Ezel / IRS Rulings / 202627023
Private Letter Ruling 202627023 Released July 2, 2026 Approved Transcribed from scan

IRS excuses a church-affiliated school from Form 990, but requires annual Form 5578

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 church-affiliated school below college level asked the IRS to excuse it from filing the annual Form 990. Treasury Regulation § 1.6033-2(g)(1)(vii) relieves an educational organization described in IRC § 170(b)(1)(A)(ii) (one with a regular academic program that is affiliated with a church or operated by a religious order) from filing Form 990, and § 1.6033-2(h)(2) explains what "affiliated with a church" means. The IRS determined the school qualifies and confirmed it need not file Form 990. It flagged one important catch: private schools must still certify annually that they do not racially discriminate (under Rev. Proc. 75-50): normally on Form 990, Schedule E, but a school that does not file Form 990 must instead file Form 5578 every year. The school must also continue to meet its other obligations as a § 501(c)(3) organization.

Ruling snapshot

  • Question: Does a church-affiliated school below college level qualify to be excused from filing Form 990 under Treas. Reg. § 1.6033-2(g)(1)(vii)?
  • Outcome: Approved (filing exemption granted), subject to filing Form 5578 annually.
  • Key authorities: IRC § 6033; § 170(b)(1)(A)(ii); Treas. Reg. § 1.6033-2(g)(1)(vii) and § 1.6033-2(h)(2); Rev. Proc. 75-50.

Full text (IRS public release)

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

Date: 04/10/2026

Employer ID number:

Person to contact:
Name:
ID number:
Telephone:

UIL: 6033.01-00

Release Number: 202627023
Release Date: 7/2/26

Dear

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

What you need to know

Treasury Regulation Section 1.6033-2(g)(1)(vii) provides that an educational organization below college level described in Internal Revenue Code (IRC) Section 170(b)(1)(A)(ii) with a program of general academic nature and is affiliated with a church. or operated by a religious order, isn't required to file Form 990. Treas. Reg. Section 1.6033-2(h)(2) clarifies what it means to be affiliated with a church. Based on the information you provided, we determined you qualify for classification as one of these educational organizations. Therefore. in accordance with Treas. Reg. Section 1.6033-2(g)(1)(vii). you're not required to file Form 990. We'll update our records accordingly.

However, be aware that Section 4.06 of Revenue Procedure 75-50 requires private schools provide us with annual certification of racial nondiscrimination. This is normally done on Form 990, Schedule E, Schools. If you don't file Form 990. you must complete Form 5578, Annual Certificate of Racial Nondiscrimination for a Private School Exempt from Federal Income Tax, annually to certify you're complying with Rev. Proc. 75-50

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
Letter 4715

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