRS Tax Exempt and Government Entities

Date: 01/23/2026

Employer ID number: [redacted]
Person to contact:
Name: [redacted]
ID number: [redacted]
Telephone: [redacted]

UIL: 6033.01-00
Release Number: 202616006
Release Date: 4/17/26

Dear [redacted]:

We received your request to be exempt from the requirement to file Form 990, Return of Organization Exempt from Income Tax on [redacted].

What you need to know

Internal Revenue Code (IRC) Section 6033(a)(3)(B) and the accompanying regulations provide us discretionary authority to decide that certain exempt organizations aren't required to file annual information returns on Form 990. Under this discretionary authority, Revenue Procedure 95-48 explains that governmental units and affiliates of these units exempt from federal income tax under IRC Section 501(a), aren't required to file Form 990. Based on the information you provided, we determined you qualify for classification as a governmental unit or an affiliate of this unit. Therefore, in accordance with Rev. Proc. 95-48, you're not required to file Form 990. We'll update our records accordingly.

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 a tax exempt organization in Publication 4221-PC, Compliance Guide for 501(c)(3) Public Charities.

We'll make this letter available for public inspection after making deletions such as the names, addresses, and other identifying details, as required by IRC Section 6110. We're also sending you Letter 437, Notice of Intention to Disclose Rulings and a copy of the letter as it will appear with 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.

Letter 4715 (Rev. 12-2025)
Catalog Number 57710B

If you have questions, you can contact the person listed at the top of this letter.

Sincerely,

Stephen A. Martin
Director, Exempt Organizations
Rulings and Agreements

Enclosures:
Letter 437
Redacted Letter 4715

Letter 4715 (Rev. 12-2025)
Catalog Number 57710B